HomeMy WebLinkAbout; ; Jurisdictional Runoff Management Plan JRMP - January 2019; 2019-01-01Jurisdictional Runoff
Management Plan
January 2018
*Appendix A & B maps updated January 2019
*
City of
Carlsbad
January 31, 2018
CITY OF CALRS BAD
JURISDICTIONAL RUNOFF MANAGEMENT PLAN UPDATE
STATEMENT OF CERTIFICATION
I certify under penalty of law that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fine and imprisonment for knowing violations.
Elaine Lukey Date
Public Works Director
Public Works
1635 Faraday Avenue Carlsbad, CA 92008 760-602-2730 t
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Contents
Executive Summary ....................................................................................................................................... v
1 Introduction .......................................................................................................................................... 1
1.1 Purpose and Objectives ................................................................................................................ 1
1.2 Overview of City of Carlsbad ......................................................................................................... 1
1.3 Water Quality Improvement Plans ............................................................................................... 4
2 City Roles and Legal Authority .............................................................................................................. 9
2.1 Legal Authority .............................................................................................................................. 9
2.2 Enforcement Procedures .............................................................................................................. 9
2.3 City Department Program Responsibilities ................................................................................... 9
3 Non-Storm Water Discharges ............................................................................................................. 11
3.1 Introduction ................................................................................................................................ 11
3.2 Conditional Non-Storm water Discharges .................................................................................. 11
3.2.1 Discharges Associated with Separate NPDES Permit .......................................................... 11
3.2.2 Controlled Non-Storm Water Discharges ........................................................................... 12
3.2.3 Discretionary Discharge ...................................................................................................... 12
3.3 Program for Non-Emergency Fire Fighting Flows ....................................................................... 12
4 Illicit Discharge Detection and Elimination ......................................................................................... 15
4.1 Introduction ................................................................................................................................ 15
4.2 Program Elements ....................................................................................................................... 15
4.2.1 MS4 Map ............................................................................................................................. 15
4.2.2 Dry Weather MS4 Outfall Monitoring Programs ................................................................ 15
4.2.3 Source Specific Observations .............................................................................................. 16
4.2.4 Observation Reporting by City Staff .................................................................................... 16
4.2.5 Reporting and Notification .................................................................................................. 17
4.2.6 City Staff Investigation ........................................................................................................ 17
4.2.7 Program Efficiencies ............................................................................................................ 18
4.2.8 Spill Reporting, Response, and Prevention ......................................................................... 18
4.3 Enforcement ............................................................................................................................... 18
5 Development Planning ........................................................................................................................ 19
5.1 Introduction ................................................................................................................................ 19
5.2 Best Management Practice Requirements ................................................................................. 19
5.2.1 BMPs for Standard Projects ................................................................................................ 20
5.2.2 BMPs for Priority Development Projects ............................................................................ 20
5.3 Land Development Process ......................................................................................................... 21
5.3.1 Environmental Review Process ........................................................................................... 21
5.3.2 Planning ............................................................................................................................... 22
5.3.3 Plan Review ......................................................................................................................... 23
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5.3.4 Construction Verification Process ....................................................................................... 28
6 Construction ........................................................................................................................................ 31
6.1 Introduction ................................................................................................................................ 31
6.2 Project Approval Process ............................................................................................................ 31
6.3 Construction Site Inventory ........................................................................................................ 32
6.4 Best Management Practice Requirements ................................................................................. 33
6.5 Construction Site Inspections ..................................................................................................... 35
6.6 Corrective Actions and Enforcement .......................................................................................... 37
7 Existing Development ......................................................................................................................... 39
7.1 Introduction ................................................................................................................................ 39
7.2 Inventory and Tracking ............................................................................................................... 39
7.3 Best Management Practices Requirements ................................................................................ 40
7.4 Program Implementation............................................................................................................ 41
7.4.1 Inspections .......................................................................................................................... 41
7.4.2 Inspection Frequency .......................................................................................................... 43
7.4.3 Inspection Tracking and Records ........................................................................................ 43
7.4.4 Municipal Separate Storm Sewer System Program ............................................................ 43
7.4.5 Existing Flood Control Devices ............................................................................................ 44
7.4.6 Street Sweeping Program ................................................................................................... 44
7.4.7 Litter Removal ..................................................................................................................... 45
7.4.8 Pressure Washing ................................................................................................................ 45
7.4.9 Application of Pesticides, Herbicides, and Fertilizers ......................................................... 45
7.4.10 Sanitary Sewer Systems ...................................................................................................... 45
7.4.11 Special Events ...................................................................................................................... 46
7.4.12 Household Hazardous Waste Collection Services ............................................................... 48
7.5 Enforcement ............................................................................................................................... 49
8 Retrofitting and Rehabilitation in Areas of Existing Development ..................................................... 51
8.1 Introduction ................................................................................................................................ 51
8.2 Identifying Candidate Retrofits and Rehabilitation Projects ...................................................... 51
8.2.1 Retrofit Types ...................................................................................................................... 51
8.2.2 Rehabilitation Types ............................................................................................................ 52
8.3 Implementing Candidate Retrofits and Rehabilitation Projects ................................................. 53
9 Special Activities/Programs ................................................................................................................ 55
9.1 Introduction ................................................................................................................................ 55
9.2 Buena Vista Lagoon Enhancement Project ................................................................................. 55
9.3 Agua Hedionda Creek Restoration Project ................................................................................. 55
9.4 Watershed Management Area Strategies .................................................................................. 55
9.4.1 Integrated Regional Watershed Management (IRWM) ...................................................... 55
9.4.2 Sustainable Landscape Incentive Program ......................................................................... 56
9.5 Optional/Contingency WQIP Strategies ...................................................................................... 56
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9.5.1 Structural or Retrofit BMPs ................................................................................................. 56
9.5.2 Offsite Alternative Compliance ........................................................................................... 56
10 Enforcement Response Plan ........................................................................................................... 57
10.1 Introduction ................................................................................................................................ 57
10.2 Enforcement Mechanisms .......................................................................................................... 57
10.2.1 Administrative Enforcement Mechanisms .......................................................................... 57
10.2.2 Judicial Enforcement Mechanisms...................................................................................... 58
10.2.3 Escalated Enforcement ....................................................................................................... 58
10.3 Enforcement Response Plan Components .................................................................................. 59
10.3.1 Illicit Discharge Detection Elimination ................................................................................ 59
10.3.2 Development Planning ........................................................................................................ 60
10.3.3 Construction ........................................................................................................................ 60
10.3.4 Existing Development ......................................................................................................... 61
10.3.5 Correction of Violations ...................................................................................................... 61
10.4 Reporting of Non-Compliant Sites .............................................................................................. 61
11 Education ........................................................................................................................................ 63
11.1 Introduction ................................................................................................................................ 63
11.2 Municipal Staff Training .............................................................................................................. 63
11.3 Construction Site Owners and Operators ................................................................................... 63
11.4 Commercial/Industrial Facilities Owners and Operators Training .............................................. 64
11.5 Residential Community and General Public................................................................................ 65
11.6 Enhanced Education Program for Focus Areas ........................................................................... 66
11.7 Partnership Programs ................................................................................................................. 66
12 Public Participation ......................................................................................................................... 67
12.1 Introduction ................................................................................................................................ 67
12.2 Water Quality Improvement Plans ............................................................................................. 67
12.3 Local Public Participation ............................................................................................................ 67
13 Monitoring and Assessment ........................................................................................................... 69
13.1 MS4 Outfall Discharge Monitoring Station Inventory ................................................................ 69
13.2 Dry Weather Major MS4 Outfall Discharge Field Screening Monitoring .................................... 69
13.3 Non-Storm Water Persistent Flow MS4 Discharge Monitoring .................................................. 69
13.4 Wet Weather MS4 Outfall Discharge Monitoring ...................................................................... 70
13.5 Data Assessment, Reporting, and Quality Control ..................................................................... 71
13.6 WQIP WMA Monitoring Requirements ...................................................................................... 72
14 Fiscal Analysis .................................................................................................................................. 73
14.1 Expenditure Categories ............................................................................................................... 73
14.2 Staff Resources ............................................................................................................................ 73
14.3 Expenditures and Sources of Funds ............................................................................................ 74
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List of Figures
Figure 1: City of Carlsbad Map ...................................................................................................................... 3
Figure 2: CB-PA1 Focus Area - Buena Vista Creek HA ................................................................................... 5
Figure 3: CB-PA2 Focus Area - Agua Hedionda HA ....................................................................................... 6
Figure 4: CB-PA3 Focus Area - Buena Vista Creek HA ................................................................................... 7
Figure 5: City of Carlsbad Organizational Chart .......................................................................................... 10
List of Tables
Table 1: Department Roles ........................................................................................................................... 9
Table 2: Hydrology and Water Quality Analysis Checklist .......................................................................... 22
Table 3: BMP Table ..................................................................................................................................... 24
Table 4: Development Process and Standards Manual Activities ............................................................... 25
Table 5: Inspection Frequency Based on Threat Prioritization ................................................................... 36
Table 6: Highest Priority Major Outfalls and Location Description ............................................................ 70
Table 7: Field Measurements ...................................................................................................................... 70
List of Appendices
Appendix A: City of Carlsbad MS4 Map
Appendix B: City of Carlsbad Existing Development Map
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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 of the 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.
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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 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 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 of the 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 of the
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
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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 of the 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; and
• San Marcos Creek and Batiquitos Lagoon; and
• Escondico Creek (approximately 125 acres of mostly open space in the southeast corner of the
city).
All drainage basins, with the exception of Encinas Creek, terminate in lagoons. As a result, the city’s
receiving water bodies are the three lagoons and the Pacific Ocean. A map of the city, including drainages,
land uses, industrial and municipal facilities is presented below in Figure 1.
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Figure 1: City of Carlsbad Map
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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 (i.e., total coliform, fecal coliform and enterococcus), riparian habitat degradation, and
hydromodification impacts.
The city identified areas (i.e. focus 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. Descriptions and locations of the focus areas are presented below.
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CB-PA1 Focus Area
The CB-PA1 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. These facilities
have a high concentration of landscaping and turf areas, which are known types of contributors to non-
storm water discharge resulting and potential pollutant loadings.
Figure 2: CB-PA1 Focus Area - Buena Vista Creek HA
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CB-PA2 Focus Area
The CB-PA2 focus area is located south of Carlsbad Village Drive and CB-PA1. This priority area drains
south towards Agua Hedionda Lagoon (Figure 3). 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. These facilities have a high concentration
of landscaping and turf areas, which are known types of contributors to non-storm water discharge
resulting and potential pollutant loadings.
Figure 3: CB-PA2 Focus Area - Agua Hedionda HA
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CB-PA3 Focus Area
The CB-PA3 focus area is located in the Buena Vista Creek HA, just east of the Buena Vista Lagoon. This
area is a majority of commercial land use and associated parking lots, with a small residential area, that
drain to a single outfall. Past monitoring efforts at this outfall has identified persistent flow and bacteria
exceedances.
Figure 4: CB-PA3 Focus Area - Buena Vista Creek HA
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.
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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 10 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 of the departments and their overall roles
in the city operations, please see the city’s website at www.carlsbadca.gov.
Table 1: Department Roles
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
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Department Roles
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 Error! Reference source not found., identifies these
departments in relation to the city management.
Figure 5: City of Carlsbad Organizational Chart
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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.
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 Permit
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 at or below the groundwater table
to extract groundwater)
• Water from crawl space pumps
• Water from footing drains
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.
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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; these SWPPPs are reviewed annually and updated on an
as-needed basis. The BMPs incorporated at Fire Stations are listed below:
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• 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 trainings 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 of the 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 of the 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 of the 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 MS4 Map
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 of the 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 13, Monitoring
Programs.
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The intent of the 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. 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 147) 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 on 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 Watershed Protection Program. City maintenance and
operations staff can reach the Watershed Protection Program through the following methods:
• City of Carlsbad Storm Water Hotline, (760) 602-2799
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• City of Carlsbad Watershed Protection Program e-mail: stormwater@carlsbadca.gov
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
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 Watershed 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 Watershed 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 of the issue, investigate, and determine
the appropriate course of action in a timely matter. Within the city’s selected focus areas (CB-PA 1, CB-
PA2, CB-PA3), a maximum response time of 45 minutes from the time of notification has been established
for initiating response investigations. This response time is expected to eliminate discharges while they
are occurring and provide an opportunity to immediately educate or issue enforcement proceedings as
necessary. If the responsible party is found, and depending on the severity of the 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 10, 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.
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4.2.7 Program Efficiencies
The city implemented a new computer database compatible with mobile devices. This system lets
Watershed Protection Program staff assess and resolve reported/discovered illegal discharges more
efficiently and comprehensively by enabling the following abilities in the field: creation of code cases;
direct attachment of photos to the code case; review of all previous inspection of facilities including
photos taken; and automated notification to office staff to create and send enforcement notices. The
inspectors have the ability to directly enter all inspection info (including photos) into the database during
the inspection. Upon completion of inspections, automated tasks are immediately sent to office staff to
create and send inspection forms, as well as any related enforcement notices. This process has eliminated
the time-consuming steps of filling out inspection forms on paper, scanning and saving them, attaching
photos, and manually entering the data into a database.
4.2.8 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.
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 10,
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 Storm Water requirements are located in the city’s Engineering Standards Manual (Standards
Manual). The Standards Manual includes guidelines and procedures on how storm water requirements
are applied to the different types of development and redevelopment projects. These requirements apply
to both private and public development projects. The storm water requirements are more specifically
located in the SWPPP Manual (Volume 4) and the BMP Design Manual (Volume 5) of the city’s Engineering
Standards Manual. Please follow the following link for the city’s Standards Manual:
http://www.carlsbadca.gov/services/building/codes/lde.asp.
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. For minor activities, such as re-roofing and interior remodels, etc certain projects are
considered exempt from storm water requirements. Refer to the Manual for a comprehensive list of
activities exempt from storm water. For projects not considered exempt, they will normally fall into one
of two categories for 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
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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.
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 the city’s E-36 form found online at the following link:
http://www.carlsbadca.gov/services/building/forms/engineering.asp . Although BMPs do not need to be
sized by a technical report (engineered), using E-36 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 Storm Water 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 Storm Water projects are incorporated during planning and/or plan
review process through the normal project development process using E-36 of the Standards Manual.
5.2.2 BMPs for Priority Development Projects
Volume 5 of the 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 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.
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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
included BMP selection and sizing methods in Volume 5.
The city has Storm Water Quality Management Plan (SWQMP) 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 for the project are
designed to meet both treatment and HMP requirements. The Standards Manual includes an integrated
BMP sizing approach for applicants to select and size BMP’s to satisfy both these requirements.
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.projectcleanwater.org/images/stories/Docs/LID/countyofsd_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 of the 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 of the updated Initial Study Checklist that includes specific hydrology and water
quality analysis the city uses during the environmental review process.
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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 of the 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)?
c. Substantially alter the existing drainage pattern of the site or area, including through the
alteration of the course of a stream or river, in a manner, which would result in substantial
erosion or siltation on- or off-site?
d. 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?
e. 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?
f. Otherwise substantially degrade water quality?
g. 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?
h. 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?
l. Impact aquatic, wetland, or riparian habitat?
m. Change receiving water quality (marine, fresh or wetland waters) during or following
construction?
n. Increase any pollutant to an already impaired water body as listed on the Clean Water Act
Section 303(d) list?
o. Increase impervious surfaces and associated runoff?
p. Result in the exceedance of applicable surface or groundwater receiving water quality
objectives or degradation of beneficial uses?
If the project has potential impacts to water quality, technical reports (i.e. preliminary Storm Water
Quality 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 SWQMPs includes the same basic content of a final
SWQMP 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 the current City SWQMP requirements, please refer to the following City website:
http://www.carlsbadca.gov/civicax/filebank/blobdload.aspx?BlobID=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 overlays to determine whether
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discretionary action is first required before design begins. If the entitlement process is required, submittal
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?BlobID=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 of the 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?BlobID=22711.
If the project thresholds trigger Priority Development
Requirements, a preliminary SWQMP is prepared for City
review (mimics the environmental review process). Staff
reviews the preliminary SWQMPs 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
SWQMP to ensure they are included in the project design.
For development projects subject to Standard Storm Water Requirements, staff use the checklist (E-36
form) to ensure typical BMPs are deployed for the project.
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 SWQMPs 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 SWQMP.
• 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 SWQMP must also be included.
Private Development
If a preliminary SWQMP is not submitted,
the application is deemed incomplete
and the applicant is notified.
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 SWQMP) 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
SWQMP 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. Our GIS system is used to generate reports
on TCBMPs in the city. Below is a sample of the TCBMP table included on these plans:
Table 3: BMP Table
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 of the 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 SWQMP. 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 SWQMPs. For a copy of the template
Private Development
The City requires a SWSQ and SWQMP 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?BlobID=22692 .
The City’s grading plan submittal
checklist, can be found at:
http://www.carlsbadca.gov/civicax/file
bank/blobdload.aspx?BlobID=22691.
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SSPCBMP plan, refer to http://www.carlsbadca.gov/civicax/filebank/blobdload.aspx?BlobID=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 SWQMPs 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 SWQMP on file with the city.
For plan reviews subject to Standard Storm Water Requirements, staff use the checklist (E-36 of the
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 Process Review
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 SWQMP 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
• SWQMP 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 Process Review
Documents/References
Application Review
City staff reviews application, site plans and accompanying
reports and documents including any SWQMP,
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 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
• SWQMP 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
SWQMP 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 SWQMP, 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, SWQMP
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
• SWQMP 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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Development
Process Stage Standards Manual Activity Description Process Review
Documents/References
Construction Plan
Approval
City approves construction plans and accompanying
Construction SWPPP and SWQMP 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 of the permit, construction plans,
Construction SWPPP, single sheet post construction BMP
site plan and SWQMP 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 SWQMP
• 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
• SWQMP
• 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, SWQMP and Municipal Permit. During
construction City project inspector reviews construction
for compliance with all plans, the Construction SWPPP,
SWQMP 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
• SWQMP
• 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
• SWQMP
• 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).
• SWQMP
• 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 prior to occupancy.
This process requires written verification from the developer, engineer of work, or other responsible party
that BMPs were installed in accordance with the SWQMP. 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 (SWQMPs) into the digital management
system (HPRM). This allows these water quality reports to be accessed by CM&I inspectors, reviewers,
and researchers. Having access to SWQMPs 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 BMPs. 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 Drawing#
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 SWQMP 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@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 prior to a site inspection. The inspector will use
the structural BMP inspection form) and the following criteria to review and determine the
condition of the treatment control BMP. The condition of each structure is rated using:
a. Good: Currently no maintenance or corrective action is required for the 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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6 Construction
6.1 Introduction
This section describes the requirements of the 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 of the 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-storm water 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.
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6.3 Construction Site Inventory
The management of the construction site inventories is divided as follows:
Private Development
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 an Excel spreadsheet to track the following project information:
1. Project status (active, inactive, completed, finaled);
2. Project threat prioritization;
3. Project and grading number;
4. 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 of the 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 proponent 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
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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.
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 of ten 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 Erosion Control Plans are reviewed prior to 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 required to obtain CESSWI certification and complete bi-monthly storm water training on construction
site BMPs and the appropriate application. In addition, inspectors are encouraged to attend conferences,
workshops, and other professional learning opportunities in an effort to stay current with the storm water
industry standards and practices. 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
Property Owners/Developers/Contractors working at active construction sites in Carlsbad are required to
comply with all applicable storm water regulations and implement BMPs in accordance with CASQA
guidelines. Each operator must implement effective BMPs to reduce discharges of pollutants from
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construction sites. These BMPs must be site specific, seasonally and construction phase appropriate, and
implemented at each construction site year-round. The following are the minimum BMPs required at all
sites throughout the year:
• The contractor/developer must provide the name and phone number of the QSP or erosion
control professional responsible for BMP compliance. The QSP or erosion control professional
must conduct a BMP compliance inspection prior to a forecasted event of 50% or greater within
48 hours, after a rain event, and weekly between October 1 and May 1 of each year.
• The city reserves the right to temporarily stop work on any private construction site that may have
the potential to contribute to storm water pollution during a forecasted rain event due to lack of
BMPs, proximity to an environmentally sensitive area, previous compliance issues, amount and
duration of rain expected, and/or any storm water compliance issue. Each site will be evaluated
on a case by case basis to determine if a temporary stop work is necessary.
• An updated SWPPP map is required to be maintained for all projects. The SWPPP map must show
BMP installations, locations, and status updates.
• 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;
• The project proponent must be able to deploy standby BMPs within 48 hours of a predicted storm
event (a predicted storm event is defined as a forecasted, 50% chance of rain by five (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 of the site. Erosion control BMPs will be installed and maintained for all completed slopes
prior to 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;
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• BMPs must be stockpiled at various locations throughout the project site for the duration of the
rainy season.
• Whenever there is a 50% chance or greater of a rain within a three (3) day forecast, the inspector
will verify that BMPs are adequately stockpiled. BMPs must be ready for deployment when there
is 50% chance of a rain event within a 48-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 with probability of precipitation of greater than 50%. In addition, treatment control BMPs
must be inspected and/or serviced prior to 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 workers, including sub-contractors, must be trained on the importance of storm
water pollution prevention and BMP maintenance prior to October 1 of each year and prior to the
commencement of work. Training records must be retained with the SWPPP and available upon
request.;
• 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.
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 is
different in these areas vs. non-Focus Areas.
The table below reflects the inspection
frequencies for the various project
categories.
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Additional Controls Required for Project Sites Located Within the High Priority Focus Areas (WQIP Area)
The High Priority Focus Areas are located south of Buena Vista Lagoon, north of Agua Hedionda Lagoon,
and west of Interstate 5. There is also a small designated area located west of El Camino Real and south
of Highway 78. For project sites located within the High Priority Focus Areas, the following additional
controls are required to be implemented at all times to the maximum extent possible:
• Maintain vegetative cover, as much as possible, by developing the project in a phased approach
to reduce the amount of exposed soil at any one time;
• Limit the areas of active construction to five acres at any one time;
• Provide 100 percent soil cover for areas of inactive construction throughout the duration of the
project;
• Provide perimeter control at all appropriate locations along and at all storm drain inlets. Perimeter
protection will be upgraded and must provide sufficient protection from run off during rain
events;
• Provide vegetated buffer strips between the active construction area and any water bodies; and
• Provide stabilized construction entrances that limit vehicle and foot traffic.
Table 5: Inspection Frequency Based on Threat Prioritization
Threat
Priority
Minimum Inspections Required Minimum
Wet Season
Inspections
Minimum
Dry Season
Inspections
Minimum
Required
Inspections Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun 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 7 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 a combination of
erosion, sediment, and non-storm water BMPs to meet the minimum water quality protection
requirements and prevent the discharge of pollutants into storm water and receiving waters;
• Checking for coverage under the Construction General Permit (CGP), Waste Discharger
Identification (WDID) number, and CGP SWPPP during the pre-construction meeting. The city will
continue to work with RWQCB staff to ensure compliance at these sites;
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• Assurance of compliance with applicable ordinances, permits and other site-specific
requirements;
• Visual observations of actual or potential non-storm water 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 and electronic
database 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 and database 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 10.
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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 Watershed Protection staff maintain a watershed-based inventory of all industrial facilities and
commercial sites/sources within the city’s jurisdiction. A copy of the 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 of the 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. For Municipal facilities, the city develops and maintains written BMP
Plans/SWPPPs which are updated on an as-needed basis. The city also requires the use of pollution
prevention methods to address the HPWQCs (indicator bacteria, riparian habitat degradation,
hydromodification impacts) 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. Property-Based Inspections/Patrol Inspections (Focus Areas) – Inspections of all
properties and businesses via patrols in each of the CB-PA1, CB-PA2, and CB-PA3 focus
areas will include:
i. Visual inspection of all public streets;
ii. Inspections of each existing development property;
1. Each commercial/industrial property;
2. Each residential property;
iii. Identification of active dry weather discharges and evidence of historical
discharges;
iv. Identification of pollutant generating activities and areas that may contribute wet
weather storm water pollutant loading; and
v. Performing follow-up with property owner/manager on identified issues to
resolve discharges and/or potential pollutant discharges.
b. Property-Based Inspections/Patrol Inspections (Non-Focus Areas) – 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.
c. 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.
d. 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.
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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.
The city will perform 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.
Property-based inspections/patrols of each property in the City of Carlsbad’s selected focus areas will be
performed at least once annually. In all other areas within the city’s jurisdiction, the city will inspect at
least 20 percent of the existing development inventory, annually.
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.
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 of the 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; and
• The date that problems or violations were resolved.
The city is currently developing an updated Municipal facility form so that City inspectors can capture
additional information during site visits. This includes assessment on general site conditions, landscaping
practices, materials and waste BMPs, equipment and vehicle storage, non-storm water management,
erosion and sediment control BMPs, MS4 facilities on-site, and corrective/required actions based on the
inspection.
In addition to existing development inspections, daily inspections are completed at Municipal facilities
that have staff onsite. Staff gather and document all required information and data listed above.
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
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as needed, the following types of facilities: catch basins, curb inlets, under sidewalk drains, channels, and
detention/desiltation basins.
The city will implement the following schedule for inspection and cleaning of MS4:
• Once a year the city will inspect/clean all MS4 facilities determined to be High Priority between
May 1st and September 30th of each year. Priority of MS4 facilities is determined by location,
(e.g. proximity receiving water) type of structure, (e.g. TCBMP) and/or inspection history (e.g.
historically collected higher volumes of material.) All remaining MS4 facilities/structures will be
inspected at any time during the calendar year. Inspections are conducted to ensure the following:
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 of the sites cleaning activities.
During rain events staff from Public Works - Streets Division will be out from beginning of rainfall to do
the following:
• Clear debris from inlets, grates, pipe openings, and road shoulders
• Remove debris from roadways prior to entering the conveyance system.
• Provide emergency erosion/sediment control as needed.
• 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.
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 storm water 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
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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 sea wall) 2 times per month;
4. Focus Areas (CB-PA1, CB-PA2, and CB-PA3) every 2 weeks.
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. Recommended best management practices include berming and
vacuuming wash water and disposing of it to the sanitary sewer or a vegetated area.
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/supervised in accordance with state
regulations. All certifications are kept on file at the city’s Parks Division. 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 Sheets (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.
BMPs for pesticide 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).
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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 of the 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 of the 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 of the Wastewater Division is to perform video inspections of the 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:
• Street Festivals;
• Marathons;
• Taste of Carlsbad;
• Art Splash.
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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 entering the 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.
• 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).
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• 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 of the special event and identifies all of the drain inlets (and other entry ways to the storm drain
system). This application will be reviewed and approved by the city prior to 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
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
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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 10, 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 of the 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 of the 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 city will consider the following types
of rehabilitation projects when evaluating applicability:
• 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.
Agua Hedionda Creek Restoration Project
The city has identified an area along Agua Hedionda Creek that will include approximately 2.43 acres of
wetland area and 5.5 acres of upland habitat for restoration to serve as a regional flood control detention
basin. See Section 9, Special Activities/Programs for more information.
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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; and/or
• Private property owners.
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9 Special Activities/Programs
9.1 Introduction
The City of Carlsbad has designed special activities and programs to be implemented within the Carlsbad
Watershed WMA. These activities and programs will be implemented by the city in addition to the
requirements of Permit Provisions E.2 through E.7. Furthermore, Watershed Management Area Strategies
have been designed for the watershed. These strategies are optional regional or multi-jurisdictional BMPs,
incentives, or programs that may be implemented to effectively prohibit non-storm water discharged to
the MS4, reduce pollutants in storm water discharges from the MS4 to the maximum extent practicable,
protect the beneficial uses of receiving waters from MS4 discharges, and/or achieve the interim and final
numeric goals.
9.2 Buena Vista Lagoon Enhancement Project
The Buena Vista Lagoon Enhancement Project is being led by the San Diego Association of Governments
(SANDAG) in partnership with Caltrans and the City of Oceanside. The Buena Vista Lagoon Enhancement
Project includes engineering studies and the preparation of an Environmental Impact Report (EIR) to
analyze possible approaches to enhancement of the lagoon. Numerous federal, state and local agencies
and organizations have cooperated in the past in an effort to gain consensus on a solution. Future
enhancements to the Buena Vista Lagoon could serve as mitigation for potential impacts from the I-5 and
rail improvements.
9.3 Agua Hedionda Creek Restoration Project
The Agua Hedionda Creek Restoration Project consists of the construction of a regional flood control
detention basin, and creation of wetland habitat with upland habitat buffers. The project is located within
the northeast quadrant of the city along Agua Hedionda Creek and will include approximately 2.43 acres
of wetland area and 5.5 acres of upland habitat. The goals of the project are to enhance existing wetland
habitat, and re-establish wetland upland habitat. The project is expected to improve and increase the
receiving water’s functions and services (e.g. water filtration, sensitive wildlife and plant habitat). Once
completed, the restored area will be included in the City of Carlsbad’s Habitat Management Plan for long-
term maintenance and monitoring.
9.4 Watershed Management Area Strategies
9.4.1 Integrated Regional Watershed Management (IRWM)
Coordinate with Integrated Regional Watershed Management (IRWM) regional water managers to plan
for and implement water quality improvement projects (retrofits, stream rehabilitation, or other
projects). In order to trigger the implementation of this strategy, the following must occur:
• Interim goals are not met;
• Progress towards numeric goals is not adequate;
• Staff resources are identified and secured; and/or
• Adaptive management informs the jurisdictions to implement.
Resources required to implement the strategy include participation as a stakeholder in the IRWM Program
as appropriate, council approval of an IRWM proposed project, and staffing necessary to implement any
identified project. Participation as a stakeholder in the IRWM program will occur as needed and if funded,
to encourage applicable project adoption in the Carlsbad WMA. Individual projects and further
participation in grant funding offered through this IRWM will be assessed on a case-by-case basis.
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9.4.2 Sustainable Landscape Incentive Program
The purpose of the Sustainable Landscape Incentive Program is to encourage landscape retrofits.
Implementation of this strategy may be triggered if: (1) it has been determined by the County of San Diego
through adaptive management that implementation is necessary; and (2) all of the necessary resources
have been secured. Resources required to implement this strategy include staff resources, grant funding,
incentive items, and partnerships. This strategy addresses pollutants from residential areas, nurseries,
and greenhouses.
9.5 Optional/Contingency WQIP Strategies
9.5.1 Structural or Retrofit BMPs
This strategy includes the implementation of structural (engineered) BMPs or retrofit of existing structural
BMPs to address flow and/or pollutant issues. This strategy is triggered if:
• Interim goals are not met;
• Progress towards numeric goals is not adequate;
• Staff resources are identified and secured; and/or
• Adaptive management informs the jurisdictions to implement.
If implemented, structural BMPs will be integrated into the city’s Capital Improvement Program for
planning, design and construction. Many of the city’s typical capital projects are funded through dedicated
sources, e.g. transportation tax dollars. Structural BMPs will have to identify alternative sources of
funding, e.g., grants or partnerships, and therefore may take longer to process than typical capital
projects. It is estimated that structural BMP projects may take five years to secure the resources necessary
to initiate each project within the strategy.
9.5.2 Offsite Alternative Compliance
The County is currently implementing Phase 1 of the Offsite Alternative Compliance Program as defined
in the WPO, Section 67.811(b)(4)(c). This phase allows for an Applicant-Implemented Offsite Alternative
Compliance Project (ACP) project. This program became effective on February 26, 2016 and allows for a
developer to wholly or partially satisfy their on-site storm water compliance obligations through the
implementation of an ACP that is owned or constructed by the PDP project applicant. The city will develop
an alternative compliance program utilizing the guidelines established in the accepted Water Quality
Equivalency Guidance for Region 9 and will incorporate potential candidate project areas identified in the
Watershed Management Area Analysis. The city is also exploring the development of a possible In-Lieu
Fee program.
The following all will need to be satisfied to trigger this strategy: (1) The Copermittees finalize water
quality equivalency standards for riparian habitat and submit it to the RWQCB for approval; (2) the
RWQCB approves the water quality equivalency standards; (3) an acceptable framework for allocating
credits for offsite BMPs is developed by the Copermittees and approved by the city; (4) the program does
not require the city to take on unfunded long-term maintenance responsibility for BMPs used as a means
of compliance by private projects; and (5) adequate staffing resources have been obtained.
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10 Enforcement Response Plan
10.1 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 of the 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 for the 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.
10.2 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.
10.2.1 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 of the 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.
10.2.2 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
10.2.3 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.
10.3 Enforcement Response Plan Components
10.3.1 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 enforce compliance, and follow-up
inspections are conducted to confirm 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
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activities necessary to eliminate the illicit discharge at his or her own expense. The activities necessary
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.
The nature of the city’s enforcement approach is determined on a case-by-case basis and is based on
factors such as the severity of the violation, the threat to human health or the environment, site-specific
circumstances, and past compliance history. If the situation is determined to pose an immediate risk to
public health or the environment, the city may coordinate with other agencies or teams that are
specifically trained to assess and mitigate emergency situations (e.g., those involving hazardous wastes or
materials). If the discharge is a significant threat to water quality and/or human health, the San Diego
Regional Water Quality Control Board (RWQCB) will be notified.
10.3.2 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, withholding the release of securities 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,
final inspections for building permits 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.
10.3.3 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.
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10.3.4 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
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.
10.3.5 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.
10.4 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. For both instances, the written notification may be provided electronically by email to
RB_9@waterboards.ca.gov.
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11 Education
11.1 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.
11.2 Municipal Staff Training
Storm water training for municipal departments and personnel will include general training and job
specific training using appropriate topics. The objectives of the 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 annually 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 Watershed 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 Watershed 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.
11.3 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 SWQMPs 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 of the 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.
11.4 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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11.5 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 city.
Presentations and outreach can be available to all levels from kindergarten to high school.
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11.6 Enhanced Education Program for Focus Areas
Within each of the City of Carlsbad focus areas (CB-PA1, CB-PA2, and CB-PA3), an enhanced education
program has been selected as a strategy to address pollutants of concern. This strategy targets sources
that include Municipal Fixed Facilities, Industrial and Commercial Facilities/Owners, Residential, and the
General Public. This strategy will be applied in both wet and dry weather conditions and aims to target
bacteria, trash, heavy metals, nutrients, toxicity, oil and grease, riparian habitat, sediment, and pesticides.
Enhancements to the education program can include:
1. Priority pollutant specific education and outreach program to be conducted in CB-PA1, CB-PA2,
and CB-PA3 for residents and commercial/industrial facilities related to priority pollutants within
the HA. The materials will have an emphasis on discharges to the city’s MS4 and the receiving
waters impacts.
2. 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.
3. As the CB-PA1 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.
4. 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.
11.7 Partnership Programs
The City of Carlsbad will partner with entities to coordinate, share, or back projects and programs that
have the potential to support overall water quality objectives. These partnerships may come in various
forms including, but not limited to:
• Coordination/information sharing meetings;
• Review of projects;
• Joint grant applications;
• Agreements;
• Private or joint funding; and
• Generating letters of support for projects.
It is vital for the city to collaborate with outside entities in order to achieve overarching water quality
improvement objectives. Based on the MS4 discharge permit, the city has a direct responsibility for the
discharges generated from their MS4 systems. Outside entities have a significant interest in downstream
waterways. Partnerships may offer a synergistic pathway to achieving desired outcomes in both MS4
discharges and in waters.
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12 Public Participation
12.1 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.
12.2 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 of the WQIP, but also the implementation mechanisms included in
the city’s JRMP.
The public participation process of the WQIP was and continues to be rigorous and transparent. All public
meetings are communicated through all city media outlets, including social media.
12.3 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
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13 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 of the Carlsbad WMA.
13.1 MS4 Outfall Discharge Monitoring Station Inventory
The city has identified 147 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.
13.2 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
• 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 147).
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 connections or illegal dumping; and
• 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.
13.3 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 of the 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; and
• 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 . 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; and/or
• The outfall is found to be an authorized discharge or covered by a separate NPDES permit.
Table 6: Highest Priority Major Outfalls and Location Description
MS4 Outfall ID Location
19C-1 North of Sunny Creek Rd.
1D-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 13.2) 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 .
Table 7: Field Measurements
Parameter Units
Temperature oC
Specific Conductivity mhos/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.
13.4 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 1D-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 1D-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 of the water
quality improvement efforts. Based on the results, the city may implement additional efforts to achieve
water quality benchmarks set for the WMA.
13.5 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 for a 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.
Carlsbad JRMP January 2018
72
13.6 WQIP WMA Monitoring Requirements
As part of the 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;
• Special Studies;
• Storm Water Monitoring Coalition Regional Monitoring; and
• 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
• Carlsbad 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.
Carlsbad JRMP January 2018
73
14 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.
14.1 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 of the 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) for the 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.
14.2 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.
Carlsbad JRMP January 2018
74
14.3 Expenditures and Sources of Funds
Annually, the city will present its expenditures for the fiscal year as well as a proposed budget for the 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.
Carlsbad JRMP January 2018
Appendix A: City of Carlsbad MS4 Map
Carlsbad JRMP January 2018
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904.21
904.31
904.4
904.51
904.61
N
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SRANCHOSANTAFER DSMELROSEDRCANNONRD
NELCAMINOREALMS4 Map and CorrespondingDrainage Areas E.2.b.(1)
I00.50.25Miles
0 1,000 2,000Feet
Document Path: J:\RequestsMarch2015\PublicWorks\PEM\Stormwater\RITM0012724_18\MS4map_36x60_2018.mxd, Date: 9/17/2018
MS4 Outfall Discharge Monitoring Station Inventory:
!.Highest Priority Non-storm Water Persistent Flow with Unit ID
!.Persistent Flow
!.Not Persistent Flow
Other Outfalls:
!(Carlsbad MS4 Outfall
!(Other MS4 or Private Outfall
""/Inlet to MS4
MS4 Pipe Owned/Maintained by the City of Carlsbad
MS4 Channel Owned/Maintained by the City of Carlsbad
MS4 Pipe NOT Owned/Maintained by the City of Carlsbad
MS4 Channel NOT Owned/Maintained by the City of Carlsbad
Non-impaired Receiving Waters
Impaired Receiving Waters
Hydrologic Sub-areas:
904.21
904.31
904.4
904.51
904.61
Carlsbad JRMP January 2018
Appendix B: City of Carlsbad Existing Development Map
Carlsbad JRMP January 2018
Page intentionally blank for printing purposes
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Document Path: \\FDSTORE01\Gis-App\RequestsMarch2015\PublicWorks\PEM\Stormwater\RITM0012724_18\JRMPDevelopment_11x17.mxd, Date: 9/12/2018
I
Municipal, Industrial, Commercial, Residential Map
!.Municipal Facility
!.Commercial Facility
!.Industrial Facility
Receiving Waters
Commercial Area
Residential Management Area
General Plan Open Space
Hydrologic Sub-areas:
904.21
904.31
904.4
904.51
904.61