HomeMy WebLinkAbout; ; JURMP Annual Report 2002-2003 NPDES Permit Order No. 2001-01; 2004-01-01
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TABLE OF CONTENTS
Executive Summary iv
Section 1: Introduction 1
1.1 Report Organization
Section 2: Municipal 3
2.1 Source Identification and Threat to Water Quality Prioritization
2.2 Pollution Prevention Practices and Best Management Practices
Implementation
2.3 Maintenance of Municipal Separate Storm Sewer System (MS4)
2.4 Management of Pesticides, Herbicides, and Fertilizers Actions
2.5 Inspection of Municipal Areas and Activities
2.6 Enforcement of Municipal Areas and Activities Actions
2.7 Self-Assessment
Section 3: Industrial 15
3.1 Source Identification and Threat to Water Quality Prioritization
3.2 Pollution Prevention
3.3 Best Management Practices (BMP) Implementation
3.4 Industrial Monitoring Program
3.5 Inspection of Industrial Sites
3.6 Enforcement of Industrial Sites
3.7 Non-compliance Notification Action Plan
3.8 Self-Assessment
Section 4: Commercial 25
4.1 Source Identification and Threat to Water Quality Prioritization
4.2 Pollution Prevention
4.3 Best Management Practices Implementation
4.4 Inspection of Commercial Sites
4.5 Enforcement of Commercial Sites and Sources
4.6 Self-Assessment
Section 5: Residential 37
5.1 Threat to Water Quality Prioritization
5.2 Pollution Prevention (including HHW and Oil recycling programs)
5.3 Best Management Practices Implementation
5.4 Enforcement of Residential Areas and Activities
5.5 Self-Assessment
Section 6: Land-Use Planning 47
6.1 Assessment of General Plan
6.2 Modification Development Project Approval Process
6.3 Revisions to Environmental Review Process
6.4 Education on New Development and Redevelopment
6.5 Self-Assessment
Section 7: Construction 52
7.1 Source Identification and Threat to Water Quality Prioritization
7.2 Pollution Prevention
7.3 Construction and Grading Approval Process
7.4 Best Management Practice Implementation
7.5 Inspection of Construction Sites
7.6 Enforcement of Construction Sites
7.7 Reporting of Noncompliant Sites
7.8 Education on Construction Activities
7.9 Self Assessment
Section 8: Illicit Discharges Detection and Elimination 60
8.1 Monitoring Programs
8.2 Public Reporting of Illicit Discharges and Connections
8.3 Illicit Connection/Illegal Discharge (IC/ID) Investigation and Follow-up
8.4 Elimination of Illicit Connections and Discharges
8.5 Ordinance Enforcement
8.6 Spill Response and Sanitary Sewer System Maintenance
8.7 Self-Assessment
Section 9: Outreach and Education 71
9.1 Municipal Departments and Personnel
9.2 Construction Site Owners and Developers
9.3 Commercial and Industrial Owners and Operators
9.4 Residential Community, General Public, and School Children
9.5 Quasi-Government Agencies/Districts
9.6 Self-Assessment
Section 10: Public Participation 85
10.1 Public Meetings and Hearings
10.2 Feedback Mechanisms
10.3 Community Events and Volunteer efforts
10.4 Other Public Participation Opportunities
10.5 Self-Assessment
Section 11: Assessment of JURMP Effectiveness 91
11.1 Program Planning, Implementation, and Assessment
11.2 Targeted Outcomes
11.3 FY 03-04 Action Plan
Section 12: Fiscal Analysis 108
12.1 Storm Water Facility Capital Improvement Program
12.2 Storm Water Facility Maintenance and Operation Program
12.3 Storm Water Program Administration
12.4 Illicit Detection and Illegal Discharge Enforcement Program
12.5 Commercial/Industrial SWPPP Inspection Program
12.6 Construction Related SWPPP Review and Inspection Program
Section 13: Special Investigations 112
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 ii
Section 14: Conclusion and Recommendations 113
14.1 Recommended activities for FY 03-04
14.2 Proposed JURMP Revisions
All Appendices and the City of Carlsbad 2003 Dry Weather Field Screening and
Analytical Monitoring Program 2003 report are under separate cover.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 iii
Executive Summary
Overview
The City of Carlsbad’s (City) Jurisdictional Urban Runoff Management Plan (JURMP)
Annual Report addresses the implementation of the Municipal Storm Water Permit -
Order 2001-01, NPDES No. CAS018758 (Permit) issued February 21, 2001. There
were 20 Copermittees originally listed in the Order. This Annual Report covers the
period from July 1, 2002 through June 30, 2003, which corresponds to the City of
Carlsbad’s Fiscal Year 2002-2003 (FY 02-03).
FY 02-03 represented Carlsbad’s second year implementing the JURMP. Since the last
Annual Report submission, many procedures have been streamlined to efficiently
manage data, monitor sites, and track the numerous businesses that operate in the City.
Planning, construction, and maintenance operations have implemented new processes
to further incorporate storm water pollution prevention practices into internal activities as
well as activities enforced by City departments. Highlights of each major component of
the JURMP are listed below.
Municipal
The City of Carlsbad municipal facilities are composed of administration buildings,
recreational areas, buildings, maintenance yards, water reservoirs, water pump stations,
sewer lift stations, a road system, parking facilities, the storm drain system, pressure
regulator vaults, and fire stations. Municipal facilities maintain the City’s infrastructure
that supports Carlsbad’s quality of life. These municipal activities have the potential to
contribute to water pollution if BMPs are not properly implemented.
During FY 02-03, all municipal facilities were inventoried and mapped, and 101 facilities
were inspected, including all high priority facilities. Pollution prevention and other Best
Management Practices (BMPs) were implemented at all City facilities, and Storm Water
Pollution Prevention Plans (SWPPPs) were implemented at all corporate yards.
The Streets Maintenance Division of the Public Works Department is responsible for
maintaining City streets as well as the storm water conveyance system. Staff inspected
all catch basins, brow ditches and channels. Maintenance work resulted in the removal
114 tons of sediment and debris from these areas of the storm drain system. City litter
crews removed 310 cubic yards of litter from roadsides, and the contracted street
sweeping service removed 2230 tons of sediment from all City roads and parking lots.
The Park Maintenance Division is responsible for maintaining, preserving and enhancing
over 300 acres of park facilities, school athletic fields, beach accesses, and landscapes
at various civic facilities. This includes the maintenance of eight community parks and
26 special use areas. In addition, the Park Department manages over 625 acres of
open space/undeveloped areas that includes trash removal, clean up and weed
abatement. In FY 02-03, Parks Maintenance prepared and implemented a
comprehensive “Integrated Pest Management” (IPM) Program.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 iv
All City employees received general storm water training. In addition, divisions and
employees in identified job titles were given job specific training on JURMP
requirements, SWPPPs, or facility BMPs.
In FY 03-04, the City plans to establish a Storm Water Committee with representatives
from Public Works, Public Safety and Community Development. This committee will
help standardize job specific training and documentation, and work on other municipal
storm water compliance issues.
Industrial
The City of Carlsbad currently has over 600 industrial facilities operating within its
jurisdiction. Major industry types in Carlsbad include high technology, multimedia and
biomedical businesses, electronics, golf apparel and equipment manufacturers, and
several light industry parks. Industrial activities can contribute to the degradation of
receiving water quality if performed with disregard for the environment. The City
continued to implement a comprehensive program to reduce polluted urban runoff
originating from existing industrial facilities.
During FY 02-03, the City updated the prioritized industrial inventory, mapped all
industries, inspected 378 industries, including all high priority industries, conducted
education and outreach to industries, and used enforcement actions to obtain
compliance when necessary. The City also worked closely with the Industrial
Compliance Unit of the Regional Board, submitting copies of inspection reports and
correspondence with high priority industries. The City took 15 enforcement actions
against industries to achieve compliance.
During FY 03-04, the City will inspect all high priority facilities and continue to inspect
medium and low priority facilities on a complaint basis and/or resources are available.
The City will also continue to review industrial monitoring data and compare results to
benchmark values and previous year’s results.
Commercial
The City currently has over 680 high priority commercial facilities operating within its
jurisdiction. Commercial facilities can generate a variety of pollutants depending on the
activities performed. Automobile maintenance, pressure washing, masonry and
concrete work, carpet cleaning, and landscaping activities are some of the high priority
operations that have the potential to generate significant amounts of pollutants, if
performed with disregard to the environment. The City continued to implement a
comprehensive program to reduce polluted urban runoff originating from existing
commercial sites and sources.
During FY 02-03, the City prioritized new commercial facilities, updated the commercial
inventory, mapped commercial facilities, provided education and outreach on BMPs,
inspected 351 commercial sites, and conducted enforcement activities as needed to
ensure compliance. The City participated in four commercial workshops and 1 outreach
event for business, and developed 8 new brochures and fact sheets in-house regarding
BMPs for commercial operations. The City took a total of 51 enforcement actions
against commercial businesses during FY 02-03 in order to achieve compliance.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 v
During FY 03-04, all automotive facilities in Car Country Carlsbad will be re-inspected
and other commercial sites will continue to be inspected on a complaint basis or as
resources are available. The City will continue to work with the agricultural operations,
and to educate landscaping companies on BMP implementation.
Residential
The City of Carlsbad encompasses approximately 42 square miles and has an estimated
population of 90,300 residents. At build out, sometime beyond year 2010, there will be
nearly 54,599 residential units, housing approximately 135,000 residents. The
residential community has a significant potential to contribute to water quality
degradation. The City has implemented a proactive information and education program
that utilizes public presentations, fact sheets, direct mailers, brochures, and the media to
increase knowledge and awareness of storm water pollution prevention efforts.
Targeted activities for residential areas include vehicle washing, vehicle storage and
maintenance, lawn and garden care, home improvement projects, pet waste disposal,
swimming pool and spa maintenance, and trash and debris cleanup and disposal. The
Storm Water Protection Program created seven new brochures addressing residential
BMPs.
During FY 02-03, the City distributed storm water educational information for residential
activities, hosted or participated in six residential outreach events, collaborated in
offering four oil recycling drop-off sites including one household hazardous waste (HHW)
collection site for residential use, responded to illegal discharge reports, and issued 84
enforcement actions to achieve compliance.
During FY 03-04, the City will continue to respond to illegal discharge reports and to
educate residents about storm water pollution prevention, with specific emphasis on
lawn and garden care (irrigation practices and chemical application). The City will also
work to create a unified City Environmental Programs message combining storm water,
water conservation, and HHW/recycling information.
Land-use Planning
The Permit requires the City to evaluate land use planning policies and principles, revise
the environmental review processes, and develop an approval process to minimize the
short- and long-term impacts of development activities on receiving water quality. Land-
use planning in the City of Carlsbad gives local leaders and the community an
opportunity to comment on and shape policies that guide community development and
interests. The City has developed goals that balance environmental protection with
smart, long-term economic growth. By laying out a vision for local growth and coastal
development, projects are consistent with the state and federal regulatory requirements
and the City’s land-use planning efforts.
During FY 02-03, the City implemented the Standard Urban Stormwater Mitigation Plan
(SUSMP), and all applicable projects were subject to a thorough discretionary and plan
check review process to ensure compliance. For developments over 1 acre, a SWPPP
is required, in addition to the required Storm Water Management Plan (SWMP). The
City reviewed and required 65 discretionary projects to submit SWMPs and SWPPPs.
The application submittal checklists for new developments were amended to focus on
pollution prevention and control requirements. Prior to the official submittal of a
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 vi
development application, the City offers a process called a Preliminary Review
Application, which helps to educate developers, applicants, engineers, and citizens
about the requirements to integrate pollution control measures into preliminary project
plans. The City also hosted a workshop to educate applicants, developers, and
engineers on the new SUSMP requirements.
The California Coastal Commission approved the Carlsbad Habitat Management Plan in
June of 2003, as Carlsbad’s contribution to the larger Multiple Habitat Conservation
Program.
For FY 03-04, the City will investigate developing a comprehensive database of existing
and proposed permanent storm water BMPs and other pollution control devices to
facilitate Permit compliance and reporting. Additional training will also be made
available for planners.
Construction
The Permit requires the City to implement activities that address and minimize short and
long-term impacts on receiving water quality related to runoff from new construction
sites. The City requires, prior to approval of a construction or grading permit, that
projects implement measures to ensure that pollutants from the site will be reduced to
the maximum extent practicable and will not cause or contribute to an exceedance of
water quality objectives. The City met these requirements by amending or conditioning
existing permits, procedures and ordinances.
The general project review process for obtaining a construction/building permit is as
follows:
Identify project specific BMPs.
Determine adequacy proposed storm water BMPs.
Include BMP requirements in permit conditions, and/or plans and specifications.
Review previously approved discretionary permits during the construction permit
process for post-construction BMPs identified in discretionary approvals, or
equivalent (where applicable).
Review proposed project revisions for additional storm water requirements (where
applicable).
The City modified construction/building permit requirements to be consistent with the
General Construction Permit which requires projects of 1 acre or larger to prepare a
SWPPP.
During FY 02-03, all active grading permits were ranked as high priority and inspected
weekly. Inspectors used enforcement actions as necessary to achieve compliance,
issuing a total of 37 field memos and 3 stop work notices. The City also hosted a
seminar on SUSMP requirements and construction BMPs for developers, engineers,
builders, inspectors and contractors.
During FY 03-04, the City will determine if additional storm water pollution control
requirements for ministerial permits need to be incorporated into checklists, standards
and procedures for building, planning, development and construction.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 vii
Illicit Discharge Detection and Elimination
The City continued to conduct an active program of detecting and eliminating illegal
discharges to the storm drain system. This program actively seeks and eliminates illicit
discharges and connections by conducting investigations, responding to spills and
sewage overflows, conducting monitoring in the storm drain system, and performing
routine cleaning and maintenance activities on the sewer and storm drain systems.
During this reporting period, the City expanded implementation of a new database to
manage illegal discharge complaints and other requests for action. These complaints
are documented and tracked in the SuiteResponse Request For Action (RFA) system.
The RFA system is used each time there is a complaint through the hotline, email, in-
person, or during field discovery related to a potential illegal discharge. The RFA system
can track response times, types of discharges, resolutions, and run reports related to
corrective actions or violations. The Storm Water Protection Program responded to 156
reports of illegal discharges to the storm drain system, and other divisions responded to
an additional 557 cleanups or investigation requests.
The City continued to implement the Dry Weather Field Screening and Analytical
Program, analyzing conditions and samples from 60 sites in the storm drain system.
The City also continued to implement the Coastal Outfall Program, which was expanded
to include the storm drain outfalls to the Lagoon. There were 58 outfall sites routinely
monitored by the storm water program.
During FY 02-03, the City continued to implement the Sewer Overflow Prevention
Plan/Response Plan. The City responded to 17 sewage spills or overflow reports, with 7
of these originating from private sources. A Performance Measurement System has
been implemented by the City to monitor annual sewage overflow spills and responses,
and assess whether preventive maintenance or other improvements can be made to
reduce spills to the environment. In addition, the City implements a “Standards of Care”
program that evaluates the maintenance needs of various pump stations and other
portions of the sewer and storm drain system.
During FY 03-04, the City will implement improved data entry and tracking procedures
using the RFA system. Toward the end of FY 02-03, the Storm Water Protection
Program initiated a goal of responding to “happening right now” complaints within 30
minutes. While this goal was consistently met during the year, it was not being tracked
electronically. Data entry procedures into RFA will be improved during FY 03-04 in order
to better track response times and to more easily track and report the types of illegal
discharges and resolutions.
The City also plans to improve the Coastal Outfall Monitoring program by bringing it in-
house and using a different laboratory with an acceptable turn-around time.
The City will also increase the advertising of the storm water hotline, in order to make
the public more aware and educate them on reporting illegal discharges.
Outreach
The City of Carlsbad works to increase public awareness and stewardship of storm
water pollution prevention using various outreach methods that target specific
audiences. During FY 02-03, the City was actively involved in outreach and education at
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 viii
the local level, the watershed level with the North County Storm Water Program
(NCSWP), and at the regional level with the Project Clean Water Outreach Workgroup.
The City created 11 new storm water educational brochures and fact sheets and
collaborated with the NCSWP to develop two new posters, one brochure, and a door
hanger. The City distributed this information through direct mail, during inspections and
investigations, on the website, at workshops, presentations, training seminars, and other
public outreach events. Articles were also published in the Carlsbad Business Journal
and the Community Service Guide. Storm water program information and water quality
messages appeared on two Community Update Videos, which were broadcast on the
local cable access channel. The City also distributed many promotional items such as
notepads, pens and key chains with pollution prevention messages. These new and
existing printed materials, items and electronic messages were viewed by over 98,000
people.
During FY 03-04, the City plans to create a unified City Environmental Programs
message combining storm water, water conservation and HHW/recycling information.
This message will help foster a better understanding of the relationship between
everyday activities such as lawn and garden care, pool maintenance, car repair,
recycling and the sources of pollution in waterways.
While the City has collaborated well with the NCSWP and the regional outreach group,
additional collaboration with local non-government organizations and stakeholder groups
with similar goals would be beneficial for outreach and education. The City expects to
work more closely in FY 03-04 with groups like the Agua Hedionda Lagoon Foundation,
The Environmental Trust, The Batiquitos Lagoon Foundation, and others in the Carlsbad
Watershed Network.
During FY 03-04, the City will conduct the annual Public Opinion telephone survey and
include questions on storm water pollution prevention. The results from this survey,
along with the results from the Watershed Public Awareness Survey, will provide
important information on the public’s awareness and knowledge of storm water pollution
prevention issues and activities. This information can help focus future education and
outreach messages and events.
Public Participation
The City of Carlsbad led and contributed to several public participation opportunities this
reporting period including the development, implementation, and review of storm water
management programs, BMPs, new requirements, and other JURMP and storm water
related issues. During the reporting period, citizens, business owners and
representatives, and other interested parties were invited to attend public meetings,
outreach events, workshops, City Council meetings, and other events related to storm
water pollution prevention at the local and watershed levels.
The City actively seeks ways to provide two-way communication with the public. This is
shown by some of the current City programs, such as the popular “Citizen’s Academy”
and the annual “State-of-Effectiveness Report” which includes a citywide public opinion
survey of at least 1,000 residents. The City has internal teams dedicated to finding the
most effective ways of communicating with the public and providing opportunities for the
public to become more involved.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 ix
For FY 03-04, the City plans to hire a Community Volunteer Coordinator to guide and
direct the City’s volunteer and community support programs. The storm water program
will work closely with the new volunteer coordinator to create more opportunities for the
public to assist with pollution prevention efforts.
Effectiveness Assessment
Information collected in surveys, public comments, inspections, investigations,
monitoring and other activities during the year were assessed in order to identify any
trends and determine new or modified courses of action. During FY 02-03, the City of
Carlsbad participated in a copermittee effort to prepare a document submitted to the San
Diego Regional Water Quality Control Board (Regional Board) in October of 2003. This
document will be used as a guideline to refine the assessment strategy and develop
additional assessment measures during FY 03-04.
During FY 03-04, the City plans to continue to develop effectiveness measures and to
implement new and existing Performance Measures.
Fiscal Analysis
During FY 02-03, the City funded all storm water program activities from the general
fund, with the exception of the Storm Water Facility Capital Improvement Program. The
increase in program costs over the past several years has put a strain on the General
Fund and, over time, could contribute to reductions in other City services. To prevent
this from occurring, the City formed a storm water financing team in FY 01-02 to study
potential funding mechanisms. At that time, the City commissioned an Alternative
Financing Mechanisms Study, which was prepared by Brown and Caldwell. The
recommendation from the financing study, as amended by the City Leadership Team,
was to pursue four separate funding sources. During FY 02-03, the Storm Water
Financing Team reviewed these potential sources, and prepared a document titled
“Storm Water Pollution Prevention Program Alternative Financing Mechanism Study
Report”.
For FY 03-04, the total annual budget is $1,611,527 (excluding the Storm Water Capital
Improvement Program costs). City staff will present the new fee study report to the City
Council and recommend the adoption of new construction related SWPPP processing
fees and a proposed Solid Waste Service fee increase for residential and commercial
service users to fund certain Storm Water Protection Program activities.
Conclusion
During FY 02-03, the City successfully implemented the Municipal Storm Water Permit
requirements and the program activities described in the JURMP. Identified program
strengths as well as improvement areas for FY 03-04 are outlined in each report section.
As more programs and activities are implemented, there is a clear need for better
databases for tracking and reporting all of these activities and the BMPs being
implemented. Tying all of these activities to changes in water quality still presents a
considerable challenge. This is part of the long-term assessment strategy to develop
trends and to determine cause and effect relationships of pollution prevention and water
quality management. The City will continue to work with the Copermittees to develop
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 x
additional effectiveness measures, in addition to developing measures on program
effectiveness within the City.
Information from JURMP activities as well as the 303(d) List indicate that bacteria,
sediment and nutrients are constituents of concern in Carlsbad. The City proposes to
address these constituents through a number of existing or new activities, which include
education, inspections, monitoring and maintenance.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 xi
Section 1
Introduction
Overview
The City’s Jurisdictional Urban Runoff Management Plan (JURMP) Annual Report
addresses the continued implementation of the Regional Water Quality Control Board
(Regional Board) Order No. 2001-01 (NPDES Permit #CAS0108758), commonly known
as the Municipal Storm Water Permit (Permit). The Permit was issued February 21,
2001, and replaced the City’s first municipal storm water permit issued in 1990 (Order
90-42). The Regional Board issued this Permit to prevent and control polluted urban
runoff from Municipal Separate Storm Sewer Systems (MS4s) to downstream water
bodies. As runoff flows through urban areas, it can carry harmful pollutants such as
pathogens, sediments, fertilizers, pesticides, heavy metals, and petroleum products.
Pollutants entering a receiving water body through the MS4 may harm aquatic life
through toxicity and habitat degradation.
Each of the 20 Copermittees listed in the Permit was required to draft a JURMP outlining
their approach to protecting water quality and preventing harmful impacts from polluted
urban runoff. The Permit requires the submittal of an Annual Report to the Regional
Board to document the progress and implementation of the JURMP. This second Annual
Report details activities conducted during the reporting period of July 1, 2002 through
June 30, 2003, which corresponds to the City’s Fiscal Year 2002-203 (FY 02-03).
The Permit requires each Copermittee to protect water quality during the three major
phases of urban development: (1) Land use planning for new development, (2)
Construction, and (3) the “use” or existing development phase.
The City of Carlsbad is a municipal corporation, following the Council-Manager form of
government. City Departments fall under one of the five major service areas (MSA’s):
Public Safety, Administrative Services, Public Works, Community Development and
Community Services. While the City created a new Storm Water Protection Program in
Public Works to help implement the permit after it was issued in February 2001, program
implementation is carried out by several different departments in different MSA’s. This
allows for program implementation and new requirements to be incorporated into the
everyday activities of the City and its employees, instead of being viewed as completely
new requirements without a connection to on-going services.
The City of Carlsbad encompasses just over 42 square miles and borders 6 miles of
coastline. Carlsbad also contains or borders three coastal lagoons (Buena Vista, Agua
Hedionda and Batiquitos lagoons). The City of Carlsbad is part of the Carlsbad
Hydrologic Unit (watershed), which includes four separate sub-watersheds that run
through Carlsbad. These include each of the three lagoons and their respective
drainage areas, in addition to a fourth watershed commonly known as Encinas Creek.
Portions of Agua Hedionda Lagoon and Buena Vista Lagoon are listed as impaired for
bacterial indicators and sedimentation/siltation on the Federal Clean Water Act Section
303(d) Impaired Water bodies list. While this report focuses on the City’s
implementation of the JURMP and not the Watershed program, the two are becoming
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 1
more intertwined as waterbodies and public education strategies cross programmatic
and jurisdictional boundaries.
1.1 Report Organization
This Annual Report was prepared in accordance with the requirements of the Permit. It
contains: a comprehensive description of the activities conducted by the City of
Carlsbad to meet the requirements of section F of the Permit; an accounting of all illicit
discharges reported, all inspections conducted, all enforcement actions taken, all
education efforts conducted; a description of the public participation mechanisms utilized
during the JURMP implementation process; a summary of all urban runoff related data
not included in the annual monitoring report; identification of management measures
proven to be ineffective in reducing urban runoff pollutants and flow; identification of
water quality improvements or degradation; a discussion of proposed revisions to the
JURMP; and a budget for the upcoming year.
The organization of this report follows the table of contents agreed to and submitted by
the Copermittees to the Regional Board. The Annual Report is divided into sections
matching major sections in the Municipal Permit and the City’s JURMP. As with the
JURMP, many of the activities described in separate JURMP sections overlap with one
another, so an activity may be referenced in more than one report section. The Annual
Report is organized as follows:
Section 1 - Introduction
Section 2 - Municipal Component
Section 3 - Industrial Component
Section 4 - Commercial Component
Section 5 - Residential Component
Section 6 - Land-Use Planning Component
Section 7 - Construction Component
Section 8 - Illicit Discharges Detection and Elimination Component
Section 9 - Education Component
Section 10 - Public Participation Component
Section 11 - Assessment of JURMP Effectiveness Component
Section 12 - Fiscal Analysis Component
Section 13 - Special Investigations
Section 14 - Conclusions and Recommendations
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 2
Section 2
Municipal Component
2.0 Overview
The City of Carlsbad Municipal Facilities are composed of administration buildings,
recreational areas, buildings, maintenance yards, water reservoirs, water pump stations,
sewer lift stations, a road system, parking facilities, the storm drain system, pressure
regulator vaults, and fire stations. These are areas where Municipal staff work or
provide a public service.
The City has developed a municipal infrastructure to maintain the quality of life enjoyed
by residents, visitors, and employees of Carlsbad. The activities supported by the City’s
infrastructure could contribute to urban runoff if the proper BMPs were not developed,
implemented, and maintained.
The City has implemented a program to prevent or reduce pollutants in urban runoff from
all municipal sources or activities. In addition, the Permit requires that high priority
municipal facilities and activities be identified and inspected, that minimum BMPs be
established for each priority, and that a process for ensuring the application of these
BMPs be implemented and enforced by the City.
2.1 Source Identification and Threat to Water Quality Prioritization
The municipal facility inventory is reviewed and updated each year, as new City facilities
are developed and brought on-line. The updated inventory is found in Appendix 2-1.
Each year, the list is reviewed and the facilities and new facilities are added as
appropriate. All municipal facilities are also mapped (see appendix 2-2).
Prioritization of municipal facilities was determined by proximity to an ESA, type of
activities conducted onsite, compliance inspections, wastes generated, and pollutant
discharge potential (see criteria in section 2 of the JURMP). As potential pollutant
sources are removed and discharge potential decreases, the municipal facilities priority
ranking may change. However, if a facility is designated as high priority under the
Permit (e.g., corporate yards) it will not be reprioritized on the inventory list.
Municipal facility locations shown on the map were created by first geocoding each
location's address against the City of Carlsbad parcel base map, and then the remaining
unmatched sites were geocoded to the City's street centerline layer. Locations matched
to the parcel base were mapped to the parcel centroid, locations matched to the street
center lines were mapped to the estimated location within the address range of the
street center line segment, and all were mapped to include proximity to the ESA.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 3
2.2 Pollution Prevention Practices and Best Management Practices
Implementation
The City of Carlsbad’s approach is to promote pollution prevention as much as possible
for all employees and at all municipal sites. Since 1991, the City has implemented a
procurement policy that directs the purchase and use of recycled products. Purchasing
staff is encouraged to use “Green Purchasing” principles. This refers to buying products
and services with reduced effects on human health and the environment (also called
“Environmental Purchasing”). While some of these products are office and janitorial
supplies, the policy also applies to construction supplies, landscape materials and
equipment, automotive, road and highway supplies.
Specific pollution prevention measures may vary from one site to another, so they are
evaluated separately at each facility. All corporate yards have been implementing
individual Storm Water Pollution Prevention Plans. In addition, the City implemented the
following pollution prevention practices (detailed in SWPPPs or inspection reports) at
City facilities where appropriate:
• Reduce use of water or use dry cleanup methods. Employees use dry cleanup
methods when possible (sweeping, etc.). Any washing activities require
containment and recovery, with no discharge to the storm drain system. These
activities are also required of contractors working for the City.
• Redirect storm water flows and conduct storm drain maintenance. Employees
perform regular visual inspections of the storm drains to identify unauthorized
discharges or pollutants and clean as needed.
• Recycle. City departments look for items to be recycled and implement the City
procurement policy for the purchase and use of recycled products.
• Move or cover potential pollution sources from storm water contact. Corporate
yards protect materials and products that could potentially pollute storm water
from rain, run-on, runoff, and wind dispersal by storing them indoors, or covering
them, and providing them with secondary containment as needed.
Municipal facilities are required to implement the minimum BMPs identified and
described in the JURMP (good housekeeping, preventive maintenance, material
handling and storage, employee training, solid waste handling, record keeping, self
inspection, and spill response) as applicable to their operation. Specific Best
Management Practices are identified in SWPPPs or inspection reports. The City then
implements and assesses the effectiveness of BMPs through on-going staff training,
self-inspections, 3rd party inspections, and SWPPP implementation. Following are some
of the specific pollution prevention and storm water BMPs implemented by various City
divisions and at specific facilities.
Maintenance and Operations, Construction Maintenance Division
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 4
Those involved with Maintenance and Operations (M & O) activities received training on
waste minimization techniques for hazardous waste and solid waste, spill prevention,
response and cleanup practices. Following are some of the BMPs implemented for FY
02-03.
• Using native soils whenever possible when backfilling trenches.
• Minimizing the amount of dirt and soil stockpiled.
• Gravel bags were placed along the downstream flow path to minimize the silt and
facilitate an effective cleanup.
• “Gutter Buddies” were installed at storm drain inlets. Silt builds up behind them
and crews are able to remove silt easily.
• Approximately 720 tons of Recycled - Class II - Base Material was used to
backfill trenches.
• Approximately 668 tons of Asphalt/Cement wastes were hauled to Hanson
Aggregate to be recycled and made into Class II base.
• A rock shaker driveway was used to prevent dirt or mud tracking onto the parking
areas.
• Oil and fuel was located in a designated storage area with 290-gallon catch
containment area.
In addition, a SWPPP was developed and implemented to outline BMPS and actions
taken to prevent runoff from the M & O yard. A site map details all equipment and
materials storage within the facility and provides the amounts of material that will be
stored at the site for construction purposes.
Fleet Maintenance
Fleet Maintenance Division provides routine preventive maintenance and repairs to
nearly 300 City vehicles and 150 other pieces of equipment. Fleet Maintenance also
performs smog inspections, responds to road calls for units disabled in the field, and
supplies the necessary fuel and lubrication service for City vehicles, as well as to the
Carlsbad Unified School District, San Dieguito Union High School District and the Encina
Wastewater Authority. BMP implementation efforts for FY 02-03 included:
• A designated pressure washer area is used to hand wash vehicles and pressure
wash engine and undercarriages. The pressure washer drain discharges to a
separator then to sanitary sewer.
• A floor scrubber and mop are used to clean the repair shop floor. Wash water is
disposed of inside the shop to the sewer.
• Oil, fuel, antifreeze, or other liquids spills are cleaned with absorbent and put into
marked drums, which are then removed by our waste hauler.
• Used batteries are stored in plastic container and picked up weekly.
• Brake shoe cores are stored in a plastic container until returned to the vendor.
• The public waste oil disposal site has been closed and the tanks moved and
covered pending removal from the yard.
• Drip pans are used to catch any leaks from vehicles stored outdoors. Spills are
cleaned up using absorbent, which is then stored in marked containers and
removed by the waste hauler. There are no maintenance or repairs services
conducted outside of the shop.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 5
• Recycled antifreeze is used and waste is stored in poly drums inside the shop.
Fleet recycles 300 gallons of antifreeze annually.
• All scrap metal is recycled at a local scrap metal supply.
• Training was conducted on BMPs, inspection intervals, and basic house keeping.
• Fleet Maintenance Shop BMPs were amended to include inspection of the
outside area including the waste oil drop off, dumpsters, and the hazardous
waste bunker.
• A site map has been developed for the Fleet Maintenance area.
Streets Department
The Street Department is responsible for the maintenance and repair of over 582 lane
miles of roadway, 5,597 streetlights, 100 signalized intersections, 5,641 storm drains,
and all sidewalks in the public-right-of-way. In addition, Streets Department manages
the street sweeping contract for all public streets. Staff implemented previously
identified pollution prevention BMPs and all streets staff received storm water training.
Pollution prevention efforts for FY 02-03 included:
• Oak Maintenance Yard: The maintenance yard is inspected quarterly by Public
Works Supervisor. As a result of these inspection the following new pollution
prevention efforts were implemented.
Storm drain filters were installed in the drains that lead most directly to
the waterways.
Frequency of yard sweeping was increased from once per month to twice
per month.
Brow ditches along the south side of the property were cleaned.
An asphalt berm was installed around the concrete lumber storage area
to prevent and control erosion.
Empty drums and unused equipment was removed from the site.
A roof was constructed over the stencil storage rack and area was
regularly swept.
Storm drain at west end of Oak was evaluated for installation of a
sediment filter.
Storage bins have been eliminated and the area has been converted to
parking spaces. Staff is now utilizing the existing material stockpiles at
the water district maintenance yard.
• Paint and Striping: Wastewater is captured, contained, and disposed of by a
certified removal contractor. This year, the streets department disposed of 880
gallons of paint related waste.
• Vehicle / equipment cleaning on-site: The wash rack at the Oak Street
Maintenance Yard facility has been eliminated. The water source has been
turned off and staff has been instructed to use the existing wash facility at the
Safety Center.
• Litter Pick-Up: In FY 02-03, the litter removal program was expanded from a
seasonal program to a full-time, year-round program, consisting of a two-person
crew. They removed 310.5 cubic yards of litter in 2,301 staff hours during FY02-
03.
• Recycled Material: The following amounts and types of material were recycled
during this reporting period:
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 6
• 200 tons of Class 2 Base Material used for patch/repair on streets and rights
of way.
• 1,050,tons of asphalt used for patch/repair on streets and rights of way.
• 100 tons of cement used for patch/repair on sidewalks.
• 100 sign blanks; used to install/replace street signs.
• Spill Response: Environmentally safe absorbent materials are used to capture
the waste and then the contaminated materials are disposed of in accordance
with the manufacture’s instructions.
• Training: Employees have been instructed to keep areas as clean as possible.
This includes maintaining the cleanliness of the vehicles, keeping high-priority
vehicles covered, cleaning up any spills, and keeping the dumpster lids closed at
all times.
• Disposal of Wastes: Waste and debris is collected in dumpsters at the Safety
Center Yard and transferred to the Coast Waste collection facility as required.
Any hazardous materials collected are disposed of in accordance with the
guidelines for disposal of such materials.
Fire Department
The Carlsbad Fire Department is a dedicated team of professionals whose "mission" is
to enhance the quality of life in our community by delivering exceptional services in
safeguarding lives, property and the environment. Following are BMPs the Fire
Department is currently implementing for runoff protection and pollution prevention:
Monthly foam system checks were discontinued. If checks are required, they are
conducted in the wash rack at the City yard.
•
•
•
•
•
•
•
A more environmentally friendly foam emulsifier has replaced foam agents.
Sump/reclamation technology has being incorporated into the design of new fire
stations.
There is a heightened awareness at fire scenes to minimize excessive water flow when
possible.
Fire drills and training are conducted at a facility in San Marcos where water is reclaimed
and re-circulated. The annual cost to rent this facility is $15,000.
A training program that simulates a pumping apparatus has been installed on station
computers.
The oil in the priming pumps is gradually being switched to a vegetable oil base.
Facilities Maintenance Division
The Facilities Maintenance Division is responsible for maintaining 600,000 square feet of
building space at 52 different locations to ensure the buildings are safe and comfortable
for the City and the community to conduct business. The division annually receives
approximately 1,500 work order request to perform a variety of repairs and alterations
such as HVAC, plumbing, electrical, painting, roofing, etc. The division also provides
professional level of custodial services for all City facilities by utilizing City staff in the
major buildings and contract services in the smaller buildings. FY 02-03 BMP
implementation activities included:
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 7
• All facilities have bi-annual roof inspection that include the cleaning and removal
of debris, sediment and foliage from all scupper outlets and roof drains. Staff
installed diffuser rock in roof drains.
• Staff continually practices proper housekeeping practices.
All mop water or cleaning by-product is disposed of in the custodial deep
sinks at all facilities. The Custodial staff has been trained not to dispose
of mop water into the parking lot, street, gutter or drain inlet.
Backup power generators are inspected monthly for leaks or other
discharge. If a leak or discharge is identified, drip pans or absorbent
material is used to capture fluids and the contaminated materials are
disposed of in accordance with manufacture’s instructions.
All stocked paint related materials are stored on pallets and under cover.
Facilities staff have been instructed to check and close the dumpster lids
on a daily basis.
• All the parking facilities are inspected and processed for maintenance and
repairs through the Pavement Management program. Parking areas were swept
bi-monthly in conjunction with the Streets Division street-sweeping contract.
• Anti-Litter signs were purchased and installed in February 2003.
• A small equipment washout area was established at M&O facility yard.
Parks Department
The Park Maintenance Division is responsible for maintaining, preserving and enhancing
over 300 acres of park facilities, school athletic fields, beach accesses, and landscapes
at various civic facilities. This includes the maintenance of eight community parks and
26 special use areas. In addition, the Park Maintenance Division manages over 625
acres of open space/undeveloped areas that includes trash removal, clean up and weed
abatement. Crew leaders are training staff in stormwater protection as it relates to parks
on a bi-weekly basis during safety meetings. During this reporting period, staff
addressed the improvements recommended by the Regional Board, Storm Water
Protection Program, D-Max Engineering, and in-house quarterly inspections at the
following locations and activities:
• Parks Yard: Staff installed canopies to cover equipment, fertilizers, soil
amendments, and bark. Plant material was relocated onto pervious soil. Bi-
weekly BMP training meetings were held and the parking area and yard were
swept or raked on a weekly basis.
• Poinsettia Park Maintenance Facility: A drain filter was installed to trap
sediment, debris, and pollutants. Storm drain inlets were identified and labeled.
Staff installed tubs under storage cabinets for pesticides, gas, and oil, along with
canopies to cover fertilizers, soil amendments, and equipment. A weekly yard
clean up was implemented. More frequent cleaning was conducted when
needed.
• Stagecoach Park Maintenance Facility: Canopies were installed to cover
fertilizers, soil amendments, and equipment. Drain inlets were identified and
labeled, and a grease dispenser was relocated undercover. A weekly yard clean
up was implemented and more frequent cleaning was conducted when needed.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 8
• Recycled Material: Chips generated from tree trimming were used for erosion
control and weed control on banks, slopes, and bare ground. Both Stagecoach
and Poinsettia crews incorporated recycled chips into landscaped areas. Parks
Crew installed straw tubes at the base of the banks at: Buena Vista School,
Magnolia School, Carlsbad High School Tennis Courts, Safety Center (dirt
parking lot), Poinsettia Park (maintenance yard), and La Costa Canyon.
• Park Maintenance: Crews increased mowing frequency to reduce the size of
grass clippings. This minimized migration of clumps of grass into the storm
drains.
• Pest Management: Pest control spraying operations were observed by County
Agricultural Department inspectors to insure compliance with San Diego County
Department of Parks and Recreation (DPR) regulations. Biweekly training
related to pest control operations was conducted. Parks crews store chemicals
in enclosures at Poinsettia Park. New diesel fuel and pesticide lockers were
purchased, along with tarps for covering equipment, dumpsters, and soil
amendments.
• Irrigation: Sprinkler systems are inspected weekly for breaks or malfunctions.
Irrigation repairs are addressed within a 24 hour period when observed or
notified.
• Spill Response: “Spill kits” were purchased for the Parks Yard, Poinsettia
Maintenance Yard, and Stagecoach Maintenance yard.
• Training: Parks staff prepared a training booklet that includes fact sheets,
BMPs, pollutant sources, and current and potential BMP practices needed to
reduce or minimize potential pollutant discharge.
2.3 Maintenance of Municipal Separate Storm Sewer System (MS4)
The City implements BMPs for maintenance activities, with an emphasis on preventing
or reducing the quantity of pollutants entering the stormwater conveyance system. The
Streets Department performs routine maintenance of all the storm drain inlets, culverts,
and open channels that comprise the City’s stormwater conveyance system. In addition
to cleaning and clearing, the Streets Department generally performs minor repairs and
limited construction activities, such as the replacement of concrete structures, the
placement of pipe and wire for slope protection, and the placement or replacement of
rip-rap. The Streets Department and M & O Division also collect and properly dispose of
all maintenance waste. Staff is trained to promptly report illegal discharges/dumping and
accidental spills to the Storm Water Protection Program and M&O Division.
In addition to the numerous small-scale structural BMPs at municipal facilities, the City
has implemented a wide range of other BMPs throughout the City. Regular inspection
and maintenance of the MS4 are requisite to the effectiveness of the structural best
management practices employed throughout the City. The Streets Department or their
contractors visually inspect all structural BMPs and the storm water conveyance system
at least once every 12 months (pipelines excluded). Based upon inspection, the
structural BMPs and the stormwater conveyance system are cleaned to remove trash,
debris, sediment, and other pollutants. All waste materials collected are properly
disposed of pursuant to applicable laws and regulations.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 9
Storm drain channels were inspected two times per year and cleaning was schedule
whenever necessary. Currently, there are 14,800 lineal feet of drainage channels. Staff
devoted 648 staff hours to this task and cleaned 26,480 lineal feet. This is equal to
177.60 cubic yards and 20.72 tons of debris removed.
The maintenance of the City’s storm drain system involved multiple activities.
Storm Patrol
During a storm, street crews are dispatched throughout the City to handle storm related
emergencies in a timely manner. Each crew was assigned to a pre-determined zone
within the City to respond to emergencies and to check inlets and outfalls for blockages.
During FY 02-03, staff spent 1,363.5 staff hours performing this activity. This equates to
3,238 miles of streets maintained during storm events.
Storm Clean-Up
After a storm event, Street crews primarily handle emergencies and strive to maintain
proper water flow, protect the natural waterways from contamination, and ensure public
safety. Major debris removal and storm clean up was performed after emergencies were
resolved. In FY 02-03, staff spent 425 staff hours cleaning up 996 locations.
Litter Pick-Up
During this reporting period, the litter removal program was expanded from a seasonal
program to a full-time, year-round program involving a two-person crew. They removed
310.5 cubic yards of litter in 2,301 staff hours during FY 02-03.
Brow Ditch Cleaning
There are 89,760 lineal feet of public brow ditches in Carlsbad currently. In FY 02-03,
staff spent 97.5 staff hours cleaning 2,327 lineal feet of brow ditch. Approximately,
1,077.12 cubic yards or 89.76 tons of debris was removed.
Catch Basin Cleaning
There are currently 3,068 catch basins in the City and 2,500 of these inlets are stenciled
with storm water protection messages. Each of these catch basins is inspected at least
once per year prior to the rainy season. Cleaning is scheduled as required. In FY 02-
03, 3,078.3 staff hours were devoted to cleaning 2,430 basins. Five tons of debris was
removed.
Inlet Filter Cleaning or Replacement: An exact number of inlet filters installed is not
available at this time. Staff is exploring several different filtering options in an effort to
determine the best application. A cleaning / replacement program will be developed in
accordance with the manufacturers recommendations once the exact filtering method is
determined.
Street Sweeping
Street sweeping is performed under a contract agreement with Cannon Pacific Services.
All residential and commercial streets are swept twice a month with the following
exceptions:
• Entire downtown Village area is swept three times per week on Mondays,
Wednesdays, and Fridays.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 10
• Alleys are swept two times per month.
• Open striped and raised curb medians are swept one time per month
unless otherwise identified as once per week.
• Bike lanes on Carlsbad Boulevard, from north city limit to south city limit,
are swept northbound and southbound one time per week (on Fridays)
with a broom-type sweeper.
• The following road segments to be swept once per week:
El Camino Real from Haymar Drive to the southern city limit o
o
o
o
o
o
Palomar Airport Road from Carlsbad Boulevard to the eastern city
limit
La Costa Avenue from Interstate 5 to Rancho Santa Fe Road
Paseo del Norte from Cannon Road to Palomar Airport Road
Tamarack Avenue from Carlsbad Boulevard to Carlsbad Village
Drive
Marron Road from Highway 78 to El Camino Real
During this reporting period, 1,496.5 miles of roadway and 20,698,764 square feet of
public parking areas were swept at the specified frequencies. From this, 2230 tons of
sediment and debris was removed and transferred to an approved disposal site.
TV Inspection
Carlsbad contracted with Affordable Pipeline for television inspections of all CMP storm
drain pipes. This was completed for 25,009 lineal feet.
Training
All Streets staff received annual training on several topics. Training topics included
Hazardous Materials Handling, JHAs, Spill Containment, and Storage of Flammable
Materials.
2.4 Management of Pesticides, Herbicides, and Fertilizers Actions
The Permit highlights pesticides, herbicides, and fertilizers as stormwater contaminants
of concern in regards to municipal areas and activities. Several municipal areas require
the application of these materials to landscaped areas, right-of-ways, parks, and
recreational facilities. The City’s pest management strategy is based on:
1) Continuous staff training;
2) Selected use of native plant species;
3) Non-chemical pest management solutions;
4) Proper irrigation scheduling;
5) Appropriately scheduled fertilizer applications;
6) Minimal use of chemical pesticides and herbicides; and
7) Proper storage and disposal of pesticides, herbicides, and fertilizer.
Maintenance and Operations
M & O has developed a pesticide program and general pesticide training is conducted
on an annual basis. Although M & O staff only uses Roundup Pro, employees are
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 11
trained on pesticide application, the requirements of the pesticide program, MSDS,
pesticide labeling, pesticide safety information leaflets – N Series, and emergency
medical care. This pesticide program complies with the County of San Diego
Department of Agriculture, Weights & Measures requirements. Roundup Pro is used for
minor weed control six to eight times per year. Other mechanical control methods (i.e.
shovels, hoes) are used whenever possible.
Parks Department
In FY 02-03, Parks Maintenance prepared and implemented a comprehensive
“Integrated Pest Management” (IPM) Program that provides for the following:
• A process by which the City can effectively evaluate the approach to using
fertilizers and pesticides as needed and begin to move toward reducing
dependence on the use of such material.
• A program framework that results in reducing the adverse impacts that the use of
fertilizers and pesticides may have on water quality; and
• General guidelines to be used in conjunction with the BMPs in order to minimize
the potential threat to human health and environmental resources.
A copy the IPM document titled, “City of Carlsbad, PW/Parks Division, IPM Guidelines”
is in appendix 2-3.
2.5 Inspection of Municipal Areas and Activities
D-Max Engineering was contracted to conduct storm water compliance inspections for
many of the municipal facilities during FY 02-03. This included all high priority facilities,
16 medium, and 63 low priority industries. The Storm Water Protection Program
inspectors also inspected some municipal facilities. The list of sites inspected is in
appendix 2-4.
During each inspection, the inspectors review the municipal facility’s SWPPPs, BMP
implementation plans, and facility self-inspection records, when available. In addition,
recommended BMPs or corrective actions were discussed. A comprehensive site
evaluation was conducted and the facility operator was verbally notified of any
deficiencies or violations.
After the inspection, an inspection report that included corrective actions, recommended
BMPs, photographs, a compliance schedule, and other relevant information was
provided to the facility manager. Copies of the inspection reports are on file at the
facility and with the City Storm Water Protection Program. The facility manager then
addressed any recommendations or requirements.
The City’s corporate yards also conduct regular self-inspections. A copy of the self-
inspection checklist is in appendix 2-5. Following is a description of self-inspection
activities and additional BMPs implemented in response to inspections by D-Max.
Maintenance and Operations
M&O conducts quarterly inspections of all facilities. The D-Max inspection report
recommended that the yard lot be swept more often. A contractor currently sweeps the
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 12
lots monthly and staff is instructed to follow up the monthly sweeping with spot cleaning
of any heavy material build-ups.
Fleet Maintenance
The Public Works Supervisor and/or assigned staff inspect outdoor areas, parking lots
and outdoor storage areas at the Fleet Maintenance Yard weekly. This is a visual
inspection based on previously identified criteria and/or areas of concern. Employees
conduct daily compliance surveillance/inspections of their areas in accordance with
training received.
Streets Maintenance Division
The Oak Avenue Maintenance Yard is inspected quarterly by Public Works Supervisor.
This is a visual inspection based on previously identified criteria.
Parks Maintenance
Staff conducts quarterly self-inspections of the Parks Yard and maintenance facilities
(Poinsettia and Stagecoach).
2.6 Enforcement of Municipal Areas and Activities Actions
Runoff from municipal facilities may pose a threat to water quality if a BMP is not in
place or if a BMP fails. BMP implementation and assessment occurs through facility
self-inspections, 3rd party inspections, and through on-going employee training. The
typical progressive enforcement steps the City can apply for compliance of municipal
facilities are as follows:
(a) Verbal or Written warnings;
(b) Notice of Violation;
(c) Compliance Schedules;
(d) Cease and Desist Orders or Stop Work Orders.
All inspection report recommendations for the municipal facilities were implemented to
the maximum extent practicable. There were no enforcement actions taken at any
municipal site during FY 02-03.
2.7 Self-Assessment
Program Strengths
D-Max Engineering Inc. was contracted to conduct municipal inspections. This provided
another set of eyes to view the municipal facilities and recommend any needed
corrective actions. It is anticipated that the City will continue to contract out municipal
inspections, and that these will be unannounced.
Facilities Division is coordinating with the Street Division for the installation of the drain
inlet stenciling, using the Thermoplastic markers currently being used citywide on all
drain inlets. This insures continuity through the system.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 13
Program Improvement Areas
In FY 03-04, Fleet will begin using recycled refined engine oil. The waste oil is recycled
or re-refined and used in other industries.
A muddy soil/material dewatering site is to be constructed at the Calavera Treatment
Plant location. This site will enable M&O field staff to dump muddy “spoils” and it will de-
water without affecting the storm water system in that area. Once the material is dry, it
will be hauled to appropriate locations for disposal.
Drain inlet plugs, walk behind vacuums for out door use along curbs, gutters and
hardscape, and a sediment trap are going to be ordered for Poinsettia Park.
In FY 03-04, the City plans to establish a Storm Water Committee with representatives
from Public Works, Public Safety and Community Development. This committee will
help standardize job specific training and documentation, and work on other municipal
storm water compliance issues.
At the end of the fiscal year, the City implemented a computerized asset
management/work order system that will allow the storm drain maintenance division to
keep track of the MS4 inventory as well as the inspections and cleanings conducted
throughout the system. The storm drain maintenance division will also be able to use
the system to set up preventive maintenance schedules for any facilities that need to be
inspected annually or those shown to be problem areas requiring more frequent
cleaning. This system will allow better management of the inspection and cleaning
schedule and also improved tracking of the amounts and types of debris being removed
from the drainage system.
Ineffective Management Practices and Improvements
The Silt bags proved not to be effective for removing silt from muddy excavation water.
The bags “silted up” quickly and staff had to remove them and let the mud be collected
another way. The gravel bags and “Gutter Buddies” proved to work the best.
M & O crews tried placing tarps over the sand, dirt, and other material piles at the
Maintenance & Operations Yard. However, this method was not very effective. It was a
constant battle for staff to keep the tarps in good repair. Light to moderate winds would
blow them off the piles. Sun damage takes a toll; the tarps need to be replaced about
once every two months. The sand and spoil piles already have redundant BMPs down
gradient, which includes straw rolls, silt fences and gravel bags. Covering sand or dirt
piles that already have other BMPs to prevent discharge of sediment is not practical or
effective.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 14
Section 3
Industrial Component
3.0 Overview
The City of Carlsbad currently has over 600 industrial facilities operating within its
jurisdiction. Major industry types in Carlsbad include high technology, multimedia and
biomedical businesses, electronics, golf apparel and equipment manufacturers, and
several light industry parks. Industrial activities can contribute to the degradation of
receiving water quality if performed with disregard for the environment. The Permit
requires the City to develop and implement a program to reduce pollutant runoff from
industrial sites within its jurisdiction. In order to comply with these requirements, a
comprehensive program to reduce polluted urban runoff originating from existing
industrial facilities has been implemented.
During FY 02-03, the City updated the prioritized industrial inventory, mapped all
industries, inspected all high priority industries, conducted education and outreach to
industries, and used enforcement actions to obtain compliance when necessary. These
activities are described in the following subsections.
3.1 Source Identification and Threat to Water Quality Prioritization
New businesses are issued business licenses on a continual basis and are documented
in the City of Carlsbad’s business license database. Every month, personnel from the
Storm Water Protection Program queried the database to export the most recent
business license applications. On a quarterly basis, new businesses were sorted by SIC
(Standard Industrial Classification) code, and those businesses with applicable SIC
codes were prioritized and sent to the City’s GIS department for mapping. Once
mapped for proximity to an Environmentally Sensitive Area (ESA), their priority was
reassessed to determine if changes were necessary, and they were added to the current
year’s inventory list. New businesses were also found by referral from other agencies,
field discovery, business directories, or while responding to complaints from the public.
The updated FY 02-03 inventory is in appendix 3-1.
Industries were prioritized by SIC code, proximity to an ESA, compliance inspections,
and field discovery. Appendix 3-2 contains Storm Water Protection Program procedure
SW-110, which explains the prioritization process. After telephone inquiries and onsite
inspections, any changes to a businesses priority or status were recorded on the Storm
Water Inventory List.
Data related to industrial businesses within the City of Carlsbad is managed on a
continual basis as per departmental procedures and JURMP requirements. Paper
copies of documents related to industrial businesses were filed according to priority and
status (active, inactive, excluded) for the current fiscal year. Appendix 3-3 contains
Storm Water Protection Program procedure SW-120, which describes the procedures
related to data management of the Inventory List.
Appendix 3-4 contains the map of all prioritized industries in the current inventory. The
high priority industrial locations shown on the map were created by first geocoding each
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 15
location's address against the City of Carlsbad parcel base map, and then the remaining
unmatched sites were geocoded to the City's street centerline layer. Locations matched
to the parcel base were mapped to the parcel centroid, locations matched to the street
center lines were mapped to the estimated location within the address range of the
street center line segment, and all were mapped to include proximity to an ESA.
The updated inventory lists 44 high, 200 medium and 366 low priority industries. This
compares to 188 high, 318 medium and 496 low priority industries identified in the initial
inventory. As anticipated, the number of industries has decreased from the first
inventory submitted with the JURMP. That first inventory was compiled by a contractor
using several databases, including the City’s business license database, the County of
San Diego hazardous materials and waste listings, California State Water Resources
Control Board list of permittees covered under the Industrial Storm Water General
Permit Order 97-03-DWQ (State General Industrial Permit), and the Encina Wastewater
Authority list of industrial facilities with wastewater discharge permits. That initial
inventory compiled the information from these sources, but did not confirm the
information for each business. The Storm Water Protection Program began conducting
industrial inspections using this inventory, and immediately found many businesses that
were out of business, had moved, or had an incorrect SIC code designation that either
changed their priority, moved them to the commercial inventory, or excluded them from
either inventory. The City reviewed 864 industries in the inventory. Of these, 223 were
found to be out of business, 9 had moved out of the City, 5 were duplicate entries, 248
were excluded, and 377 were inspected. Appendix 3-5 contains the listing of industries
that were inspected or reviewed during FY 02-03.
Updating this inventory was a major undertaking during FY 02-03. With the current
procedures in place (see SW-110, SW-120), staff can now maintain a much more
accurate inventory. However, because there were over 1,000 industries in the initial
inventory, all medium and low priority industries were not inspected or reviewed in FY
02-03. Any new businesses with an initial high priority designation are inspected during
the fiscal year. The medium and low priority industries in the inventory continue to be
reviewed in response to complaints or as time and resources become available.
3.2 Pollution Prevention
Pollution prevention measures are specific to individual industrial facilities. Industries
were informed of specific pollution prevention opportunities during site inspections, in
outreach materials, and through correspondences. City inspectors regularly
recommended and/or required the following pollution prevention practices (detailed in
individual facility inspection reports):
• Move or cover potential pollution sources from storm water contact. Protect
materials and products that could potentially pollute storm water from rain, run-
on, runoff, and wind dispersal by storing them indoors or covering them, and
providing them with secondary containment as needed. For industries with
conditional SIC codes, moving stored materials indoors may allow an exemption
from the State General Industrial Permit requirements.
• Reduce use of water or use dry cleanup methods. Businesses conducting
washing or cleaning activity that involves the use of a water hose or pressure
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 16
washing system were encouraged to try it dry (use mops, brooms, rags or wire
brushes to clean pavement, buildings and equipment as much as possible). The
City produced a brochure for power washing activities recommending dry
methods and other BMPs. Industries were also encouraged to adjust irrigation
systems to prevent excessive irrigation runoff.
• Redirect storm water flows and conduct storm drain maintenance. Perform
regular visual inspections of the storm drain to identify unauthorized discharges
or pollutants and clean as needed. An industry may have been required to
modify downspout locations in order to redirect storm water flows away from
potential pollutant sources.
• Recycle. When inspecting solid waste collection areas, inspectors noted if
recyclable materials (cardboard, green waste, etc.) were placed in dumpsters
and recommended recycling.
All high priority industries were inspected during FY 02-03, and all were required to
implement Storm Water Pollution Prevention Plans (SWPPP). If the City required a
medium or low priority facility to implement a SWPPP after an inspection, the business
was usually given 60-90 days to develop the document and submit it to the Storm Water
Protection Program for review. During subsequent re-inspections, the business was
expected to have implemented the SWPPP and have procedures in place to ensure the
document is revised as business practices change. During FY 02-03, the City required 4
medium priority and 6 low priority industries to develop SWPPPs.
3.3 Best Management Practices (BMP) Implementation
The City required industries to implement the minimum BMPs identified and described in
the JURMP (good housekeeping, preventive maintenance, material handling and
storage, employee training, solid waste handling, record keeping, self inspection, and
spill response) as applicable to their operation. BMP information was made available to
industries during inspections, in printed materials and direct mailings, and also through
our website and hotline, presentations, and outreach events.
Printed Material and Direct Mailings
During FY 02-03, the City created a brochure containing the list and description of the
minimum BMPs. This brochure was distributed to all industrial facilities during
inspections and by direct mail to industries that the City verified in the inventory. Over
400 of these brochures were distributed to industries during FY 02-03.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 17
This brochure is found in appendix 3-6 and is also available on the City’s storm water
web page (www.ci.carlsbad.ca.us/cserv/storm.html).
Inspections and Site Visits
Businesses have the flexibility to choose and implement the source and treatment
control BMPs that are found to be the most effective. In order for the BMPs to be
effective, they must address the pollutants of concern and be specific to the activity that
could result in a discharge. The City may require BMPs based on problems identified
during site inspections. Inspection reports detailed corrective actions and recommended
BMPs. If corrective actions were required, follow-up inspections were conducted to
verify compliance. The City conducted 377 industrial inspections during FY 02-03, which
included 104 high priority, 144 medium priority, and 129 low priority inspections.
Website and hotline
The Storm Water Hotline is listed on all printed material. Industries can call the hotline
to request BMP information. City brochures were also available through the City
website. During FY 02-03, there were 2,906 visits to the storm water web page.
Community Groups
An article highlighting the City’s Storm Water Program was published in the August 2002
edition of the Carlsbad Business Journal (see appendix 3-7), which has a circulation of
approximately 3,000 readers.
A presentation was made to the Carlsbad Chamber of Commerce Business Environment
Committee on November 7, 2002. This PowerPoint presentation explained the City’s
storm water program, including inspections of industries and required BMPs.
Telephone Surveys
Telephone surveys were used to determine status of home-based businesses on the
industrial inventory. Approximately 200 home-based industries were surveyed by
phone. In most cases, this screening procedure determined that the wrong SIC code
had been applied during the business license application process. Home-based
businesses are not typically true manufacturing facilities. In addition, City code prohibits
any home-based business from conducting any activities outdoors or storing materials
outdoors. If a business was excluded from additional inspections or regulation, the City
mailed the owner general storm water information and removed the business from the
active inventory list.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 18
Customer Service Survey
Inspected businesses were invited to complete a short written survey to measure
knowledge of BMPs and storm water pollution prevention post inspection and to assess
their satisfaction with the City’s storm water compliance inspection process. The results
of this survey are found in appendix 10-1.
3.4 Industrial Monitoring Program
The Regional Board requires permitted industries to conduct monitoring as outlined in
the State General Industrial Permit. The Carlsbad Municipal Code (CMC) also allows
the City to require other facilities to conduct monitoring. FY 02-03 was the first year that
the City conducted routine industrial inspections of high priority industries. Permitted
facilities are required by the State to maintain self-audit reports, SWPPPs, monitoring
reports, and annual reports on site. These plans and reports are available for review by
the City, as well as county, state, and federal personnel. City inspectors reviewed
monitoring results during inspections to verify that monitoring was conducted as
required, and to compare results to benchmark values. The inspection reports were
used to document if monitoring was conducted as required. Since this was the first year
that the City conducted inspections of high priority industries, inspectors reviewed the
most recent monitoring results. All current high priority industries conducted the annual
monitoring as required. The City will continue to annually inspect the high priority
industries and compare monitoring results to benchmark levels as well as to results from
the previous year. At that time, inspectors will note if benchmark values are routinely
exceeded and will follow up as needed with written notification and required corrective
actions or additional BMPs to prevent or reduce the identified pollutant at its source.
3.5 Inspection of Industrial Sites
The City of Carlsbad conducted inspections of industrial facilities in accordance with the
program established in the JURMP. During FY 02-03, 377 industries were inspected.
This included 104 high, 144 medium and 129 low priority industries. The City inspected
all high and medium priority industries and contracted with D-Max Engineering to assist
inspections of some of the low priority industries.
Each month, approximately 30 businesses were selected from the master inventory list.
Inspection letters, along with the Industrial and Commercial BMP brochure, were sent to
each business notifying them of the upcoming inspection. Inspections were scheduled
within two weeks after the inspection letters were mailed. However, follow-up
inspections and future routine inspections were unannounced to better verify BMP
implementation and compliance.
In preparation for an inspection, the following facility-related information, if available, was
gathered:
• Permit Applications: Applicable permit applications (building permit or business
licenses) from the facility helped in assigning, confirming, or re-assigning SIC
codes. Permit applications also typically include information about a site such as
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 19
past/present owners/operators, size, contact names and numbers, and alternate
addresses.
• Past Inspection and Compliance Report Documentation: Previous inspection,
investigations and compliance reports from any accessible municipal, County, or
Regional Board files are reviewed to gather information on any previous
violations or other issues.
The inspector brings the following forms and equipment to the inspection:
• Inspection Form: This form includes any relevant information about the facility
such as business name, site address, contact name, SIC code, priority, and other
information useful during the inspection (see appendix 3-8).
• SWPPP Checklist: Part of the inspection includes a review of the site’s SWPPP,
if applicable.
• BMP Checklist: The inspector checks for the implementation of the minimum
BMPs, using this form to document compliance and noncompliance issues.
• Storm Water Discharge Parameter Benchmarks: This table of generally
acceptable analytical values for storm water discharges may be used by the
inspector during the review of past monitoring results, analysis of field samples,
and/or analysis of sampling, if applicable.
• Digital Camera: Photographs are taken of any illegal discharges or non-
compliance issues to be addressed in the inspection report.
• Brochures and Fact Sheets: Any applicable brochures and fact sheet are
provided to the facility operator during the inspection or with the inspection
report.
During each inspection, the City inspector reviewed SWPPPs, BMP implementation
plans, accuracy of SIC Code assignments, monitoring results, facility self-inspection
records, and annual compliance reports, when available. In addition, the City’s storm
water program, ordinance, General Industrial permit requirements, and recommended
BMPs were discussed. High priority industrial facilities were required to provide
SWPPPs, spill response plans, monitoring plans, and employee training guidelines for
review by the City inspector. A comprehensive site evaluation was conducted and the
facility operator was verbally notified of any deficiencies or violations.
An inspection report that included corrective actions, recommended BMPs, photographs,
compliance schedules, and other relevant information was mailed to the owner/operator
within 15 working days after the inspection via Certified mail. If violations were noted
during the inspection, the City required the submittal of a written explanation and
description of the actions taken to correct the problem. During FY 02-03, copies of
inspection reports and correspondence with High Priority industries were sent to the
Industrial Compliance Unit of the San Diego Regional Water Quality Control Board for
their review and follow up, if required. A sample report is included in appendix 3-9.
Follow-up inspections were performed within 60 days to verify implementation of the
corrective actions. If corrective actions were not implemented as required, or if the
business did not respond to the inspection report, the inspector began enforcement
actions, which may have included a verbal or written warning, Notice of Violation, or
Cease and Desist Order.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 20
Medium and low priority industries were inspected in response to a complaint or as
needed. More frequent inspections or follow-ups were conducted for sites found to be
out of compliance or placed on a compliance schedule. All high priority industrial sites
are inspected annually, unless the City receives confirmation from the SDRWQCB that
an inspection will or has occurred.
3.6 Enforcement of Industrial Sites
The City conducted follow-up inspections to determine compliance with the corrective
actions outlined in the inspection report or enforcement notices. Escalating enforcement
procedures provided flexibility in establishing appropriate compliance time frames. If a
significant and/or immediate threat to water quality was observed, appropriate actions
were taken to require the responsible party to immediately cease the discharge and/or
correct the situation. In judging the degree of severity, the inspector also took into
account any history of similar incidents or discharge.
The Enforcement Response Plan is used by City Storm Water Protection Program
inspectors to identify, document, and respond to storm water violations. The plan is
intended to provide guidance for City inspectors in selecting initial and follow-up
enforcement actions, identifying responsible staff, and specifying appropriate time
frames for actions. See the City’s Enforcement Response Plan (FY 01-02 JURMP
Annual Report) for a detailed description of the following typical escalating enforcement
procedures:
• Verbal Warning
• Written Warnings
• Notice of Violation
• Cease and Desist Order
• Notice and Order to Clean, Test, or Abate
• Civil and Criminal Court Actions
The Storm Water Protection Program has two full-time environmental specialists who
conduct inspections. Environmental Specialists are the Storm Water Protection Program
code enforcement personnel, and are required to successfully complete the Peace
Officer Orientation II Laws of Arrest Course (40 hours of a POST certified course
pursuant to Section 832(a) of the California Penal Code). Staff also attended the
Environmental and Regulatory Workshop and the 10th Annual Environmental Cross
Media Enforcement Symposium. These training courses, in addition to the Enforcement
Response Plan, help the Storm Water Protection Program staff to appropriately identify
and respond to storm water violations.
The City took a total of 15 enforcement actions against industries during FY 02-03 in
order to achieve compliance. These are listed in Table 3.1.
Table 3.1. Number of enforcement actions in FY 02-03 against industries.
Industrial Priority Written Warning Notice of Violation
High 1
Medium 10 4
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 21
Industrial sites typically had fewer violations and enforcement actions than commercial
sites. In general, industrial facilities have been more strictly regulated than commercial
facilities, as manufacturing facilities may also have additional permit and compliance
activities for air quality, hazardous materials, wastewater discharges, and so on. Many
high priority industries in Carlsbad have also been operating under the State General
Industrial Permit for several years, so unlike commercial facilities, storm water
compliance activities were better understood and implemented by the industry.
Commercial facilities are covered in section 4 of this report.
3.7 Non-compliance Notification Action Plan
All industrial facilities operating within the City’s jurisdiction were required to maintain
compliance with the Carlsbad Municipal Code and any requirements established in the
JURMP, as applicable to their operations. The Regional Board was sent all
correspondences and actions pertaining to high priority industries. Actions related to
medium priority sites were also sent to the Regional Board if the facility was considered
non-compliant or if their filing status needed to be documented (i.e. recommended NOI
filer or NONA certification required). If an incident or practice of non-compliance
occurred at an industrial facility, City inspectors determined if the incident posed a threat
to human or environmental health by considering the following criteria:
• Characteristics, quantity, and toxicity of substances/materials involved;
• Proximity of site to a sensitive water body;
• Proximity of site to an impaired water body;
• Proximity of site to a sensitive habitat/endangered species;
• Estimated volume of actual and/or potential discharge; and
• If discharges to storm drain, condition of storm drain (clog, etc.).
If an incident of non-compliance was determined to pose a threat to human or
environmental health (it required a hazardous materials emergency response), the City
will provide verbal notification to the Regional Board within 24 hours, followed by a
written report within 5 days. No incidents of this nature occurred during FY 02-03.
During this reporting period, only one incident of noncompliance was reported to the
Regional Board. On April 22, 2003, a letter was sent to the Regional Board notifying
them on the non-filer status of U.S. Logic Inc., a computer terminal manufacturer in
Carlsbad.
3.8 Self-Assessment
Program Strengths
City Storm Water Protection Program inspectors worked closely with businesses during
inspections. By developing contacts and providing consistent follow-up with business
representatives and owners, the City was able to establish open and professional
communications about storm water compliance issues. While these one-on-one
interactions are time-consuming, they were found to be effective for delivering the
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 22
message and ensuring compliance. The majority of sites were found to be compliant
during follow up inspections.
The Storm Water Protection Program developed a summary inspection format that
provided photos along with text describing problem areas and recommended corrective
actions. The summary inspection report was well received by industries. A sample
summary inspection report can be found in appendix 3-9.
The City maintained regular communications with the Industrial Compliance Unit of the
Regional Board throughout the year. In addition to copies of inspection reports and
other correspondences with high and medium industries, the City regularly coordinated
inspections and compliance issues with Regional Board representatives over the phone
and through emails.
The City recruited two students from the University of California, San Diego to participate
in a new internship program with the Storm Water Protection Program. Interns worked
on a variety of activities including commercial and industrial inspections, data
management, and outreach and education. Their assistance with inspections, home
based business reviews, data entry, and investigations increased productivity and
helped the program achieve inspection goals.
Program Improvement Areas
A formal, 5-page inspection form that includes contact information, a storm water check
off list and SWPPP review section is used during inspections. This form is not provided
to the businesses post inspection. A cover letter with a summary inspection report
follows within 15 days after the inspection and requires a written response from the
industry if corrective actions were identified. This process of back and forth
correspondences could be shortened with the use of a 1-page streamlined inspection
form that highlights compliance issues, corrective actions, and follow up inspection
dates. This form will only be used after the initial advisory inspection and a clear
understanding of storm water compliance issues is achieved by the industry. A copy of
the form will be left with the business representative post inspection and compliance will
be verified during follow up site visits.
Telephone surveys were used to determine status of home-based businesses on the
industrial inventory. Approximately 200 home-based industries were surveyed by
phone. This was highly time consuming and in most cases, screening determined that
the wrong SIC code had been applied during the business license application process.
Home-based businesses are prohibited by City code from conducting any work activities
or storing any materials outdoors. Therefore, most home-based businesses that are
identified on the business license with a manufacturing SIC code are not true
manufacturing facilities and actually pose little threat to water quality. Home based
business SIC codes should be screened more closely during the business license
application process and the business could be removed from the list, without telephone
screening, if the SIC code does not fall into one of the industrial SIC codes.
The Regional Board is currently revising the language and procedures outlined in the
State General Industrial Permit. The City highly anticipated the finalization of this
document in FY 02-03. Unfortunately it has not been completed. When the permit is
reissued, the City would like to host a workshop for all industries in Carlsbad to discuss
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 23
the new permit guidelines, compliance issues and address any concerns business might
have about the new permit.
Managing information about and from businesses proved to be a major undertaking
during FY 02-03. The Storm Water program does not have a database that meets all of
the needs of the program and is currently using four separate computer applications to
track businesses within the City. A dedicated storm water database would help the
program function efficiently and effectively, and allow for better tracking and reporting of
effectiveness measures.
Trash management continues to be a problem at some industrial sites throughout the
City. Closer coordination with Waste Management, who is the City contracted waste
hauler, may be beneficial to track businesses with continuous trash problems and begin
enforcement actions for those egregious violators.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 24
Section 4
Commercial Component
4.0 Overview
The City currently has over 680 high priority commercial facilities operating within its
jurisdiction. Commercial facilities can generate a variety of pollutants depending on the
activities performed. Automobile maintenance, pressure washing, masonry and
concrete work, carpet cleaning, and landscaping activities are some of the high priority
operations that have the potential to generate significant amounts of pollutants, if
performed with disregard to the environment. The City has implemented a
comprehensive program to reduce polluted urban runoff originating from existing
commercial facilities.
During FY 02-03, the City prioritized new commercial facilities and updated the
commercial inventory, mapped commercial facilities, provided education and outreach
on BMPs, inspected 351 commercial sites to ensure BMP implementation, and
conducted enforcement activities as needed to ensure compliance. These activities are
detailed in the following subsections.
4.1 Source Identification and Threat to Water Quality Prioritization
New businesses are issued business licenses on a continual basis and are documented
in the City of Carlsbad’s business license database. Every month, personnel from the
Storm Water Department queried the database to export the most recent business
license applications. On a quarterly basis, new businesses were sorted by SIC
(Standard Industrial Classification) code, and those businesses with applicable SIC
codes were prioritized and sent to the City’s GIS department for mapping. Once
mapped for proximity to an Environmentally Sensitive Area (ESA), their priority was
reassessed to determine if changes were necessary, and they were added to the current
year’s inventory list. New businesses were also found by referral from other agencies,
field discovery, or while responding to complaints from the public. The updated FY 02-
03 inventory list is found in appendix 4-1.
Prioritization of commercial businesses was determined by SIC code, proximity to an
ESA, compliance inspections, and field discovery. Refer to appendix 4-2 for procedure
SW-100, which gives a full description of the procedures used to determine commercial
priority. After telephone inquiries and onsite inspections, any changes to a business’
priority or status were recorded on the Storm Water Protection Program’s Inventory List.
Data related to commercial businesses within the City of Carlsbad are managed on a
continual basis as per departmental procedures and JURMP requirements. Paper
copies of documents related to commercial businesses were filed according to priority
and status (active, inactive, excluded) for the current fiscal year. Refer to appendix 3-2
for a full description of the procedure related to data management of the Inventory List
(procedure SW-110).
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 25
Appendix 4-3 contains a map of all current high priority commercial facilities. Because
restaurants/eating and drinking establishments and automotive facilities represent the
largest commercial groups in Carlsbad, the map contains separate symbols for the
locations of these facilities. The high priority commercial locations shown on the map
were created by first geocoding each location's address against the City of Carlsbad
parcel base map, and then the remaining unmatched sites were geocoded to the City's
street centerline layer. Locations matched to the parcel base were mapped to the parcel
centroid, locations matched to the street center lines were mapped to the estimated
location within the address range of the street center line segment, and all were mapped
to include proximity to the ESA.
4.2 Pollution Prevention
The City of Carlsbad’s approach is to promote pollution prevention Best Management
Practices (BMPs) as much as possible for all businesses within its jurisdiction. Specific
pollution prevention measures vary from one commercial site to another. The City
encourages the use of several activity specific BMPs during inspections, public events,
and workshops. Commercial businesses were informed of specific pollution prevention
opportunities during site inspections, in outreach materials, and through direct mailings
and correspondence. City inspectors regularly recommended and/or required the
following pollution prevention practices (detailed in individual facility inspection reports)
where appropriate:
• Reduce use of water or use dry cleanup methods. Businesses conducting
washing or cleaning activity that involves the use of a water hose or pressure
washing system were encouraged to try it dry (use mops, brooms, rags or wire
brushes to clean pavement, buildings and equipment as much as possible). The
City produced a brochure for power washing activities recommending dry
methods and other BMPs. Businesses were also encouraged to adjust irrigation
systems to prevent excessive irrigation runoff.
• Redirect storm water flows and conduct storm drain maintenance. Perform
regular visual inspections of the storm drain to identify unauthorized discharges
or pollutants and clean as needed. An industry may have been required to
modify downspout locations in order to redirect storm water flows away from
potential pollutant sources.
• Recycle. When inspecting solid waste collection areas, inspectors noted if
recyclable materials (cardboard, green waste, etc.) were placed in dumpsters
and recommended recycling.
• Move or cover potential pollution sources from storm water contact. Protect
materials and products that could potentially pollute storm water from rain, run-
on, runoff, and wind dispersal by storing them indoors, or covering them, and
providing them with secondary containment as needed.
Storm Water Pollution Prevention Plans (SWPPP’s) are always encouraged and may be
required by the City for certain commercial businesses based on inspection findings and
potential threat to water quality. If the City of Carlsbad required a commercial business
to implement a SWPPP after an inspection, the business was usually given 60-90 days
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 26
to develop the document and submit it to the Storm Water Department for review.
During subsequent follow up inspections, the business was expected to have
implemented the SWPPP and have procedures in place to ensure the document is
revised as business practices change. During FY 02-03, the City required 8 commercial
businesses to develop and submit SWPPPs.
4.3 Best Management Practices Implementation
The City required commercial businesses to implement the minimum BMPs identified
and described in the JURMP (good housekeeping, preventive maintenance, material
handling and storage, employee training, solid waste handling, record keeping, self
inspection, and spill response) as applicable to their operation. BMP information was
made available to commercial businesses during inspections, in printed materials and
direct mailings, at workshops and presentations, on the website and hotline, and at
outreach events. A complete listing of all education and outreach events held during FY
02-03 is in Appendix 9-1.
Printed Material
During FY 02-03, the City created several new commercial BMP brochures, including the
General BMP brochure referenced in report subsection 3.3 and found in appendix 3-5.
This brochure was distributed to all commercial businesses during inspections and by
direct mail. Over 600 of these brochures were distributed to commercial businesses
during FY 02-03.
In addition to the previously developed Restaurant brochures and Lawn & Garden
brochure, which are available in English and Spanish, the City created the following new
printed materials to cover the following commercial activities:
• Concrete and Mortar Projects,
• Lawn and Garden Care, Spanish translation
• Mobile and Pressure washing,
• Automotive Repair Shops, Spanish also
• Pool, Spa and Fountain Maintenance
• General Business BMPs
• Fats, Oils and Grease Fact Sheet
• Trash Fact Sheet
Direct Mailings
The City often used direct mailings in FY 02-03 to distribute the printed BMP material to
commercial businesses. These brochures were sent with the cover letter from the
Mayor (appendix 4-4) or with an invitation to a commercial workshop.
During FY 02-03, the City developed and distributed a BMP brochure for automotive
service and repair shops in both English and Spanish. This brochure is in Appendix 4-5.
In addition, the City worked closely with the Copermittee Outreach Workgroup to
develop and distribute “The Green Wrench Guide”, a BMP booklet for the automotive
industry.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 27
The City and the North County Storm Water Program (NCSWP) also developed a BMP
poster for automotive repair shops. The booklet and poster along with the City’s
automotive brochure were provided to all Carlsbad automotive facilities by direct mail,
during inspections, workshops, or complaint investigations. This poster is found in
appendix 4-6.
The City developed a BMP poster with the NCSWP (above right and in appendix 4-7)
that was distributed to all City restaurants during March and April 2003. The City
collaborated with the Copermittee Outreach Work Groups to develop and distribute
“What’s Cookin”, a BMP guide for eating and drinking establishments. The City also
continued to distribute the Restaurant BMP brochures (English and Spanish) developed
in FY 01-02.
During inspections at restaurants, outdoor grease bins and areas around grease traps
were often found to be a potential source of pollution. Dumpsters and solid waste areas
were also often observed to be potential problem areas. In response, the City created
two fact sheets that were distributed during inspections and complaint investigations.
The first entitled “Fats, Oils and Greases” included information about spill response and
clean up, and the second “Trash” addressed solid waste handling issues (see
appendices 4-8 and 4-9).
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 28
The City developed a new BMP brochure for mobile and pressure washing (appendix 4-
10) This was sent by direct mail to 21 mobile and pressure washing businesses on the
City’s mailing list. In addition, this brochure was provided during complaint
investigations where a mobile or pressure washer was found to be the responsible party.
A BMP brochure for concrete and mortar projects was created and distributed during FY
02-03. This brochure was mailed to 25 businesses, as well as being distributed during
complaint investigations (appendix 4-11).
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 29
A BMP brochure for pool, spa and fountain maintenance was also created and
distributed in FY 02-03 to 29 companies by direct mail and during complaint
investigations (appendix 4-12).
Inspections and Site Visits
Businesses have the flexibility to choose and implement source and treatment control
BMPs that are found to be the most effective. In order for the BMPs to be effective, they
must address the pollutants of concern and be specific to the activity that could result in
a discharge. The City may require BMPs based on problems identified during site
inspections. Inspection reports detailed corrective actions and recommended BMPs. If
corrective actions were required, follow-up inspections were conducted to verify
compliance. The City inspected 351 high priority commercial inspections during FY 02-
03.
During facility inspections, City staff reviewed SWPPPs, if available, assessed current
BMPs and on-going employee training programs, and required general or specific BMPs
as needed to prevent storm water pollution. BMP effectiveness was evaluated during
follow-up inspections. The City has the authority to require additional controls to be
implemented, if warranted, for commercial sites or sources tributary to Clean Water Act
section 303(d) impaired waters or other receiving waters within Environmentally
Sensitive Areas. Enforcement activities are further described in subsection 4.5 and
Section 8 of this report.
Workshops
The City, in association with the Copermittee Outreach Work Group, planned and
participated in four regional workshops during FY 02-03. The workshops focused on
providing BMPs and other storm water information to high priority commercial
businesses, including restaurants, automotive repairs shops, agricultural and
landscaping business, and the mobile trade industry.
Automotive Workshop: City representatives attended the Regional Automotive
workshop on August 8, 2002 in Escondido. Prior to the workshop, the City
mailed invitations to the automotive facilities within the City and included a copy
of the Automotive BMP brochure. There were 44 North County businesses at the
workshop.
Agricultural and Landscape Workshop: City representatives attended this
workshop on October 17, 2002, in Vista, with approximately 20 North County
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 30
businesses in attendance. Prior to the workshop, the City mailed invitations and
the Lawn and Garden Care brochure to 50 landscape companies and agricultural
operations in Carlsbad.
Mobile Trade Industry Workshop: City representative attended this workshop on
February 29, 2003, in Oceanside with approximately 29 businesses attending.
Prior to the workshop, the City mailed out invitations and the “BMPs for Power
Washing”, brochure to the mobile trade companies in the inventory (21).
Workshop for Eating and Drinking Establishments: City representatives attended
this workshop on May 22, 2003, with approximately 22 businesses attending.
Prior to the workshop, the City mailed out invitations and the BMP brochure for
restaurants (created in 2001) to the eating and drinking establishments in the
inventory (102).
Website and hotline
The Storm Water Hotline is listed on all printed material. Commercial businesses can
call the hotline to request BMP information. City brochures were also available through
the City website. During FY 02-03, there were 2,906 visits to the storm water web page.
Community Groups
An article highlighting the City’s Storm Water Program was published in the August 2002
edition of the Carlsbad Business Journal (see appendix 3-6), which has a circulation of
approximately 3,000 readers.
On November 7, 2002, a PowerPoint presentation was made to the Carlsbad Chamber
of Commerce Business Environment Committee that explained the City’s storm water
program, including outreach efforts, pollution prevention, enforcement and inspections of
commercial businesses.
Telephone Surveys
Telephone surveys were used to determine status of home-based businesses on the
commercial inventory (active, excluded, no longer in business, moved), appropriateness
of SIC codes, and type of activities conducted onsite. Over 150 home-based
commercial businesses were surveyed by phone. In some cases, this screening
procedure determined that the wrong SIC code had been applied during the business
license application process.
The Carlsbad Municipal Code prohibits any home-based business from conducting any
activities outdoors or storing materials outdoors. However, home-based businesses
may include mobile operations that could pose a threat to water quality depending on the
type of business (i.e., paint contractors, landscapers, mobile washing, etc.). Once
confirmed, these businesses were entered into the Permits Plus database program, and
business owners were mailed specific BMP brochures (power washing, pool
maintenance, and etc.) along with general storm water information. If a business was
excluded from additional inspections and storm water requirements (wrong SIC, etc.),
the City mailed the owner general storm water information and removed the business
from the annual inspection inventory.
Customer Service Survey
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 31
Businesses inspected by the City were invited to complete a short written survey to
measure knowledge of BMPs and storm water pollution prevention and to assess their
satisfaction with the City’s storm water compliance inspection process. The results of
this survey are found in appendix 10-1.
4.4 Inspection of Commercial Sites
Site visits and inspections were the primary methods used by the City to educate and
ensure storm water pollution prevention and BMP implementation at commercial sites.
The City conducted inspections of commercial businesses on a complaint basis or as
time and resources became available. During FY 02-03, the City contracted with D-Max
Engineering Inc. to assist with commercial business inspections. A total of 351
commercial sites were inspected.
A large percentage of businesses on the inventory list were home-based businesses.
Many commercial home-based businesses involved those in the mobile trade industry
(carpet cleaning, power washing, etc.), which are considered high priority. These
businesses were identified, contacted and mailed appropriate BMP information. The
City reviewed another 257 businesses and excluded 134 commercial businesses based
on several qualifying factors including SIC Code, location, business type, and probability
to contribute to storm water pollution. The City also found that 6 had moved out of the
City, 115 were out of business, and 2 were duplicates. This information is detailed in
appendix 4-13.
Each month, approximately 30 businesses are selected from the master inventory list.
Inspection letters, along with the general industrial and commercial BMP brochure, are
sent to each business notifying them of the upcoming inspection. Inspections were
scheduled within two weeks after the inspection letters were mailed. However, follow-up
inspections and future routine inspections were unannounced to better verify BMP
implementation and compliance.
Prior to an inspection, the following facility-related information was gathered when
available:
• Permit Applications: Applicable permit applications (building permit or business
licenses) from the facility helped in assigning, confirming, or re-assigning SIC
codes. Permit applications also typically include information about a site such as
past/present owners/operators, size, contact names and numbers, and alternate
addresses.
• Past Inspection and Compliance Report Documentation: Previous inspection,
investigations, and compliance reports from accessible municipal, County, or
federal files are reviewed to gather information on any previous violations or
other issues.
The inspector brought the following forms and equipment to the inspection:
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 32
• Inspection Form: This form includes any relevant information about the facility
such as business name, site address, contact name, SIC, priority, and other
information useful during the inspection.
• SWPPP Checklist: Part of the inspection includes a review of the site’s SWPPP,
if applicable.
• BMP Checklist: The inspector checks for the implementation of the minimum
BMPs, using this form to document compliance and non-compliance issues.
• Digital Camera: Photographs are taken of any illegal discharges or non-
compliance issues to be addressed in the inspection report.
• Brochures and Fact Sheets: Any applicable brochures and fact sheet are
provided to the facility operator during the inspection or with the inspection
report.
During each inspection, City inspectors reviewed SWPPPs, BMP implementation plans,
accuracy of SIC Code assignments, and facility self-inspection records, when available.
In addition, the City’s storm water program, ordinances, and recommended BMPs were
discussed. Eight high priority commercial facilities were required to develop SWPPPs,
spill response plans, and employee training guidelines. A comprehensive site evaluation
was conducted and the facility operator was verbally notified of any deficiencies or
violations.
An inspection report that included corrective actions, recommended BMPs, photographs,
a compliance schedule, and other relevant information was mailed to the owner/operator
within 15 working days after the inspection via Certified mail (see sample in appendix 3-
9). If violations were noted during the inspection, the City required the submittal of a
written explanation and description of the actions taken to correct the problem.
Follow-up inspections were performed within 60 days to verify implementation of the
corrective actions. If corrections were not made as required, or if the business did not
respond to the inspection report, the inspector began an enforcement action, which may
have included a verbal or written warning, Notice of Violation, or Cease and Desist
Order. These procedures are detailed in the City’s Enforcement Response Plan,
previously submitted with the FY 01-02 JURMP Annual Report.
4.5 Enforcement of Commercial Sites and Sources
When a storm water complaint was received about a commercial site or source, or an
illegal discharge was observed or suspected, the City conducted a complete storm water
inspection. Commercial sites or sources were also selected for inspection based on
results of dry-weather field screening indicating a potential problem. As more water
quality data are collected, it is expected that commercial sites may be chosen for
inspection based on their potential to discharge a constituent of concern to a specific
water body.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 33
Table 4-1. Number of Commercial Enforcement Actions in FY 02-03.
Action Total Number
Verbal warning 8
Informational Letter 17
Written Warning 9
Notice of Violation 16
Cease & Desist Order 1
The City conducted 7 inspections of commercial sites based on illegal discharge reports.
All of these were the result of facility and equipment washing to the storm drain, except
one that was a sediment control problem.
In addition, there were 24 commercial mobile businesses working on residential sites
that were identified in response to illegal discharge investigations. These included
construction contractors, landscaping companies, pool construction and maintenance
companies, mobile detailers and pressure washers, and carpet cleaning companies.
Escalated enforcement actions were taken when necessary to achieve compliance. In
some cases, an informational letter or written warning was escalated to a Notice of
Violation if compliance was not achieved with the first effort. More detailed information
on complaint response and illegal discharge investigations is found in report section 8
and appendix 8-2.
4.6 Self-Assessment
Program Strengths
City Storm Water Protection Program inspectors worked closely with businesses during
inspections. By developing contacts and providing consistent follow-up with business
representatives and owners, the City was able to establish open and professional
communications about storm water compliance issues. While these one-on-one
interactions are time-consuming, they were found to be effective for delivering the
message and ensuring compliance. The majority of sites were found to be compliant
during follow up inspections.
The Storm Water Program developed a summary inspection format that provided photos
along with text describing problem areas and recommended corrective actions. The
summary inspection report was well received by commercial businesses. A sample
summary inspection report can be found in appendix 3-9.
The City in association with the Copermittee Outreach Work Group planned and
participated in four regional workshops during FY 02-03. The workshops focused on
providing BMPs and other storm water information to high priority commercial
businesses, including restaurants, automotive repairs shops, agricultural and
landscaping business, and the mobile trade industry. There were approximately 145
commercial representatives from businesses throughout North County.
The City recruited two students from the University of California, San Diego to participate
in a new internship program with the Storm Water Protection Program. Interns worked
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 34
on a variety of activities including commercial inspections, data management, and
outreach and education. Their assistance with inspections, home based business
reviews, data entry, and investigations, increased productivity and helped the program
achieve its inspection goals.
The City’s goal was to respond to “happening right now” complaints within 30 minutes.
This goal was consistently met throughout the year. There were several complaints filed
for commercial businesses (primarily mobile commercial businesses) in Carlsbad during
the reporting year and in most cases prompt enforcement action followed.
Because the City could only conduct inspections of commercial businesses on a
complaint basis or as time and resources became available, D-Max Engineering Inc.
was contracted to conduct 232 commercial business inspections. The completion of
these commercial inspections helped the City update the commercial inventory and
assure BMP implementation at commercial sites.
Program Improvement Areas
A formal, 5-page inspection form that includes contact information, storm water check off
list and SWPPP review section is used during advisory inspections. This form is not
provided to the businesses post inspection. A summary inspection report follows within
15 days after the inspection and requires a written response. This process of back and
forth correspondences could be shorten with the use of a 1-page streamline inspection
form that highlights compliance issues, corrective actions, and follow up inspection
dates. This form would only be used after the initial advisory inspection and a clear
understanding of storm water compliance issues is achieved by the industry. A copy of
the form would be left with the business representative post inspection and compliance
is ensured during follow up site visits.
Telephone surveys were used to determine status of home-based businesses on the
commercial inventory. Approximately 150 home-based commercial businesses were
surveyed by phone. This was highly time consuming and in most cases, screening
determined that the wrong SIC code had been applied during the business license
application process. Carlsbad Municipal Code prohibits any home-based business from
conducting any activities outdoors or storing materials outdoors. However, home-based
businesses may include mobile operations that could pose a threat to water quality
depending on the type of business (i.e., paint contractors, landscapers, mobile trades,
etc.). Home based business SIC codes should be screened more closely during the
business license application process and business could be removed from the list,
without telephone screening, if the SIC does not fall with a high or medium SIC
parameter.
Managing information about and from businesses proved to be a major undertaking
during FY 02-03. The Storm Water program does not have a database that meets all of
the needs of the program and is currently using four computer applications to track
business with within the City. A dedicated storm water database would help the program
function would efficiently and effectively.
Trash management continues to be a major problem at commercial sites throughout the
City. Closer coordination with Coast Waste Management would be beneficial to track
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 35
businesses with continuous trash programs and begin enforcement actions for those
egregious violators.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 36
Section 5
Residential Component
5.0 Overview
The City of Carlsbad encompasses approximately 42 square miles, with an estimated
population of 90,300 residents (January 1, 2003, California Department of Finance). At
build out, sometime beyond year 2010, there will be nearly 54,599 residential units,
housing approximately 135,000 residents. The residential community has a significant
potential to contribute to water quality degradation. The focus of the City’s pollution
prevention strategy is a proactive information and education program that utilizes public
presentations, fact sheets, direct mailers, brochures, and the media to increase
knowledge and awareness of storm water pollution prevention efforts.
During FY 02-03, the City developed and distributed storm water educational information
for residential activities, hosted or participated in various outreach events, provided
HHW collection and oil recycling drop-off sites, responded to illegal discharge reports,
and conducted enforcement as necessary to achieve compliance. These activities are
further described in the following subsections.
5.1 Threat to Water Quality Prioritization
The City of Carlsbad borders over 6 miles of coastline and has three coastal lagoons
partially or completely within the City’s jurisdiction. Because of these water bodies and
the tributaries leading to them, most residential activities have the potential to
significantly impact water quality. Residents who live a few miles from a lagoon or creek
are expected to implement the same Best Management Practices (BMPs) as those who
live within 200 feet of a lagoon or creek, because all are part of a watershed and their
individual activities can adversely impact water quality. Sending a message that only
those residences immediately adjacent to a water body must implement specific BMPs is
contradictory to the watershed education messages being delivered. For this reason,
the City chose to target high priority residential activities instead of areas. Following are
the targeted activities that have the potential to adversely impact water quality in the
watershed:
• Vehicle washing
• Vehicle storage and maintenance
• Lawn and garden care
• Home improvement projects
• Pet waste disposal
• Swimming pool and spa maintenance
• Trash and debris cleanup and disposal
The City addressed these activities through outreach and education efforts at the local,
watershed, and regional levels using the most efficient and effective methods available.
In addition, high priority activities were also addressed during investigations of illicit
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 37
connections, illegal discharges, or other public complaints (See subsection 5.5 and
Section 8 of this report). Current and on-going outreach efforts include the following:
• Public presentations
• Internet web site
• Storm water hotline
• BMP brochure and other printed materials development
• General outreach efforts through printed ads, press releases, media interviews
Specific education efforts are further detailed in Section 9 of this report.
5.2 Pollution Prevention (including HHW and Oil recycling programs)
A comprehensive outreach and education program that increases knowledge and
awareness of pollution prevention measures is continuously being implemented.
Residential pollution prevention opportunities were typically incorporated into the BMP
brochures and handouts that were developed for residents. This information was
distributed to residents through various means, including mass mailings, public events,
or conveyed during personal interactions with City inspectors while investigating
potential storm water violations. This information was also presented in newspaper
articles, public newsletters, and other publications. The brochures and household
hazardous waste information was available on the City’s website. These outreach
methods for BMP distribution are detailed in section 5.3. Pollution prevention strategies
typically contained in the City’s outreach materials included:
• Use alternative, safer, or recycled products
• Recycle and properly dispose of solid waste
• Reduce use of water
• Use dry cleanup methods
• Reduce the amount of hazardous materials by implementing natural controls
• Redirect storm water flows away from areas of concern
The following were some specific pollution prevention methods communicated in printed
material:
y Sweep and Rake. Sweep up debris and put it in a trash can. Do not use
a hose to wash off sidewalks, parking areas and garages. Rake up yard
waste and start a compost pile.
y Dispose of Yard Waste More Frequently. By disposing of grass,
leaves, shrubs and other organic matter more frequently, less will wash
into storm drains.
y Reduce Use of Landscape Chemicals. Decrease the use of lawn and
garden care products such as pesticides, insecticides, weed killers,
fertilizers, herbicides and other chemicals. Avoid over-irrigation that
washes chemicals into the gutter and storm drains.
y Use Soap Sparingly. When washing your car at home, use soap
sparingly, divert wash water to landscaped areas and pour your bucket of
soapy water down the sink. Never wash your car in the street.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 38
y Clean up After Your Pets. Take a bag when you walk your pets and be
sure to always clean up after them. Flush pet waste down the toilet or
dispose of it in a sealed plastic bag and throw it in the trash.
y Care for Your Cars. Fix oil leaks immediately. When you change your
oil, recycle it properly. For the recycling center nearest you, call 1-800-
CLEANUP.
y Buy Non-Toxic Products. When possible, use non-toxic products in
household cleaning. If you must use a toxic cleaning product, buy small
quantities, use it sparingly and properly dispose of unused portions. For
the household hazardous waste collection facility nearest you, call 1-800-
CLEANUP.
The City continued to endorse a used oil-recycling program where the public can recycle
up to 10 quarts of used motor oil and/or 15 quarts of diesel at four locations. Used motor
oil was only accepted if it was not mixed with other liquids, including water, antifreeze,
gasoline, or parts cleaners. The following four locations accepted used oil for recycling.
Firestone Store
#2252
2545 El Camino
Real
Carlsbad, CA 92008
760-434-8392
CIWMB# 37-C-
01199
Jiffy Lube # 1621
6021 Paseo Del
Norte
Carlsbad, CA 92009
760-431-9875
CIWMB# 37-C-
02977
Ken Grody GMC
Pontiac
5445 Paseo Del Norte
Carlsbad, CA 92008
760-438-1021
CIWMB# 37-C-05563
HHW Collection
Facility
1165 East Taylor
Street Vista, CA 92084
800-714-1195
The City promoted the used oil collection program through various outreach and
education efforts. The City’s web page (http://www.ci.carlsbad.ca.us/cserv/oil.html)
offered residents information on how and where to properly dispose of used oil. There
were 1,679 hits on this web page for the year.
The program was also promoted at various public events such as the Public Works Fair,
Earth Day, Carlsbad Day at the San Diego Fair, Business Expo, Barrio Festival, and the
Citizens’ Academy. The City provided phone numbers for the disposal locations as well
as specific City Solid Waste number to request general information about household
hazardous waste disposal.
HOUSEHOLD HAZARDOUS WASTE PROGRAM
The City’s Household Hazardous Waste (HHW) program promotes alternatives to the
illegal disposal of household hazardous waste and used oil for the protection of
California's environment and the health of its inhabitants.
The City contracted with the City of Vista for Carlsbad residents to dispose of HHW at
the HHW Collection Facility on 1165 East Taylor Street in Vista, California.
During FY 02-03, 1,344 Carlsbad residents used this facility to dispose of 67.84 tons of
HHW. The collection facility is open on Saturdays, 9 a.m. to 3 p.m. only (facility is
closed on holiday weekends). The City has a toll-free phone number to request
additional information on HHW (800-714-1195) and the collection facility was continually
promoted through mailers to residents and on the City’s Website. City of Carlsbad
residents disposed of the following types of HHW:
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 39
Table 5.1. HHW amounts collected during FY 02-03.
Activity
Quantity
(in tons)
Flammable solid/liquid 7.89
Oil-base Paint 14.37
Poison (non-Aerosol) 4.11
Organic/Inorganic Acid 0.546
Organiz/Inorganic Base 1.76
PCB Waste/Mercury 0.00935
Empty Drums 0
Oxidizing Base 0.198
Propane Cylinders 0
Flammable Aerosols 1.8
Poison Aerosols 0.1723
Antifreeze 1.172
Car Batteries 3.729
Latex Paint 18.58
Motor Oil 5.67
Oil Filters 0.172
Household Batteries 0.687
Fluorescent Bulbs 0.077
Class9/Non-RCRA 6.08
Asbestos 0.379
Total 67.84
The City promoted the HHW disposal program through various outreach and education
efforts. The City’s web page offers residents information on how and where to properly
dispose of used oil. The same outreach methods and tools used for oil program were
and will be employed for the HHW program. The outreach efforts for the HHW program
will piggyback on the used oil program in many circumstances. The City plans on
reaching single-family residences, multi-family residences, children and City employees
on these programs.
The City distributed a HHW guide to residents entitled “Put Toxic Waste In It’s Place”.
This booklet was created jointly by the Solana Center for Environmental Innovation and
the Integrated Waste Management Board. This 17-page booklet defined HHW and
included information on how families can protect themselves from hazardous chemicals,
use safer alternatives, and dispose of HHW properly.
5.3 Best Management Practices Implementation
The City has developed and implemented a program to reduce contaminants in urban
runoff originating from existing residential areas. As part of this program, the City
designated minimum BMPs for high priority residential activities and worked to ensure
that the BMPs were implemented. Information on pollution prevention and best
management practices was communicated to residents through various methods
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 40
including printed material, education and outreach events, and illegal discharge reports
and complaint investigations. These are further described below.
Printed Material
The City developed various BMP booklets for high priority residential activities. During
this report period, previously developed brochures addressing pet waste, residential car
washing, motor oil, and lawn and garden care were distributed to residents.
During FY 02-03, the City translated the “Lawn & Garden Care” brochure into Spanish
(appendix 5-1), and developed several new fact sheets and brochures. Some of these
new materials were applicable to residents as well as commercial operations. These
materials provided information on how to prevent storm water pollution for the following
activities:
• Home improvement projects (see below and appendix 5-2)
• Concrete and Mortar work (see section 4.0 and appendix 4-10)
• Power washing/surface cleaning (see section 4.0 and appendix 4-9)
• Solid waste disposal and trash issues (see below and appendix 4-8)
• Private storm drain cleaning (appendix 5-3)
The City worked with the North County Storm Water Program (NCSWP) to develop a
general BMP brochure for residents (see below and appendix 5-4). In addition, this
group worked with the Solana Center for Environmental Innovation who provided a
colorful poster with the message “Storm Drains Lead Straight To the Ocean”. This
poster also advertised 1-800-CLEANUP.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 41
Direct Mailings
The City purchased a brochure from Water Environment Federation entitled “Fat-Free
Sewers”, and distributed it to all City sewer customers as a bill stuffer (see subsection
8.6). This brochure explained how to prevent fats, oils and greases from damaging
homes and the environment by preventing sewer blockages and spills. The City’s
Maintenance and Operations phone number along with the City’s Storm Water Hotline
number were included on the back of each brochure. This brochure was sent to
approximately 20,000 Carlsbad customers in January 2003.
The Winter 2002 edition of the Carlsbad Community Services Guide, which has a
circulation of approximately 38,000, contained an article written by City staff on storm
water protection (see appendix 5-5).
The Storm Water Protection Program also included information on storm water pollution
prevention and BMPs in the City’s Annual Drinking Water Quality Report, which was
mailed to all water customers (approximately 24,500) in June 2003 (appendix 5-6).
Website and hotline
Printed outreach materials were made available for download from the City’s website. In
addition, residents can call the Storm Water Hotline to request copies of these materials.
There were 2,906 hits to the storm water web page during FY 02-03.
Presentations
Twice a year, the City hosts an event called “Citizen’s Academy”. This seven week
course (one night per week) educates residents about Carlsbad City government and
public services. A PowerPoint presentation, which included an overview of the Storm
Water Protection Program, related permit and regulations, program activities, and
residential BMPs, was presented to the group. In addition, storm water outreach
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 42
materials were available to the participants and the Enviroscape watershed model was
demonstrated. Approximately 100 residents attended the two Academies held on
September 26, 2002 and February 20, 2003.
The City’s Storm Water Protection Program purchased an EnviroScape watershed
model. This interactive, three-dimensional landscape illustrates residential, recreational,
agricultural, industrial and transportation areas -- all representing possible sources of
water pollution. Children and adults learn how pollutants can flow through a typical
community. Household items such as drink mix (fertilizers and pesticides), candy
sprinkles (trash and pet waste), soy sauce (motor oil), non-dairy creamer (paint and
sludge), cocoa (sediments), and parsley flakes (lawn clippings) are used to demonstrate
how daily activities can affect water quality. While the EnviroScape model emphasizes
the sources of pollution, a second demonstration shows how to prevent pollution. City
staff used this educational tool at various public events.
Public Events
The City hosted or participated in several public events, which provided opportunities for
residents to learn about storm water pollution prevention. Table 5.2 provides a summary
of these events. During most of these events, a booth was set up and residents had the
opportunity to pick up printed materials, view an Enviroscape model demonstration, and
speak directly with City storm water representatives.
Table 5.2. Outreach events for the Residential Community
Event Date Type Attendance Location
Buena Vista Creek
Cleanup Day
9/21/02
Manned table,
printed materials
60 Oceanside
Carlsbad
Citizen’s Academy 09/26/03 Powerpoint,
Enviroscape
model
50 Carlsbad
Presentation for
Homeowner’s
Assoc.
11/14/02 Presentation and
printed materials
50 Carlsbad
Citizen’s Academy 2/20/02 Powerpoint,
Enviroscape
model
50 Carlsbad
Children’s Day at
the Flower Fields
3/29/03
3/30/03
Booth,
Enviroscape
model, brochures
200+ Carlsbad
Earth Day at
Balboa Park
4/27/03 Booth,
Enviroscape
model, materials
600+ San Diego
Direct Interactions
Residents were educated about pollution prevention and storm water BMPs during
complaint investigations. Typically, follow-up informational letters were sent to
homeowners after an investigation. These correspondences often included brochures
and fact sheets. Additional information on complaint investigations is provided in section
5.4.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 43
Promotional items
Promotional pens were created jointly with the North County Storm Water Program
(NCSWP) promoting 1-800-CLEANUP, and contained the following pollution prevention
messages each time the pen was clicked: “Pickup litter, Cigarette Butts”; “Recycle
Motor Oil and Filters”; “Eliminate Water Runoff”; “Pickup Pet Waste”; “Sweep
Sidewalks”; “Reduce Pesticide Use”. Other items that displayed the City’s storm water
logo, message and hotline number included a raindrop “stress ball”, raindrop notepads,
and key chains. These were distributed at public events and group presentations.
5.4 Enforcement of Residential Areas and Activities
The public can report illegal discharges to the storm drain or any activities that may
impact water quality to the storm water hotline. Reports of illegal discharges were also
received through the storm water email address or from other City departments. All
reports and referrals were promptly investigated and resolved to the fullest extent.
Specific information on the effects of storm water pollution and how to prevent future
impacts to water quality through the use of BMPs was provided to the residential
community during investigations. This information was designed to increase the public’s
awareness and understanding of storm water pollution prevention efforts and water
quality enhancement. When enforcement actions were necessary, the City inspector
utilized the appropriate enforcement mechanisms as allowed by the Carlsbad Municipal
Code, described in section 5.4 of the JURMP, and the Enforcement Response Plan.
The City jointly produced a door hanger with the NCSWP (see appendix 5-7). This door
hanger was used during residential investigations when the exact source or person
responsible for the discharge could not be determined. The door hangers include
pictures and text about common pollutant sources, with check boxes to highlight the
types of pollutants found, and the storm water hotline number. The purpose of the door
hanger was to inform the residents of storm water pollution in their neighborhood, to
educate them on BMPs, and to provide them with a number to call if they have additional
information to report.
While the City emphasized education as the primary method for changing behavior, City
inspectors and staff with enforcement authority could initiate enforcement actions
against residents who discharged pollutants to the storm water conveyance system, or
who failed to implement BMPs required by the City. The inspectors, in accordance with
the City’s existing procedures and Enforcement Response Plan, documented each
observed violation. Depending on the severity of the violation, enforcement could range
from a verbal warning to monetary fines.
During FY 02-03, the Storm Water Protection Program responded to 156 complaints of
illegal discharges. Of these, 99 were from residential sites. Of these 99, 35 were from
contractors or other mobile businesses working at residential sites. In 28 of these
incidents, there was no violation found, either because it was an exempt discharge or a
source was not found as reported. Thirteen of these 99 were referred to other
departments or agencies for action and resolution, including City departments
(Engineering Inspections, Maintenance and Operations, Parks and Rec), other water
and sewer districts (Olivenhain and Leucadia), and County vector control.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 44
During investigations, the Storm Water Protection Program inspector informed the
responsible party of the problem or violations and how to correct them and/or prevent
future occurrences. The City gave 32 verbal warnings and left door hanger literature
during 35 investigations. The number one priority was to prevent a discharge from
reaching a waterbody. City maintenance crews were often called on-site to block storm
drains and to vactor pollutants out of catch basins. In 20 of these incidents, City
maintenance crews cleaned the site, 19 were cleaned by the resident, and 4 were
cleaned by contractors. Occasionally, a resident responsible for an illegal discharge to
the City’s storm drain system was held responsible for the cleanup costs.
When verbal warnings or letters were not sufficient to achieve compliance, or additional
documentation was warranted, the City escalated enforcement actions by issuing written
warnings or a Notice of Violation. There were 9 written warnings and 4 NOV’s issued
from incidents occurring at residential sites.
Table 5.3 – Total number of enforcement actions against residents in 02-03.
Action Total
Verbal warning 32
Info letter 39
Written Warning 9
Notice of Violation 4
A description of these enforcement actions is found in section 8.5.
5.5 Self-Assessment
Program Strengths
Residents were informed of specific pollution prevention opportunities and BMPs during
investigations, in outreach materials and events, water bill stuffers, the media, and
through correspondences. By developing contacts and providing consistent follow up
with residents, the City was able to establish open and professional communications
about storm water compliance issues.
The Storm Water Protection Program depends on other City departments to assist with
investigations and remediation during field reviews. The City’s M & O Department is key
to prompt, effective responses to residential complaints involving clean ups. Regular
meetings and discussions about compliance issues and consistent contacts facilitate this
coordination with departmental representatives.
Program Improvement Areas
The City plans to create a unified City Environmental Programs message combining
storm water, water conservation and HHW/recycling information. This message will help
foster a better understand of the relationship between everyday residential activities
such as lawn and garden care, pool maintenance, car repair, recycling, and the sources
of pollution in our waterways.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 45
Outreach and education efforts will be expanded during Fiscal Year 03-04 through a
variety of outreach tools including print advertising, information flier development, utility
billing stuffers, community update calendars, welcome aboard packets, and outreach
events. The City also plans to develop and distribute promotional items such as
magnets, oil funnels, oil rags, post-it notes and tire gauges that have messages to
promote used oil recycling.
An additional used oil collection facility is anticipated for Fiscal Year 03-04. This site will
provide residents with five locations to properly dispose of used oil. The City is
researching the coordination of special collection events during FY 03-04 in addition to
the enhanced outreach efforts already identified.
During FY 03-04, the City anticipates making an additional permanent collection facility
in Oceanside available for residents to dispose of HHW material. The facility will be
open every other Saturday from 9 a.m. to 1 p.m. by appointment only. Residents are
expected to receive a scheduled appointment within 7-10 days after the request, thereby
keeping the wait time for disposal at a minimum. In addition, the City of Carlsbad is
exploring the feasibility of curbside HHW by fiscal year 2004-05.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 46
Section 6
Land-Use Planning Component
6.0 Overview
The City’s Land Use and Planning Department is concerned with the quality of life of the
people that live, work, and visit Carlsbad. The General Permit requires the City to
evaluate its land use planning policies and principles, revise the environmental review
processes, and develop an approval process to minimize the short- and long-term
impacts of development activities on receiving water quality. Land-use planning in the
City of Carlsbad gives local leaders and the community an opportunity to comment on
and shape policies that guide community development and interests. The City has
developed goals that balance environmental protection with smart, long-term economic
growth. By laying out a vision for local growth and coastal development, projects are
consistent with the state and federal regulatory requirements and the City’s land-use
planning efforts. This section of the annual report outlines Land-Use Planning actions
implemented in FY 02-03 and describes the specific actions completed, in progress, or
projected to meet or exceed the Permit requirements.
6.1 Assessment of General Plan
In September 1994, the City of Carlsbad adopted an aggressive growth management
plan (General Plan) to guide development and anticipate the types and numbers of
facilities needed to accommodate the Carlsbad community at build out. The General
Plan is reviewed and revised annually to ensure that the public interest is considered
and City goals are met.
The City has adopted a Local Coastal Program covering that part of the City within the
Coastal Zone. Under the California Natural Community Conservation Program (NCCP),
the City of Carlsbad and six other cities in northern San Diego County participated in the
preparation of the Multiple Habitat Conservation Program (MHCP). The MHCP is a
comprehensive planning program designed to develop an extensive ecological preserve
in northwestern San Diego County. The City of Carlsbad, a participant in the MHCP,
prepared a subarea plan, called the Carlsbad Habitat Management Plan (December
1999). The HMP contains the specific conservation, management, facility planning, land
use, and other actions the City will take to implement the goals, guidelines, and
standards or the MHCP plan. The California Coastal Commission approved the Draft
HMP in June 2003.
The City revised the General Plan, Zoning Ordinance, and Municipal Code to comply
with Order 2001-01 and address water quality and watershed protection. On November
1, 2002, the revised Zoning Ordinance, Municipal Code, and Local Coastal Plan
Amendments were submitted to the California Coastal Commission. To date, a Coastal
Commission hearing has not been scheduled to consider these amendments.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 47
6.2 Modification Development Project Approval Process
The City requires project proponents to design measures that prevent and/or reduce
pollutants, to the maximum extent practicable, from impacting receiving water quality.
All projects were subject to a thorough discretionary and plan check review process to
ensure that water quality requirements for the development comply with the City’s storm
water ordinances, local permits, Order 2001-01, and any other applicable requirements.
This reporting year the Development Services Division of the Engineering Department
amended the project application submittal checklists to bring greater attention to the
requirements of pollution control. Prior to the official submittal of a development
application, the City offers a process called a Preliminary Review Application. This
process is used to educate developers, applicants, engineers, and citizens about the
requirements to integrate pollution control measures into preliminary project plans prior
to finalizing project designs.
This preliminary review, along with the formal discretionary review process, is the first
opportunity the City has to prepare written comments on a specific development
proposal with water quality objectives. During the preliminary review, pollution
prevention measures were integrated into the initial design of the project. If the
proposed project impacts are over 1-acre of land, applicants/developers are required to
submit a preliminary SWPPP to address potential water quality impacts that may result
from the proposed development. For projects disturbing less than 1 acre and listed as a
priority project pursuant to Order 2001-01 a preliminary Storm Water Management Plan
(SWMP) is required. By requiring applicants/developers to submit these documents, the
City has an opportunity to thoroughly review each proposed project and ensure all
associated impacts are considered and adequate mitigation measures are incorporated.
The discretionary development checklist has been revised to include both the SWPPP
and SWMP requirement.
SUSMP
The City, in cooperation with the other Copermittees, developed and adopted Model
Standard Urban Storm water Mitigation Plan (SUSMP) for the entire region. The City
also prepared a local SUSMP that covers priority development projects, BMPs, and
integration of pollution prevention measures into projects. SUSMP requirements apply
to all new development and major redevelopment projects as designated by the City.
The local SUSMP identifies specific post-construction site design, source control and
treatment control storm water BMPs that must be implemented on certain larger
development projects, called “Priority Projects.”
In FY 02-03, 5,621 permits/projects were issued and/or approved. Of those ministerial
and discretionary projects, 3,804 were from the Building Department, 1,380 were from
Engineering and 437 were from the Planning Department. Of that 5,621 permits and
projects, 65 discretionary projects were reviewed and required to submit applicable
SWPPPs and SWMPs.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 48
6.3 Revisions to Environmental Review Process
The review of all discretionary projects is consistent with the requirements of the
California Environmental Quality Act (CEQA). Project proposals are reviewed to ensure
that all development will be in compliance with the new/revised Grading, Storm Water,
and Coastal ordinances, Order 2001-01, local permits, and all other applicable
ordinances and requirements. Prior to project approval and issuance of local permits,
the City requires each proposed project to implement measures that prevent and reduce
pollutants associated with the development, to the maximum extent practicable, from
impacting receiving water quality.
6.4 Education on New Development and Redevelopment
Municipal Staff Education
Weekly staff meetings include the review of new discretionary permits. In 31 of these
meetings (see appendix 6-1), specific and general topics about pollutant control were
discussed for the purpose of continuous training. During these weekly project reviews,
staff discussed each new project to determine if pollutants of concern were considered
and that proper source and/or treatment control measures were incorporated. Past
experiences, design alternatives, effectiveness, long-term maintenance, and other
relevant issues to water quality are also discussed during these weekly reviews.
Education for Developers, Contractors, Property Owners, and Community Planning
Groups
In May 2003, the City and the County of San Diego hosted a public workshop entitled
“SUSMP and Construction Inspection Seminar” (see appendix 6-2). The City also
presented training on NPDES Best Management Practices for Construction Sites. The
purpose of these efforts was to review and educate project applicants, local engineers,
developers, contractors, and property owners about water quality requirements, roles,
development standards, and expectations of new projects.
Topics addressed at the workshops:
¾ Priority Development Projects: These include subdivisions, commercial
developments, auto repair, restaurants, hillside development environmentally
sensitive areas, parking lots over 5,000 s.f., and streets over 5,000 s.f.
¾ Modification Development Project Approval Process Actions: The City
included a questionnaire with the project application package to determine
whether each proposed project was subject to construction and/or post-
construction storm water BMP requirements.
¾ Source Control And Treatment Control BMPs: The incorporation of source
control BMPs is first and foremost in the minimization of runoff from impervious
areas.
¾ Engineering Construction Documents: The ordinance was reviewed for
compliance with the City’s storm water ordinances and Order 2001-01. The
grading ordinance requires the implementation of BMPs and other measures.
Phased grading was not specifically addressed in the grading ordinance but is
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 49
addressed as a policy within the Engineering Department, which administers the
grading permit process.
¾ SWPPPs: This document must include measures that ensure pollutant
discharges are reduced to the maximum extent practicable. In addition that plan
must also outline how storm water and non-storm water discharges will be
managed; erosion control measures; grading procedures; soil stabilization; and
re-vegetation efforts. Sample SWPPPs and SWMPs are available as a guide for
engineers, developers and applicants when preparing these documents for
proposed development projects.
¾ Modifications of Construction and Grading Approval Process Actions: The
general project review process for obtaining a construction/building permit
includes the identification of BMPs and review of previously approved
discretionary permits during the construction permit process. There are four
basic types of projects to be reviewed during the to ensure compliance with the
minimum BMPs. These include Exempt Permits; Building Permits;
Grading/Building Projects not subject to the require an NPDES General
Construction Permit; and Grading/Building Projects that are subject to a NPDES
General Construction Permit.
The City will continue to meet with project proponents and provide educational
opportunities and materials on water quality requirements and objectives for new and
redevelopment projects.
6.5 Self-Assessment
Program Strengths
Staff continued to promote staff education of water quality objectives by adding this to
weekly meetings and discussing applicability to discretionary and final plan check
projects.
During fiscal year 02-03, development services incorporated precise grading permits for
single family, multifamily and commercial development. This effort is in addition to
issuing rough grading permits. Developers are now required to prepare precise grading
plans together with supporting water quality documents (SWMP, SWPPP or both,
whichever is applicable). This process triggers engineering inspections to be involved in
construction activities while monitoring construction and post-construction activities.
In December 2003, through approval by City Council, staff has also added both review
and inspection fees for SWPPP’s. These fees are based on project size. This funding
will support our staff in reviewing the documents before final approval and fund
inspections of the storm water bmp measures as part of each project.
Staff is working on a goal that will create a storm water database. The database would
assist staff in monitoring locations and types of permanent bmp measures through the
City that would hopefully be integrated with our GIS mapping.
Program Improvement Areas
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 50
An improvement would be to complete the storm water database program, begin adding
data to the system, and measure effectiveness of the program.
Other improvements would be sending staff to additional water quality training seminars
during FY 03-04 to ensure that knowledge on project criteria, BMP measures, and
numeric sizing is refreshed and kept accurate.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 51
Section 7
Construction Component
7.0 Overview
The Permit requires the City to implement activities that address and minimize short and
long-term impacts on receiving water quality related to run off from new construction
sites. Performance goals are used to assess the completeness of this component and
the effectiveness of action plans. These performance goals include construction site
inspections, BMP implementation reviews, corrective actions, enforcement, and
reporting requirements.
During FY 02-03, the City updated the construction inventory, inspected all high priority
sites, conducted education and outreach to developers, engineers, contractors, and City
staff, and used enforcement actions to obtain compliance when necessary. These
activities are described in the following subsections.
7.1 Source Identification and Threat to Water Quality Prioritization
To assist in the prioritization and identification of threats to water quality, the City uses
the Permits Plus database system to develop and update a watershed based inventory
of all construction sites that require a grading permit within the City regardless of site
size or ownership. This is done during the grading permit process. Construction sites
with grading permits may include any site where an activity such as grading, excavation,
clearing, road construction, structure construction, or demolition results in the
disturbance of soil.
The City prioritized all active grading permits for FY 02-03 as high priority for the
purposes of conducting site inspections.
The inventory of construction sites with an active grading permit is found in appendix 7-
1. This inventory is maintained throughout the year. For the purposes of this report, a
report was generated on September 30, 2003, which illustrates the active grading
permits and priority prior to the wet season.
7.2 Pollution Prevention
Pollution prevention consists of procedures and practices that eliminate or reduce the
generation of pollutants at their source. The City has identified and required
implementation of the following controls to prevent pollution for new construction sites:
SWPPPs and erosion control plans are required for grading permits and
applicable construction projects. These plans are checked by the City to
ensure they adequately address the provisions of the General Permit for
Construction.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 52
Engineering inspectors enforce implementation of BMPs described in
approved erosion control plans and SWPPPs.
Building permit construction sites are required to implement minimum BMPs,
if a grading permit has been issued .
The City has adopted the pollution prevention measures contained in the Stormwater
Best Management Practice Handbooks, published by the California Stormwater Quality
Association (CASQA), Caltrans Storm Water Quality Handbooks, and Standards for
Design & Construction of Public Works Improvements in the City of Carlsbad.
The purpose of the City checking grading permit applications for compliance the General
Permit for Construction is not to duplicate or perform the duties of the Regional Water
Qualtiy Cotnrol Board (Regional Board). It is to enhance the permitting process. The
City has found the process confusing and contradictory in the past. The goal of the City
is to compliment Regional Board requirements so that the overall process is easy to
understand by the construction industry. For example, many of the BMPs contained in
the SWPPPs are incorporated into the grading plan. In the past an erosion control plan
may call for particular BMP and the SWPPP may refer to a different one. In looking at
the project as a whole, these types of discrepancies are minimized.
7.3 Construction and Grading Approval Process
The City currently has mechanisms in place to ensure that all construction sites with a
grading permit implement measures to reduce pollutants to the maximum extent
practicable. The City requires, prior to approval of a grading permit, that projects
implement measures to ensure that pollutants from the site will be reduced to the
maximum extent practicable and will not cause or contribute to an exceedance of water
quality objectives. The City is meeting this obligation by amending or conditioning
existing permits, procedures and ordinances that are already in place.
The general project review process for obtaining a construction/building permit is as
follows:
Identify the project’s BMP requirements.
Determine adequacy of project’s proposed storm water BMPs.
Include BMP requirements in permit conditions, and/or plans and specifications.
Review previously approved discretionary permits during the construction permit
process for post-construction BMPs identified in discretionary approvals, or
equivalent (where applicable).
Review proposed revisions to approved projects for additional storm water
requirements (where applicable).
The City has modified it’s requirements to be consistent with the General Construction
Permit, requiring projects of 1 acre or larger to prepare a SWPPP.
The City has also defined a process to outline how BMPs and other pollution prevention
measures will be required and implemented. The process is described as follows:
Construction Permit Application
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 53
A fact sheet has been developed in accordance with the Municipal Permit that identifies
and prioritizes construction activities. The fact sheet is completed by the construction
permit applicant and reviewed by City staff who also assist the applicant in determining
the appropriate BMPs and documents required (SWPPP, SWMP, and minimum BMPs)
to complete the permit application.
This is currently a requirement for construction sites with an active grading permit. The
City is in the process of implementing these procedures into ministerial permits. It
should be noted that that the City’s grading ordinance is very strict and captures the
majority of all construction sites. Once the ministerial permits process includes minimum
BMPs, this will capture construction site that may not have a grading permit. An
example of these ministerial permits would be one single residential home construction
with minimal grading, home remodeling, and commercial site tenant improvements.
Construction Permit Processing
Based on the initial project information and assessment contained in the permit
application, staff review applications to determine the adequacy and accuracy of the
information. During the permitting process, the appropriate BMPs, pollution prevention
methods required, and documents necessary (SWPPP, SWMP, and minimum BMPs)
are reviewed and incorporated into the permit requirements.
The City implemented the construction and grading requirements of the Municipal Permit
into local construction and grading permits. A Building/Grading Permits Checklist was
developed to ensure construction and grading requirements are incorporated into the
construction/building permits.
The following construction and grading requirements are incorporated into the
construction and building permits through the use of a checklist:
The project proponent must:
Develop and implement a plan to manage storm water and non-storm water
discharges from the site at all times;
Minimize grading during the wet season and coincide grading with seasonal dry
weather periods to the extent feasible. If grading does occur during the wet season,
require project proponent to implement additional BMPs for any rain events which
may occur, as necessary for compliance with the Permit;
Emphasize erosion prevention as the most important measure for keeping sediment
on site during construction;
Utilize sediment controls as a supplement to erosion prevention for keeping sediment
on-site during construction, and never as the single or primary method;
Minimize areas that are cleared and graded to only the portion of the site that is
necessary for construction;
Minimize exposure time of disturbed soil areas;
Temporarily stabilize and reseed disturbed soil areas as rapidly as possible;
Permanently re-vegetate or landscape as early as feasible; and
Stabilize all slopes.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 54
7.4 Best Management Practice Implementation
The City developed a list of BMPs for construction sites with an active grading permit. A
list of minimum BMPs was developed and incorporated into the construction/building
permit process. The City approves specific BMPs during the review of SWPPPs,
grading plans, erosion control plans, and other water quality documents during the
construction permit review process. All active grading permits for FY 02-03 were ranked
as high priority for the purpose of evaluation of BMPs.
Designation of Minimum BMPs
All construction sites with and active grading permit must be protected to prevent
discharges to the maximum extent practicable (MEP). Each site, at a minimum, must be
protected by an effective combination of erosion and sediment controls, materials and
waste management controls and site management controls. The minimum BMPs are
determined on a case-by-case basis during SWPPP, grading plan, and erosion control
plan reviews. BMPs are required to be in place year round.
The following categories of BMPs are required at construction sites with an active
grading permit:
1. Erosion control for graded slopes
2. Erosion control for graded flat areas (slope < 5%)
3. Sediment control for perimeter boundaries
4. Offsite tracking control of sediment
5. Materials management control
6. Waste management control
7. Non-storm water management control
Construction sites with an active grading permit are required to implement at least one
BMP from categories 1 through 3 and all applicable BMPs in categories 4 through 7.
If a BMP is found to be inadequate, then another, higher-level BMP is automatically
required. For example, a stabilized construction entrance of large rocks (TC-1) may be
adequate for a portion of the project, but may need to be upgraded to a tire wash facility
(TC-3) if truck traffic increases and offsite tracking occurs. If a set of minimum BMPs is
infeasible at a specific site, the City requires the use of other equivalent BMPs.
The City is in the process of developing minimum BMPs for ministerial construction
permits to be required for construction sites that don’t have an active grading permit. It
should be noted that if a project is required to obtain a grading permit, the grading permit
is typically active throughout the building phase. As a result, most construction projects
are required to implement minimum BMPs throughout the life of the construction
activities.
Additional BMP Requirements
BMP implementation is required year round, regardless of site threat to water quality
priority. The implementation of additional BMPs is required for high priority sites during
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 55
the wet season.
Additional BMPs considered for construction sites with an active grading permit are as
follows:
• Scheduling (not grading during the rainy season)
• Preservation of Existing Vegetation
• Vegetation Buffer Strips
• Dust Control
• Soil Stabilizers
• Earthen Dikes
• Ditches and Berms
• Slope Drains
• Temporary Drains & Swales
• Check Dams
• Slope Terracing
• Brush or Rock Filter
• Sediment Trap
• Sediment Basin
• Employee & Subcontractor Training
• Spill Prevention & Control
• Contaminated Soil Management
• Water Conservation
• Structure Construction & Painting
• Paving Operations
• Dewatering Operations
• BMP Inspection and Maintenance
• Phase Construction (conduct grading in phases to minimize disturbed area)
• Training
• Good Housekeeping
The City has developed a list of additional BMPs to be implemented for construction
sites with an active grading permit that discharge to a tributary of a 303(d) water body or
are located adjacent to and/or discharging directly to an ESA. During the discretionary
and environmental review process, impacts to ESAs and impaired water bodies are fully
evaluated. In most cases, the project proponent will need to submit a preliminary
SWPPP to the Engineering Department. The SWPPP is evaluated to determine if all
potential water quality impacts and appropriate BMPs described to mitigate those
impacts have been addressed. If additional BMPs are required they are incorporated
into the site design at this stage.
7.5 Inspection of Construction Sites
In accordance with the Municipal Permit requirements, inspections are performed to
insure compliance. This includes the review of implemented BMPs, pollution prevention
methods, and documents (SWPPP, SWMP, and minimum BMPs) related for the
implementation of pollution prevention efforts. If additional BMPs or revisions to the
stormwater pollution prevention documents are needed, the City inspector requires
revisions and the appropriate enforcement measures are taken, if necessary.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 56
Prior to the rainy season and throughout the year, the City creates an request for
inspection for each construction site with an active grading permit. All of the projects are
considered a high priority, as a result, each site is inspected once a week during the wet
season and at least twice during the dry season. The City has staffed appropriately
based on this level of effort.
The City developed and implemented a checklist for inspecting construction sites to
ensure compliance with applicable ordinances, permits (building, grading, storm water
etc.), and Order 2001-01. This checklist is included in the Engineering Inspection
Manual as Exhibit 3-18B and is found in appendix 7-2. In addition, site inspection
procedures were developed that require developers to implement an effective
combination of BMPs to meet or exceed the water quality protection requirements based
upon the sites potential threat to receiving waters.
7.6 Enforcement of Construction Sites
Any BMP violations and/or exceedances of the benchmark water quality parameters are
discussed with the site supervisor during inspections. If BMP violations an/or elevated
levels are not or cannot be immediately addressed by the site supervisor, the inspector
will require the submittal of a written explanation and description of the actions that will
be taken to correct the problem. The site supervisor is given an inspection form for each
violation documented during the inspection. If the site supervisor does not resolve
violations discovered during an inspection voluntarily, the City will pursue appropriate
enforcement actions as detailed in the City’s Enforcement Response Plan.
The Carlsbad Municipal Code has been revised to include specific enforcement of the
storm water quality requirements contained in the grading ordinance. Section 15.12.150
(Administrative Code Enforcement Powers and Procedures) provides additional specific
enforcement powers in addition to the general enforcement powers already contained in
Title 1, Sections 15.12 and 15.16 of the Municipal Code.
The City has an Enforcement Response Plan; however, a specific and separate
enforcement response plan has not been developed for construction and grading
activities. Currently, it is the City’s policy to respond to complaints and implement
enforcement actions described in the Municipal Code until the situation is effectively
remedied. In addition, the City requires developers and builders to submit cash
deposits, which can be used to install appropriate erosion control materials and
infrastructure, if deemed necessary by the City because of negligence by the builder.
These funds ensure that adequate erosion control measures are implemented at
construction sites. The Engineering Department works closely with the City Attorney’s
Office on projects subject to enforcement actions that include penalties, fines, public
nuisance declarations, or court actions. All other enforcement actions are handled
administratively within the Engineering Department in accordance to existing policies
and procedures.
The City has defined a process to identify and annually assess the construction sites
with active grading permits for the purposes of reporting to the RWQCB. Whenever an
inspector creates a field memo, correction notice, or a notice of violation, that information
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 57
is logged into the Permits Plus database for reporting purposes to the RWQCB. The
following table is a summary of enforcement actions taken by the City.
Table 7.1 Total number of enforcement actions taken during FY 02-03.
Actions Taken Number of Actions
Field Memo 37
Correction Notice 0
Stop Work Notice 3
Total Actions 40
7.7 Reporting of Noncompliant Sites
The City has defined the process for identifying and annually assessing noncompliant
sites to determine if an act of noncompliance presents a threat to storm water quality.
The Public Works Director or designated representative provides verbal notification,
within 24 hours, to the Regioanl Board of non-compliant sites that may pose a threat to
human or environmental health. Written follow-up notification within 5 days of the
discovery of the noncompliant site is sent via certified mail to the Regional Board. Non-
compliant construction sites considered a potential threat to water quality criteria are
outlined in Section 7.8.1 of the JURMP and the Municipal Code is used to respond
appropriately and evaluate each individual situation. Other regulations are applied, as
appropriate, for impacts to human health and the environment that would not necessarily
affect storm water or receiving water. Non-compliant sites will continue to be reported to
the Regional Board.
During this reporting period the only site reported to the Regional Board for
noncompliance was the Carlsbad Unified School District construction site at Calaveras
Elementary School. The school district is a State agency and not under the jurisdiction
of the City.
7.8 Education on Construction Activities
Staff were trained on the sections of the JURMP that they are responsible for
implementing. In addition, employees were trained on specific topics during regular staff
meetings. Additional training took place as part of “case reviews” conducted by the lead
inspector and/or the supervisor.
“Case reviews” typically involve the review and discussion of projects that present
unusual or challenging circumstances. Staff evaluates SWPPPs or BMPs for difficulties,
problems or methods that have proven to be successful. The process of sharing field
and practical experience expands the skills and knowledge of the City staff. Some “case
reviews” may involve finding alternative solutions or recommendations for projects that
present new challenges to staff.
Also, City staff involved in planning, development, construction, and inspection activities
received on-going training related to their duties and responsibilities. For example,
inspectors attended several workshops and seminars held by the City of San Diego,
County of San Diego, Caltrans, RWQCB, and San Diego State University Soils Lab staff
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 58
as well as those hosted by BMP manufacturer representatives. Internal training is also
given during bi-weekly staff meetings.
A list of training sessions and attendees is in appendix 7-3.
The City conducts workshops to educate external parties, which includes project
applicants, developers, contractors, and property owners on the implementation of the
Carlsbad stormwater program for construction sites. On May 16, 2003, the City hosted a
seminar in conjunction with the County of San Diego and the North County Civil
Engineers and Land Surveyors Association. Attached is an attendance list and agenda
of the information presented.
7.9 Self Assessment
Program Strengths
During this reporting period, the City conducted several work shops and training
seminars to educate engineers, developers, contractors, and City staff who are involved
with construction activities in the City of Carlsbad.
The City classified all grading permit applications as high priority projects for the
purposes of implementing minimum construction site BMPs and construction BMP
inspections.
The City of Carlsbad implemented the inspection of BMP requirements on all grading
permit projects.
Overall the implementation of construction BMPs has been very successful.
Program Improvement Areas
The City developed a goal for several key employees to review the effectiveness of
implementing minimum construction site BMPs for ministerial permits. It is expected that
during the reporting period for FY 03-04 revised procedures and additional minimum
BMPs will be developed to be used for ministerial permits.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 59
Section 8
Illicit Discharges Detection and
Elimination Component
8.0 Overview
The City continued to conduct an active program for detecting and eliminating illegal
discharges to the storm drain system. The City’s program actively seeks and eliminates
illicit discharges and connections by conducting illegal discharge investigations,
responding to spills and sewage overflows, conducting monitoring and performing
routine cleaning and maintenance activities on the sewer and storm drain systems.
Information on the City’s HHW and oil recycling programs are in sub-section 5.2.
8.1 Monitoring Programs
Dry Weather Analytical and Field Screening Monitoring
The City has conducted an annual Dry Weather Analytical and Field Screening
Monitoring program since 1995. The purpose of the monitoring program is to detect and
eliminate illicit connections and illegal discharges to the storm drain system. This
program consists of field observations, field screening, visual monitoring, and analytical
monitoring at selected sites throughout the City’s storm drain system. During FY 02-03,
this monitoring was performed at 60 sites.
For the past six years, the City has contracted this work out to D-Max Engineering, Inc.
Follow-up investigations were conducted by D-Max Engineering and City of Carlsbad
staff, based on best professional judgment in combination with the action levels and
confidence intervals established by the Monitoring Workgroup. The dry weather
monitoring program report for FY 02-03 is under separate cover, and a summary of
follow-up activities is found in Appendix 8-1.
Coastal Outfall Monitoring
The City is required by the NPDES permit to conduct a coastal outfall monitoring
program to detect and mitigate urban runoff discharges to coastal storm drain outfalls.
This program was initiated in November 2001 using a prescriptive approach, which
required monthly monitoring of coastal outfalls and receiving waters from November 1
through March 31, and sampling every other week between April 1 and October 31.
Samples are collected at flowing outfalls and in the receiving water and are analyzed for
Total Coliform, Fecal Coliform and Enterococci.
The program expanded in November 2002 to include outfalls to coastal lagoons. This
significantly increased the number of outfalls monitored by the City of Carlsbad. During
FY 02-03, the coastal monitoring workgroup also developed an adaptive strategy for the
storm drain monitoring program, which was approved by the Regional Board and
implemented on April 1, 2003.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 60
While this program was primarily designed after the AB411 Recreational Water
Monitoring Program, this effort can also help identify illegal discharges, illicit
connections, or other sewage contamination sources. Sampling is conducted year
round, however samples are not collected within 72 hours of a rainfall event so that any
discharge sampled will represent dry weather flows only. If bacteria results from the
outfall exceed standards established by the program, the site may be re-sampled and
upstream investigations are initiated as described in the Adaptive Program. The coastal
and lagoon outfall results are detailed in Attachment A of the copermittees unified report
covering the receiving waters monitoring program.
Investigation Sampling
City Storm Water Protection Program employees respond to reports of illegal discharges
and have been trained in water quality sampling techniques. Staff uses field testing
equipment and a variety of field sampling containers, which can be placed on ice and
delivered to a certified laboratory for analysis. If an unknown discharge is suspected to
be hazardous, the County Hazardous Materials inspectors are immediately contacted.
County inspectors can often do additional field tests for hazardous characteristics or
concentrations, as well as providing guidance on how to safely proceed with cleanup
and disposal.
8.2 Public Reporting of Illicit Discharges and Connections
The public continued to use the storm water hotline and e-mail address to report illegal
discharges to the storm drain system. Storm Water Protection Program staff answer the
hotline and check emails during regular office hours and forward the information to the
appropriate personnel. After regular office hours, the hotline provides a voice mail
message (in English and Spanish) directing complainants to leave a message for follow-
up or be directed to dispatch for emergency response (i.e., dumping of hazardous
materials into the storm water system). Reports received by e-mail are forwarded to the
appropriate personnel for investigation. When an illegal discharge is reported as
“happening right now” during regular office hours, an inspector is immediately
dispatched to the site.
During FY 02-03, the two regional stormwater hotlines continued to be operated in San
Diego County. In addition to a manned service during business hours, the hotlines
provide a voice mail message for 24-hour access in both English and Spanish. Through
these hotlines, complaint information is forwarded to the appropriate City contacts for
follow up and/or investigation. The following are the numbers and e-mail address
available for public reporting of illegal discharges and connections:
¾ City of Carlsbad Storm Water Hotline: (760) 602-2799
¾ City of Carlsbad Storm Water Email: stormwater@ci.carlsbad.ca.us
¾ Regional Stormwater Hotline: 1-888-846-080
¾ THINKBLUE Hotline: 1-888-THINKBLUE (1-888-844-6525)
In April 2002, the City’s Suite Response Request For Action (RFA) system went online.
This complaint and response tracking database is used by the Storm Water Protection
Program and other City departments. During FY 02-03, the RFA program was being
implemented by over 90% of City departments. This Citywide, web based customer
relationship management software program allows employees to take a request or
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 61
complaint and have it routed electronically to the appropriate person for investigation. In
cases where an illegal discharge is reported as “happening right now”, the City
employee taking the request, is prompted by a RFA dialog box to contact the Storm
Water Protection Program for immediate response. All results of the investigation are
entered into the RFA and tracked electronically by the system. The system sends e-mail
reminders to ensure that every request is addressed and acted on until resolved.
8.3 Illicit Connection/Illegal Discharge (IC/ID) Investigation and Follow-up
The following information details how the City investigates and responds to illegal
discharge complaints:
High Priority Discharges: Discharges are considered high priority if the activity
is “happening right now” and directly entering or has entered the storm drain
conveyance, waterway, or ocean. Investigations of high priority discharges are
immediately initiated. During an investigation, inspectors identify and coordinate
efforts with other City departments to eliminate the source, identify the
responsible party, and initiate enforcement action, if necessary. The
investigation includes documentation of all activities and observations occurring
during the site visit. Investigations may include interviews with witnesses and
responsible parties, upstream evaluation, sampling, field testing, and interagency
coordination. Some investigations involve follow-up visits or re-inspections to
ensure the discharge has been eliminated. Types of high priority discharges:
1. “Happening Right Now” Discharges: Spills that are “currently” occurring
have the greatest potential for an effective cleanup if prompt action is taken.
Immediate action will abate the spill, eliminate the pollutant source, and only
permit a small amount of the pollutant to be discharged thereby reducing the
time and effort needed for clean up.
2. Spills Directly into the Waterway or Ocean: Spills that enter the waterway
and ocean can cause the most damage because they directly affect the
receiving water. These require immediate action t and may require additional
protective measures (booms, absorbent materials, etc.) to be implemented
while the clean up is ongoing.
3. Sewage Spills: The City’s Maintenance and Operation (M & O) Department
responds and provides remediation for most sewage spills. If the source of
the spill is not the result of a line break or other accidental cause, City storm
water inspectors conduct follow-up investigations to determine the source of
the spill and initiate enforcement actions. Details of the M & O response to
sewage spills is found in Section 8.
Normal Priority Discharges: Discharges are considered normal priority if the
activity is not directly flowing into the storm drain, already happened, or the threat
to water quality is minimal. Investigations of normal priority discharges are
initiated as time and resources become available. The same investigation and
documentation procedures used for high priority discharges are also
implemented for normal priority discharges.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 62
When an inspector determines that the situation poses an immediate and severe risk to
public health or the environment, the City coordinates with other agencies or teams
specially trained to assess and mitigate emergency situations (i.e. Fire Department and
County HazMat teams, etc.). Investigators contact these agencies as soon as they
determine that it is warranted based on the severity of the situation. On December 20,
2002, the City of Carlsbad Fire Department assisted the storm water program with an
emergency situation involving the discharge of diesel fuel to the ocean from a
commercial facility.
Whenever possible, digital photos were taken to document the occurrence and/or clean-
up action. These photos were included and available in the investigation file and RFA
database. In cases where an incoming complaint report (or dry weather monitoring) did
not identify the source of a discharge, field screening analyses were often conducted to
determine the components of the discharge. Although field screening is preferred for
quickly evaluating a discharge, samples are collected for laboratory analysis if field
screening results are inconclusive.
During FY 02-03, the City Storm Water Protection Program responded to 156 complaints
or storm water referrals. In addition, 557 complaints or requests for action related to
storm water quality, the sewer system, or storm drain system maintenance were
conducted by Engineering Inspections, Code Enforcement, and M & O (Utility
Operations, Construction Maintenance, and Street Maintenance). An issue summary
report with yearly totals by complaint type is shown below:
Table 8.1. Total numbers of issues in RFA for FY 02-03 by department responding.
Issue Type/SubType Department Total #
Animals-Pet Waste - Private Property Code Enforcement 5
Desiltation Basin-Complaint Engineering 2
Erosion-Erosion from new construction Engineering Inspections 4
Animals-Pet Waste - Public Property Storm Water Protection Program 3
Dirt/Debris-Piles Storm Water Protection Program 28
Erosion-Erosion from Existing Development Storm Water Protection Program 7
Storm Drain-Dumping to Storm Drain Storm Water Protection Program 43
Storm Drain-Washing to Storm Drain Storm Water Protection Program 45
Storm Water-General Information/Questions Storm Water Protection Program 10
Vehicles-Leaking Oil or Fluids Storm Water Protection Program 20
Drainage-Runoff from street M & O - Streets Maintenance 23
Drainage-Water ponding/pooling M & O - Streets Maintenance 49
Litter/Debris-Clean up request M & O - Streets Maintenance 273
Storm Drain-Damaged/Needs Repair M & O - Streets Maintenance 20
Storm Drain-Needs Cleaning M & O - Streets Maintenance 50
Street Sweeping-Request for sweeping M & O - Streets Maintenance 39
Lift Station-Spill/leak M & O - Utility Operations 1
Sewer System-Leak M & O - Utility Operations 1
Sewer System-Sewer Stoppage M & O - Utility Operations 85
Sewer System-Sewer Stoppage at Cleanout M & O - Utility Operations 3
Sewer System-Sewer Stoppage in Street M & O - Utility Operations 1
Sewer System-Sewer Stoppage Private M & O - Utility Operations 1
Grand Total 713
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 63
A summary of all of the above investigations and responses is found in Appendix 8-2.
8.4 Elimination of Illicit Connections and Discharges
The IC/ID elimination process is an ongoing endeavor, involving a combination of
education, inspections, complaint response, and enforcement. The City uses one or any
combination of these efforts as is necessary to achieve compliance. The ultimate goal is
eliminate the discharge or connection and to prevent future occurrences. Enforcement
actions are discussed further in subsection 8.5.
During FY 02-03, the Storm Water Protection Program responded to 156 complaints of
potential illegal discharges. All of these complaints were investigated, however in some
cases either a source was not found or the source was not an illegal discharge (i.e.
groundwater seepage). Table 8.2 lists the total number of illegal discharges and
connections eliminated.
During this reporting period, one illicit connection was identified and eliminated. This
investigation was the result of an inquiry from the business owner regarding the drains at
the facility. D-Max Engineering on behalf of the City conducted a storm water
compliance inspection of Pat and Oscar’s Restaurant on May 22, 2002. During the
inspection a drain, reported to be sewer connection was found in an enclosed, covered
trash storage area. The City inspector requested additional information about the drain
and soon after a Pat and Oscar’s representative contacted the City and stated that the
drain was in fact a storm drain. The drain was permanently blocked to prevent future
discharges from the dumpster area.
Table 8.2. Total numbers of illegal discharges and illicit connections eliminated
from residential, commercial and industrial sources.
Discharge Eliminated Residential Commercial Industrial
Illegal discharge 36 35 18
Illicit connection 0 1 0
All of the illegal discharges eliminated from industrial facilities were identified during
inspections. All of the residential and twenty of the commercial discharges eliminated
were in response to complaints.
8.5 Ordinance Enforcement
The first step the City took to eliminate discharges or prevent repeat occurrences was to
educate the responsible party about the discharge or connection and ensure corrective
actions were adequately and promptly implemented. Voluntary elimination of illegal
discharges was strongly encouraged. In most cases a verbal warning was sufficient to
stop the discharge or correct the activity. Whenever appropriate, these verbal warnings
were combined with distribution of educational information (BMP brochures, fact sheets,
copies of the ordinance, and etc.). However, when sufficient action was not taken to
comply with the verbal warning, the City initiated additional enforcement actions.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 64
Enforcement was based on the intensity, frequency, duration, and knowing intent of the
violation. Depending on the severity of the violation, enforcement ranged from a written
warning to Notices of Violation (NOV) or Cease and Desist orders. During FY 02-03, no
administrative, civil and/or criminal court actions or monetary penalties were sought
against violators. Table 8.3 lists the total numbers of enforcement actions taken during
the reporting period.
Table 8.3 Total number of enforcement actions taken for existing development.
Type of Action Residential Commercial Industrial Total
Verbal warning 32 8 0 40
Information letter 39 17 0 56
Written Warning 9 9 11 29
Notice of
Violation
4 16 4 24
Cease and Desist 0 1 0 1
Notice to Clean 0 0 0 0
Admin. Citation 0 0 0 0
TOTAL 84 51 15 150
Verbal warning: In most cases, a verbal warning on-site was sufficient to stop the
discharge or correct the activity. Whenever appropriate, these verbal warnings were
combined with distribution of educational information. Any potential or illegal discharges
noted at an industrial or commercial site (not a mobile business) were written in the
inspection report.
Information Letter: Informational letters are typically used to provide additional
educational information about the storm water program and new requirements when a
violation was not considered a serious threat or an intentional illegal discharge. Any
potential or illegal discharge observed during an industrial or commercial inspection was
addressed on-site, noted in the written inspection report, and followed up with a
compliance schedule, written warning, or NOV as appropriate.
Written Warning: These are similar to a NOV and are intended to provide
documentation of the incident and educational materials about the City’s storm water
pollution prevention requirements. The issuance of a warning notice constitutes the
initiation of escalating enforcement actions.
Notice of Violation, Administrative Citation and Cease and Desist Orders: A Notice
of Violation is a formal letter detailing the specific CMC violation along with corrective
actions and a timeline for compliance. If the responsible party does not comply as
required, the City can follow with an Administrative Citation, starting at $100 per
violation. A Cease and Desist order is a formal notice to stop a discharge or operation.
During FY 02-03, the issued NOV’s and Cease and Desist Order were effective in
correcting the violations.
8.6 Spill Response and Sanitary Sewer System Maintenance
The City continued to actively prevent and respond to sewage spills and other spills, and
to limit discharges from the sanitary sewer system to the MS4. This occurred through
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 65
public education and outreach, inspections, preventive maintenance, complaint
response, and spill response, which included containment and remediation.
Education
Educating the public about the proper disposal of fats, oils and greases is the most
effective way of preventing sewage spills. In order to educate the public about proper
disposal, the City purchased and distributed a brochure from Water Environment
Federation entitled “Fat-Free Sewers”. The brochure was provided to all City sewer
customers (approximately 20,000 customers) as a water bill stuffer in January 2003.
The M & O and Storm Water Hotline phone numbers were included on the back of each
brochure.
Spill response
M & O responds to sewage spills within the City of Carlsbad sanitary sewer collection
system, and cooperates with the Leucadia Wastewater District and Olivenhain Water
District for sewage spills that occur within their collection system in Carlsbad. During
normal business hours, calls are dispatched through M & O to field units for immediate
response and evaluation. After working hours, phone numbers are routed through police
dispatch to construction maintenance standby personnel.
City employees are trained to follow the City’s Sewer Overflow Prevention
Plan/Response Plan, which is found in appendix 8 - 3. Staff training was conducted
semi-annually, and tailgate meetings were held quarterly. All of spill response incidents
were tracked in the RFA system or spill reports. Sanitary sewage overflow responses
were documented as required on the Sanitary Sewer Overflow Report Form, which was
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 66
faxed to the Regional Water Quality Control Board, the County Health department, and
the City Storm Water Protection Program after a spill response.
During FY 02-03, the City responded to 17 sewage overflow or spills. A total of 2,335
gallons were recovered with approximately 10,371 gallons entering the environment.
The overflow report details are found in appendix 8-4.
Seven of the overflows were from private laterals, lines or cleanouts. While the City is
not responsible for private property overflows, Carlsbad does respond and assist the
owner to prevent discharges to the environment. The City recovered over 600 gallons
from private sewage overflows and spills.
There were six overflows that entered a storm drain, and two overflows that reached
Agua Hedionda Lagoon (100 gallons) and Buena Vista Creek (7000 gallons). When
receiving waters were impacted, the City notified proper authorities and posted the
areas.
A portion of the Leucadia Wastewater District collection system is located within
Carlsbad City limits. They are responsible for operating and maintaining their system,
including responding to overflows and spills. However, the City’s M & O will respond or
provide assistance for sewage overflow within the Leucadia Wastewater District. During
FY 02-03, Leucadia responded to six sewage overflows in Carlsbad. Response details
are found in appendix 8-5.
Other Spills
The City’s Emergency Services (Fire/Police Departments) responds to reports of
hazardous materials spills and discharges in Carlsbad. Fire Department personnel are
trained in hazardous material emergency response and identification of hazardous
materials and are relied on to assume command during hazardous materials incidents.
Emergency Services may request assistance from the Street Division to contain an area
to protect life, property, and City rights-of-way and control traffic and secondary
perimeter boundaries as directed by the Police Department.
If Emergency Services is first on the scene of an unidentified spill, the Supervisor/Scene
commander decides whether to provide emergency containment measures or wait until
the emergency response agency has identified the substance. If the Supervisor
suspects the substance to be of an extremely hazardous nature that may endanger staff,
emergency reporting procedures are followed and the area is cleared to protect people.
All Supervisors retain a copy of the Department of Transportations “Emergency
Response Guidebook” which lists classifications of hazardous materials and
recommendations for handling materials.
The San Diego County DEH Hazardous Incident Response Team (HIRT), through a
Joint Powers Agreement, handles any significant spills of a hazardous nature. The
County maintains these records, as does the State of California Office of Emergency
Services in Sacramento. During FY 02-03, there were twelve other spills in Carlsbad
that were reported to the Office of Emergency Services (see appendix 8-6). In
summary, four of these involved fluid leaks from vehicle accidents, three were the result
of illegal chemical disposal, three were from an unknown cause, one was an accidental
release and another was a result of equipment failure.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 67
Minor petroleum or other small spills on City streets are handled by the Street Division
using absorbents, sweeping, and proper waste disposal. These cleanup requests are
documented in the City’s RFA system and summarized under “Litter/Debris – Cleanup
Request” in appendix 8 - 2.
Inspection and Preventive Maintenance
During FY 02-03, the City performed routine preventative maintenance and inspections
of the sanitary sewer system, which included video inspections, access hole inspections,
semi-annual inspections of three major trunk lines, and routine cleaning of sewer mains.
The City performed approximately 1,500 access hole inspections. Regular monitoring of
the sewer system was achieved with routine cleaning and manhole inspections. Sewer
system surveillance was conducted on a regular basis. Flow monitoring was done to
compare the flows in dry and wet seasons. Anything unusual was reported and followed
up on.
Approximately 100 miles of sewer lines were cleaned last year. The following table
details the locations of annual, semi-annual and quarterly cleaning. This schedule is
designed to provide more frequent cleaning for identified trouble areas, with siphons
being cleaned annually, low flow and flat lines cleaned semi-annually, and grease
problem areas cleaned quarterly.
Quarterly Cleaning
Location Footage
Ocean / Pine / Oak / CVD / 10745'
Christensen / Beech
Villa Loma 1971'
Total 12716'
12716 x 4 = 50864 / 5280 = 9.6 miles
Semi-Annually
Location Footage
Ralph's 1238'
Aviara Pkwy / Manzinita 6068'
Cove Siphon 350'
Grand Ave. 3555'
Pio Pico / Magnolia 2380'
Valley / Valley Pl. 2285'
Pio Pico/Tamarack/Magnolia 1057'
North County Plaza 1120'
Roosevelt (from Magnolia to 2714'
Grand) Total 20767
20767 x 2 = 41,534 / 5280 = 7.9 miles
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 68
Annually
Location Footage
Chase Apts. 850'
Normandy Ln. 316'
Hoehn Motors 45'
Tanglewood Complex 9121'
Terramar Neighborhood 4960'
Total 16412'
16412 / 5280 = 3.1 miles
*Criteria for priority areas are "Flat lines, Low flow, Grease and Roots" if any one or
more of these criteria are met we will investigate the area to determine the frequency
of cleaning.
Minimum velocity of 2 F.P.S. shall be maintained
Minimum slopes: 8" min…0.40%, 10"min…0.28%, 12"min…0.21%
The City operates and maintains 18 sewer pump stations. The following preventive
maintenance activities were conducted during this reporting period.
From Monday through Friday, all sewer pump stations were inspected daily. The ten
largest pump stations were also inspected daily on Saturdays and Sundays. The
operator inspected the electrical systems quarterly, and the pumps and shafts were
serviced annually. In addition, outside services were contracted to inspect the electrical
services annually. The wet wells were cleaned as needed.
Eleven pump stations are equipped with telemetry, which was checked daily. This
included checking the 24-hour history records, pump gallons per minute, wet well on-off
cycles and pump alternating cycles.
The City conducted most pump repair work, although any needed machine work was
performed by outside services. In the case of emergencies, the City has a 24-hour duty
person, and cell phones are issued to the Duty person, Lead Worker and Supervisor. In
the case of power failures, ten of the stations have onsite generators and four stations
can be powered by the City’s two trailer mounted generators.
Complaint Response
City M & O personnel also responded to 89 sewer stoppage incidents, 2 sewer leaks,
and 20 sewer repair requests. These requests and the City’s response are tracked
electronically in the RFA system. This information is included in the table in Appendix 8
- 2.
8.7 Self-Assessment
Program Strengths
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 69
The City is committed to responding in a timely manner to illegal discharge reports,
complaints and other requests for action, which is evidenced by the City’s continued
implementation of the SuiteResponse RFA system (about 90% of City uses this system).
All reports and requests are documented in the City’s RFA system, which notifies
employees of the need to investigate or follow-up on existing issues until they are
resolved. In addition, it serves as a database and can be used to search on previous
issues by address, complaint type, or other criteria, and various reports can be
generated from this database.
The Storm Water Protection Program depends on other City departments to assist with
investigations and remediation during IC/ID. The City’s Streets Department and M & O
Department are key to prompt, effective responses to clean ups and source control.
Regular meetings and discussions about compliance issues and consistent contacts
facilitate this coordination with departmental representatives.
The City has a Performance Measurement System in place that monitors annual sewage
overflow spills and responses, and assesses whether preventive maintenance or other
improvements can be made to reduce spills to the environment.
Program Improvement Areas
Toward the end of FY 02-03, the Storm Water Protection Program initiated a goal of
responding to “happening right now” complaints within 30 minutes. While this goal was
consistently met during the year, it was not being tracked electronically. Data entry
procedures into RFA will be improved during FY 03-04 in order to better track response
times and to track and report the types of complaints and resolutions.
Managing information from compliant investigations proved to be a major undertaking
during FY 02-03. Although the RFA system has been used to generally help the
program with tracking, it is difficult to adapt to the changing needs of the storm water
program. Currently the storm water program uses five computer applications to track
and search for information about businesses or residents with possible IC/ID’s. A
dedicated storm water database that can communicate with this database would help
the program function more efficiently and effectively.
In FY 02-03, some Coastal Outfall Monitoring program investigations were not
conducted, because there were repeated delays in getting timely sample results from the
contracted lab, even with repeated requests for improved communication and turn-
around time. There were several incidents in which the commercial laboratory did not
provide results until 3 or 4 weeks after the samples were taken, which prevented the
contractor or City from performing timely investigations. The City will bring the Coastal
Monitoring Program in-house and use the Encina Wastewater Authority laboratory in
order to be more cost effective, decrease the turn-around time for laboratory results, and
provide timely upstream investigations with in-house employees.
The City plans to increase the advertising of the storm water hotline, in order to make
the public more aware and educate them on reporting illegal discharges.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 70
Section 9
Outreach and Education
9.0 Overview
Public awareness and education are integral to the success of any Urban Runoff
Management Plan. The City of Carlsbad works to increase public awareness about
storm water pollution prevention and to provide education that promotes behavioral
changes and environmental stewardship.
Carlsbad’s Storm Water Protection Program collaborated locally and regionally to ensure
outreach efforts and messages for storm water pollution prevention were consistent,
though these messages often took varied forms. The City was actively involved in
outreach and education at the local level, the watershed level (North County Storm
Water Program), and the regional level (Project Clean Water – Outreach Workgroup).
These efforts are summarized in appendix 9-1 and are further discussed in the following
subsections by target audience.
9.1 Municipal Departments and Personnel
Storm water training for City employees included general training for all employees and
job specific training for designated departments and personnel. The objectives of the
City employee training program 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; and
• Integrate employee feedback into training and BMP implementation.
General Employee Training
During this reporting period, all City employees received general storm water training.
General issues typically addressed the causes of storm water pollution, how it affects the
environment, and the overall structure of the storm water program. Messages related to
general training may include, where applicable, the topics listed in permit section F.4.a.
General storm water training for all employees was delivered through various media and
methods. During FY 02-03, City staff received information about storm water protection
through various communication methods, including the following:
1. Storm Water Webpage: Employees were able to download BMPs directly from
the City’s website.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 71
2. Intranet: The City’s intranet was used to post messages and inform employees
of various events and opportunities for participation, such as the Coastal Cleanup
Day and Earth Day activities.
3. Citywide E-mail: City employees who have access to e-mail were sent storm
water and BMP information on at least a quarterly basis (over 600 employees).
These e-mails included information about pollution and its impact on the
environment, in addition to listing the storm water hotline and email address.
4. Council Updates: Updates on the implementation of the NPDES permit were
given to City council in April and May 2003.
5. Public Works Newsletters: The Spring 2003 edition of this departmental
newsletter featured an article on storm water protection. Employees were
notified by e-mail when this newsletter is published and posted on the City’s
intranet.
6. Community Update Video: The Community Update is a 30-minute video that is
shown quarterly on the local cable access channel (Cable channel 3). A
community update video featuring the storm water program aired repeatedly
during the first quarter of FY 02-03 and was made available on video tape to
department heads for additional storm water training. It featured an 8-minute
segment on the importance of storm water protection, best management
practices, as well as contact information for the Program.
7. Workshops: All new employees are invited to attend a one-day orientation
workshop entitled Experience Carlsbad. At this workshop, employees were
given a Power Point presentation introducing them to the Storm Water Protection
Program.
8. Printed material: All residential and commercial brochures developed by the
Storm Water Protection Program are available for employees at various City
buildings, through the internet, and directly from the City’s Storm Water
Protection Program.
9. Paycheck stuffers: A two-sided flier entitled “Storm Water Protection…It’s Our
Business!” was created and distributed to all 1,150 employees as a paycheck
stuffer during this reporting period (appendix 9-2). This flyer discussed the
importance of storm water pollution prevention, BMPs, the duties of the Storm
Water Protection Program, how to report illegal discharges, and other highlights
of the City’s efforts to implement the NPDES permit. This flier was also placed in
employee benefits packages that all new employees received during orientation
with Human Resources.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 72
10. Promotional Items: Items such as notepads, key chains and pens with the storm
water hotline and other pollution prevention messages were distributed to
employees.
Job Specific Training
Job positions have been identified within departments that work in and around municipal
facilities and require activity or job specific training. This includes a wide variety of
positions, from development to construction to maintenance and enforcement. Table 9.1
identifies the departments with personnel that require job specific training.
Table 9.1. Department and Positions for Job Specific Storm Water Training
MSA Dept. Positions
PW Engineering, Construction Inspections Construction Inspectors
PW Engineering, Engineering
Development Services
Associate Engineer, Assistant
Engineer
PW Environmental Programs, Storm
Water
Environmental Specialists
PW General Services, Facilities
Maintenance
Building Maintenance Workers
PW General Services, Parks Maintenance Workers
PW General Services, Landscape
Maintenance
Maintenance Workers
PW General Services, Vehicle
Maintenance
Equipment Technicians, Equipment
Service Worker, Shop Assistant
PW Maintenance and Operations, Utility
Operations
Meter Services Workers;
Sanitation System Operators;
Water System Operators
PW Maintenance and Operations,
Construction/Maintenance
Utility Workers;
Maintenance Workers
Com-
Dev
Planning, Building, Code Enforcement Building Inspectors, Code
Enforcement, Planners (Devpt. Serv.)
Safety Fire Department Fire Fighters
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 73
Implementing and educating municipal employees on storm water BMPs and pollution
prevention is an on-going and evolving process. BMPs may change due to the iterative
process of selection, implementation and assessment. If a BMP is found to be
ineffective, a new or additional BMP is selected for implementation. Because the field of
storm water pollution prevention is new and expanding, the technology is changing
rapidly and new products are continually being introduced. In addition, the Regional
Board is actively implementing and revising new regulations and permits, such as the
General Permits (Construction; Industrial; Potable Water Discharges and Hydrostatic
Testing; Small Linear Underground/Overhead Construction Projects; etc.).
A Supervisor’s Committee, modeled after the Safety Committee, will be established to
develop a calendar of storm water training activities for staff, and to coordinate
compliance activities and documentation. When appropriate, storm water training
activities may follow safety training sessions, therefore minimizing the need for separate
meetings and duplication of training documentation. The Supervisor’s Committee will be
in full operation in FY 03-04.
Training Topics
Supervisors and Managers assess the training needs of their staff, and ensure that
applicable job positions receive the necessary training to comply with the Municipal
NPDES Permit and the City’s JURMP. In accordance with the JURMP, employees were
trained based on the type of storm water quality and pollution issues that may be
encountered during the performance of their duties. Employees were trained on the
requirements of the storm water management program as detailed in the appropriate
JURMP section, their facility Storm Water Pollution Prevention Plan (SWPPP), and
permit requirements and regulations. Training occurred through various media,
including informal staff presentations, distribution of flyers, fact sheets, brochures and
promotional items, and during formal on and off-site training. In addition to the storm
water training topics listed above for general employees, the Municipal NPDES permit
section F.4.b. lists topics that targeted municipal staff should be educated on where
applicable. The table in appendix 9-3 summarizes the employee training during FY 02-
03.
City employees will continue to receive training on general storm water issues, best
management practices and watershed awareness. Identified employees (by job title)
needing job or activity specific training will continue to be trained on their specific
JURMP component, applicable permits and BMPs identified in the JURMP for their
facility or activity.
9.2 Construction Site Owners and Developers
The City conducted two workshops to educate project applicants, developers,
contractors, and property owners on the implementation of the Carlsbad storm water
program, water quality requirements, development standards, and new expectations for
construction projects. On May 16, 2003, the City hosted a seminar in conjunction with
the County of San Diego and the North County Civil Engineers and Land Surveyors
Association. The workshops covered SUSMP and Construction Inspections and NPDES
Best Management Practices for Construction Sites. A copy of the sign-in list is in
appendix 9-4.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 74
Appendix 6-1 contains an outline of the information presented at the workshop by the
City of Carlsbad. The following table summarizes the workshop and number of
participants.
Table 9.2. Summary of construction site and development workshops.
DATE #
attending
TRAINING
TYPE NAME OF TRAINING or TOPICS Location Presenter
05/16/2003 62 Workshop SUSMP & Construction Inspection Faraday Cid Tesoro,
County San
Diego
05/16/2003 66 Workshop NPDES BMPs for Construction Sites Faraday Hammann, City
of Carlsbad
In addition to the formal workshops the City hosted, employees in construction and
development services provided information and education to applicants and developers
during one-on-one or small group meetings, inspections, complaint investigations, and
during pre-construction meetings.
The City provided sample SWPPPs and SWMPs for engineers, developers and
applicants to use as a guide when preparing documents for proposed development
projects. Copies of theses documents and the SUSMP are available at the City’s
permits counter. The SUSMP is also available through the City’s internet site.
9.3 Commercial and Industrial Owners and Operators
The City continued to educate commercial and industrial owners and operators through
various methods. This included the development of printed materials, participation at
workshops, presentations to business community groups, direct mailings, and
inspections and site visits. Accomplishments are detailed below.
Printed Materials
The City developed several new commercial and industrial brochures and fact sheets
during FY 02-03. These materials were distributed by direct mail, during inspections and
complaint investigations, and were available at public events and presentations. These
materials are described further in report sections 3, 4 and 5. These brochures are also
available on the City’s storm water web page (www.ci.carlsbad.ca.us/cserv/storm.html).
The City developed a general storm water brochure entitled “Best Management
Practices for Businesses – Commercial and Industrial” (see subsection 3.3 and appendix
3-6). This brochure was distributed to all active industrial facilities during inspections
and by direct mail to industries that the City verified as active in the current inventory.
In addition to the previously developed Restaurant (English and Spanish), Automotive,
and Lawn and Garden brochures, the City developed the following new printed materials
(found in the corresponding appendices):
• Concrete and Mortar projects (appendix 4-11)
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 75
• Lawn and Garden Care – translated to Spanish (appendix 5-1)
• BMPs for Automotive Service and Repair – translated to Spanish (appendix 4-
5)
• BMPs for Power Washing (appendix 4-10)
• BMPs for Swimming Pool, Fountains and Spas (appendix 4-12)
• Fats, Oils and Grease fact sheet (appendix 4-8)
• Trash fact sheet (appendix 4-12)
The City continued to actively participate in the North County Storm Water Program
(NCSWP), which is a collaboration of the Carlsbad Watershed copermittees (Oceanside,
Carlsbad, Encinitas, Vista, Escondido, San Marcos, Solana Beach and the County of
San Diego). Through this group, the City helped develop BMP posters for Restaurants
and for Automotive Repair Facilities (see appendices 4-6 and 4-7). These posters were
distributed to local Carlsbad restaurants and automotive facilities.
The City also continued to actively participate in the Project Cleanwater Outreach
Workgroup. Products from this group included the BMP booklet “What’s Cookin”, which
was distributed to Carlsbad eating and drinking establishments, and the BMP booklet
“The Green Wrench Guide”, which was distributed to automotive facilities.
Website and hotline
The Storm Water Hotline was listed on all printed material. Industries can call the hotline
to request BMP information. All City brochures were also available through the City
website. During FY 02-03, there were 2,906 visits to the storm water web page.
Inspections and Site Visits
Facility inspections and site visits provided excellent educational opportunities with local
business owners and managers. City Storm Water inspectors work with businesses
during inspections and complaint investigations to identify storm water compliance
issues, detail corrective actions, and assess the appropriateness of BMPs. This
included one-on-one interaction as well as providing them with inspection reports and
printed materials detailing BMP options.
Community Groups
An article on storm water pollution prevention was published in the August 2002 edition
of the Carlsbad Business Journal (see appendix 3-7), which has a circulation of
approximately 3,000 readers.
A presentation was made to the Carlsbad Chamber of Commerce Business Environment
Committee on November 7, 2002. This PowerPoint presentation explained the City’s
storm water program, including inspections of industries and required BMPs.
Workshops and outreach events
The City of Carlsbad Storm Water Protection Program was actively involved in the four
regional workshops held during FY 02-03. The following table summarizes the
workshops attended by the City during this reporting period.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 76
Table 9.3. Outreach events for Businesses
Event Date Location Attendance Materials & topics
Automobile
Industry
Workshop
8/8/03
Escondido 44 Auto Industry Brochures,
Posters
PowerPoint presentation
Landscape &
Agriculture
Industry
Workshop
10/17/02 Carlsbad 20 Lawn & Garden Care
brochure
PowerPoint presentation
Mobile Trade
Workshop
2/26/03 Oceanside 29 Power washing brochure
PowerPoint presentation
Green Day at
the Four
Seasons
4/22/03 Carlsbad 200 Enviroscape model
Lawn & Garden Care, Car
Washing, Pet Waste,
Motor Oil brochures
“Only Rain…” brochure
Restaurant
Workshop
5/22/03 Escondido 22 Restaurant brochure &
poster
Prior to each of the four regional workshops, the City of Carlsbad mailed an invitation
along with the appropriate BMP brochures to all applicable businesses in the inventory.
Survey
Surveys help the City understand how the public perceives stormwater management and
can help foster better planning and management programs. During this reporting period,
a storm water awareness survey was conducted to assess how commercial and
industrial businesses have incorporated BMPs after the advisory inspection. The
questions and results are detailed in Appendix 10-1. The City will use the information
from these surveys to incorporate the public's needs and desires into the overall goals of
the Storm Water Protection Program.
9.4 Residential Community, General Public, and School Children
Carlsbad continued its on-going outreach to the residential community, school children,
and the general public during FY 02-03. This included the development and distribution
of printed materials, public outreach events, presentations, published articles and press
releases, a video, website access, and direct interaction with the public. These
accomplishments are described below.
Printed Material
The City developed various BMP booklets for high priority residential activities. During
FY 02-03, the City translated the “Lawn & Garden Care” brochure into Spanish, and
created additional fact sheets and brochures. Some of these new materials are
applicable to commercial operations, but also to residents who conduct home
improvement projects. These materials provided information on how to prevent storm
water pollution for the following activities:
• Home improvement projects (appendix 5-2)
• Concrete and Mortar work (appendix 4-11)
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 77
• Power washing and surface cleaning (appendix 4-10)
• Solid waste disposal and trash issues (appendix 4-9)
• Private storm drain cleaning (appendix 5-3)
• Pollutants were found in your neighborhood storm drain - door hanger (appendix
5-7)
Staff continued to distribute the brochures created during the previous fiscal year
addressing pet waste, residential car washing, motor oil, and lawn and garden care to
residents through various methods, which are discussed below.
The City also continued to work with the North County Storm Water Program and
developed a general BMP brochure for residents (appendix 5-4). In addition, this group
worked with the Solana Center for Environmental Innovation to distribute a colorful
poster with the message “Storm Drains Lead Straight To the Ocean”. This poster also
advertised the 1-800-CLEANUP hotline number.
Direct Mailings
The City purchased a brochure from Water Environment Federation entitled “Fat-Free
Sewers”, and distributed it to all City sewer customers as a bill stuffer. This brochure
explained how to prevent fats, oils and greases from damaging homes and the
environment by preventing sewer blockages and spills. The City’s Maintenance and
Operations phone number along with the City’s Storm Water Hotline number were
included on the back of each brochure. This was sent to approximately 20,000
customers in Carlsbad in January 2003.
The Carlsbad Community Services Guide is mailed four times a year to all Carlsbad
households (approx. 38,000). The Winter edition of the guide contained an article
written by City staff on storm water protection (see appendix 5-5).
The Storm Water Protection Program also included information on storm water pollution
prevention and Best Management Practices in the City’s Annual Drinking Water Quality
Report, which was mailed to all water customers (approximately 24,500). This report
was sent out in June 2003 and a portion is found in appendix 5-6.
Website and Hotline
Most of the printed materials are available for download from the City’s website. In
addition, residents can call the Storm Water Hotline to request copies of these materials.
There were 2,906 hits to the storm water web page during FY 02-03.
Presentations
The City’s Storm Water Protection Program purchased an EnviroScape watershed
model. This interactive, three-dimensional landscape illustrates residential, recreational,
agricultural, industrial and transportation areas -- all representing possible sources of
water pollution. Children and adults learn how pollutants can flow through a typical
community. Household items such as drink mix (fertilizers and pesticides), candy
sprinkles (trash and pet waste), soy sauce (motor oil), non-dairy creamer (paint and
sludge), cocoa (sediments), and parsley flakes (lawn clippings) are used to demonstrate
how daily activities can affect water quality. While EnviroScape emphasizes the sources
of pollution, a second demonstration shows how to prevent pollution. City staff used this
educational tool at various public events.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 78
City employee E. Lukey giving an EnviroScape presentation to
school children at the Public Works Fair.
The Public Works Fair is an annual City event held during May. Local elementary
schools (Kindergarten through 5th grade) were invited to come and learn about Public
Works operations first hand by viewing demonstrations of heavy equipment, street lights,
park maintenance, fire trucks, and police cars. The Storm Water Protection Program
staff gave demonstrations using the EnviroScape model and provided printed materials.
Approximately 500 school children and adults attended the fair on May 21, 2003. The
children also received a comic book produced by the American Public Works
Association called “P.W. Paws in Public Works Works for Me!” This provided a message
(revised by the City) that the water that goes into storm drains flows directly to our
creeks, lagoons and ocean without treatment (appendix 9-5).
Twice a year, the City hosts an event called “Citizen’s Academy”. This seven-week
course (one night per week) educated residents about Carlsbad City government and
the public services. A PowerPoint presentation, which included an overview of the
Storm Water Protection Program, related permit and regulations, program activities, and
residential BMPs, was presented to the group. In addition, storm water outreach
materials were available to the participants and the Enviroscape watershed model was
demonstrated. Approximately 100 residents attended the two Academy’s held on
September 26, 2002 and February 20, 2003. This has been a highly successful and
popular event, which has a waiting list for new participants.
Public Events
The City hosted or participated in several public events, which provided opportunities for
residents, school children, and the general public to learn about storm water pollution
prevention. Table 9.4 provides a summary of these events. During most of these
events, a manned booth is set up and residents and kids have the opportunity to pick up
printed materials, view an Enviroscape model demonstration, and speak directly with
City storm water representatives.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 79
Table 9.4. Outreach events for Residents, General Public, and School children
Event Date Type Audience & # Location
Buena Vista Creek
Cleanup Day
9/21/02
Manned table,
printed materials
General public,
40
Oceanside
Carlsbad
Citizen’s Academy 09/26/03 PowerPoint,
Enviroscape
model
Residents, 50 Carlsbad
Presentation for
Homeowner’s
Assoc.
11/14/02 Presentation and
printed materials
Residents, 50 Carlsbad
Citizen’s Academy 2/20/03 PowerPoint,
Enviroscape
model
Residents, 50 Carlsbad
Children’s Day at
the Flower Fields
3/29/03
3/30/03
Booth,
Enviroscape
model, brochures
School children,
residents. 200+
Carlsbad
Public Works Fair 5/21/03
Booth,
Enviroscape
model, Brochures
School children,
residents, 500
Carlsbad
Earth Day at
Balboa Park
4/27/03 Booth,
Enviroscape
model, materials
General public,
600+
San Diego
The Earth Day at Balboa Park was a joint participation by the NCSWP, and the City of
Carlsbad during FY 02-03. Approximately 60,000 people from across the region attend
this Earth Day event held annually at Balboa Park in San Diego.
City of Carlsbad interns H. Thompson and M. Barbee (center, right)
staffing the Earth Day booth with another NCSWP representative.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 80
Community Update Video
The growing medium of cable television was used to provide the public with information
about the storm water protection program. The Community Update is a 30-minute video
segment aired quarterly on the local cable access channel. This 8-minute segment
introduced residents to the Program, the importance of storm water protection, best
management practices and how they can be used for everyday activities, as well as
contact information for the Program.
Direct Interactions
Residents were educated about pollution prevention and storm water BMPs during
complaint investigations. The inspector will meet with the resident, explain the
regulation and pollution problem, along with how to correct the situation. When a
resident was not home or available, a door hanger and other outreach materials were
left to provide additional information and a description of the reported discharge.
Typically, follow-up informational letters were sent to homeowners after an investigation.
These correspondences included brochures and fact sheets about storm water and
BMPs. Additional information on complaint investigations is given in 5.3.
Prompts and Promotional items
Promotional pens were created jointly with the North County Storm Water Program
(NCSWP) promoting 1-800-CLEANUP, and contained the following pollution prevention
messages each time the pen was clicked: “Pickup litter, Cigarette Butts”; “Recycle
Motor Oil and Filters”; “Eliminate Water Runoff”; “Pickup Pet Waste”; “Sweep
Sidewalks”; “Reduce Pesticide Use”. Other items that displayed the City’s storm water
logo, message and hotline number include a raindrop “stress ball”, raindrop notepads ,
and key chains. These were distributed at public events and group presentations.
Toward the end of FY 02-03, the City created additional materials that will be distributed
in 03-04 and detailed in the next annual report.
Classroom Education
During FY 02-03, the City contracted the Resource Conservation District of Greater San
Diego County (RCD) to conduct the “Classroom Watershed Program” for second and
sixth grade classrooms in Carlsbad. The program used the EnviroScape interactive
model, to teach students about watershed stewardship through pollution prevention.
Outreach materials and workbooks were provided to the students that included best
management practices for reducing water pollution. Sixth grade classes received a pre
and post demonstration test to measure changes in knowledge.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 81
Scott Phillips of RCD giving classroom presentation with EnviroScape.
The following table lists all of the schools and the number of classrooms and students
that were given the watershed classroom presentation during FY 02-03.
Table 9.5. Carlsbad Elem. Schools receiving the 2003 Watershed Awareness Program
Date Elementary
School
# 6th grade
classes
# 2nd grade
classes
# of
teachers
# of students
4/22/03 Magnolia 3 1 104
5/5/03 Kelly 3 3 60
5/12/03 Aviara Oaks 4 4 80
5/13/03 Aviara Oaks 4 4 80
5/15/03 Hope 4 4 76
5/23/03 Jefferson 3 3 60
5/30/03 Buena Vista 3 3 60
Total 3 21 22 520
Communities Alive in Nature
Communities Alive in Nature (CAN) is an education program that applies watershed
stewardship concepts through field studies and restoration projects in the environment.
Incorporating elements of the State of California curriculum requirements for language
arts, math, science and technology, CAN primarily focuses on educating elementary and
high school students. The program teaches students about the myriad of factors
contributing to the health of a watershed while giving students an opportunity to conduct
field tests, including bioassessment, physical and chemical parameters, visual
degradation, and correlating land use to constituents of concern. High school students
were educated about watershed health through a combination of classroom
presentations and field visits. In turn, they taught elementary school students what they
had learned. During FY 02-03, 630 elementary school students from the Carlsbad
Unified School District completed this program and performed field studies and
restoration work at the Calavera Nature Preserve in Carlsbad. City of Carlsbad Senior
Planner, Eric Munoz, made four presentations during 2003 as part of the CAN program.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 82
Presentations included information on watershed dynamics and land use planning efforts
that resulted in the establishment of nature preserves.
Watershed Stewards Training
The Watershed Stewards Program was designed and sponsored by the Agua Hedionda
Lagoon Foundation and the U.C. Natural Reserve System to train community stewards
to conduct public outreach, monitoring and restoration activities for the protection of the
natural resources (appendix 9-6). This program was jointly funded through a US EPA
Watershed Grant and a City of Carlsbad Community Activities Grant ($25,000 for CAG).
This program primarily focused on stewardship efforts in the Agua Hedionda Watershed,
one of four watersheds that run through Carlsbad. Two training sessions were held
during FY 02-03 with approximately 24 participants. The early sessions were aimed at
high school students, while later sessions were for adults.
Calavera School Presentations and Preserve Walks
The City gave a presentation and conducted a nature walk with Calavera School during
the Spring of 2003. Senior Planner Eric Munoz gave a presentation on “Coastal Issues
of Common Concern”, addressing topics such as watershed planning and bioinvasions.
Approximately 60 students participated.
9.5 Quasi-Government Agencies/Districts (i.e. educational institutions,
water districts, sanitation districts, etc.).
Quasi-government agencies and districts within the City typically fall under one of the
existing commercial or industrial classification categories of high, medium, or low priority,
based on the criteria used to identify facilities and “businesses”. Outreach and
education for these facilities is identified during the advisory inspection.
During FY 02-03, the City inspected 36 water and sanitation facilities as part of the
industrial inspection program. Educational information was provided during the
inspection, as well as in any written reports of needed corrective actions. Most of the
water and sewer districts and educational institutions were covered or will be covered
under general storm water permits issued by the Regional Water Quality Control Board.
Therefore, many of these facilities already have knowledge of the storm water
requirements and participate in education activities. The City works closely with the
Encina Wastewater Authority, who also participates in the North County Storm Water
Program.
9.6 Self-Assessment
Program Strengths
Carlsbad’s Storm Water Protection Program collaborated locally and regionally to ensure
outreach efforts and messages for storm water pollution prevention were consistent.
The messages were delivered by various means including presentations, workshops,
inspections, investigations, and outreach events, in addition to use of direct mail, the
website and local access Cable television. The City was actively involved in outreach
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 83
and education at the local level, the watershed level (North County Storm Water
Program), and the regional level (Project Clean Water – Outreach Workgroup).
During FY 02-03, the City developed eleven new brochures and fact sheets. In addition,
the City collaborated with the NCSWP to develop three new posters, a brochure, a door
hanger, and pens. The City also uses promotional items such as pens, key chains,
raindrop sticky notes, and raindrop “stress ball” as additional outreach tools. These
small items can send a storm water message and the hotline number to a wide variety of
audiences and are less likely to be thrown away if they serve a functional purpose. All of
these items were well received by the public.
Program Improvement Areas
While the City has collaborated well with the NCSWP and the regional outreach groups,
additional collaboration with local non-government organizations and stakeholder groups
would be beneficial for outreach and education. The City expects to work more closely
in FY 03-04 with groups like the Agua Hedionda Lagoon Foundation, The Environmental
Trust, the Batiquitos Lagoon Foundation, and others who are part of the Carlsbad
Watershed Network.
The City also plans to create a unified City Environmental Programs message combining
storm water, water conservation and HHW/recycling information. This message will help
foster a better understand of the relationship between everyday activities such as lawn
and garden care, pool maintenance, car repair, recycling, and the sources of pollution in
our waterways.
During FY 03-04, the City will conduct its annual (telephone) Public Opinion Survey and
include questions on storm water pollution prevention. The results from this survey,
along with the results from the Watershed Public Awareness Survey, will provide
important information on the public’s awareness and knowledge of storm water pollution
prevention issues and activities. This information can help focus future education and
outreach messages and events.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 84
Section 10
Public Participation Component
10.0 Overview
Public participation is crucial to ensuring the effectiveness of the City’s Storm Water
Protection Program. Public participation allows the residents, interested parties, and
stakeholders interests to be expressed and a variety of creative solutions to be
considered before final decisions are made.
The City of Carlsbad led and contributed to several public participation opportunities this
reporting period including the development, implementation, and review of storm water
management programs, best management practices, and other JURMP and storm water
related issues. The goal has been to ensure that the Carlsbad community has a vested
interest in solving storm water management problems and has a general knowledge and
understanding of watershed protection. Citizens, business owners and representatives,
and other interested parties were invited to attend the public meetings, outreach events,
workshops, City Council meetings, and other events during this reporting year.
10.1 Public Meetings and Hearings
The public had several opportunities to attend meetings with the City, at the watershed
and regional levels, to learn about the City’s implementation of the NPDES permit and
have their concerns addresses. Table 10.1 contains a list of some of the public
meetings and dates held during this reporting period.
The Carlsbad City Council meets on the first four Tuesdays of every month at 6:00 p.m.
These meetings are held in the Council Chambers at Carlsbad City Hall, 1200 Carlsbad
Village Drive, and are open to the public. The Council Meetings are also televised live on
Tuesday night, on Cablevision Channel 3 and replayed that Wednesday at 2 pm.
Videotaped copies of the council meetings are available at the Carlsbad library.
City Council Agendas are prepared by the City Clerk's Department and are available on
the Friday prior to the City Council Meeting. Agendas are available at the meeting,
posted outside Council Chambers, or the public can pick up a copy from the Clerk's
Department. A subscription service is also available for interested parties to receive the
agenda each week in the mail, at the cost of $50.00 per year. Copies of the current
agenda and public hearing notices are available on the City’s web site at
www.ci.carlsbad.ca.us. Council Agenda Packets are available for review at the City
Clerk's Department and at the Carlsbad Library on the Friday prior to the City Council
Meeting. City Council Minutes are prepared by the City Clerk's Department and are the
permanent record of proceedings of each City Council Meeting.
The public can also attend the Copermittee Management Committee Meetings and other
Copermittee meetings. Notices of these meetings are available from the Project
Cleanwater website at www.projectcleanwater.org. Carlsbad representatives continue to
be actively involved in several of the Project Cleanwater Technical workgroups and
Technical Advisory Committees (TACs), including the Monitoring Workgroup,
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 85
Assessment Workgroup, Data and Information Management Workgroup, Outreach
Workgroup, and Legislative and Regulatory issues TAC.
For the past two years, Carlsbad has been actively involved with the North County Storm
Water Program (NCSWP), which is a collaboration of the Carlsbad Watershed
Copermittee education coordinators. The NCSWP organizes and participates in local
public events and collaborates with other environmental agencies and groups to develop
and distribute educational materials. This group also serves as a forum for stakeholder
and outside environmental organizations to participate in the development of education
programs for the Carlsbad Watershed. The NCSWP typically meets monthly at the City
of Encinitas.
The Carlsbad Watershed Network (CWN) is a group of nonprofit foundations,
conservancies, and public agencies within the Carlsbad Hydrologic Unit. CWN
promotes the well being of the Carlsbad Watershed by providing a forum for discussion,
mutual support of member activities, educational programs, and a vehicle to influence
actions of all parties in the watershed. This group typically meets on the second
Tuesday of each month from 9:00 am – 11:00 am at the City of Carlsbad Faraday
building.
Table 10.1. Public Meetings held during the reporting period
City Council Municipal Stormwater Copermittee Watershed
Copermittees
Others
Regular Meetings Management
Committee
Outreach
Workgroup
Monitoring
Workgroup
NCSWP CWN
Meeting
7/9/02
7/23/02
8/6/02
8/13/02
9/10/02
9/17/02
9/24/02
10/1/02
10/8/02
10/22/02
11/5/02
11/12/02
11/19/02
12/3/02
12/10/02
12/17/02
1/04/03
1/21/03
2/4/03
2/08/03
2/25/03
3/4/03
3/11/03
3/25/03
4/1/03
4/8/03
4/15/03
4/22/03
5/6/03
5/13/03
5/20/03
5/27/03
6/3/03
6/10/03
6/17/03
6/24/03
7/18/02
9/19/02
11/21/02
1/16/03
2/20/03
3/20/03
5/15/03
8/6/02
10/8/02
12/10/02
3/11/03
5/13/03
6/10/03
7/9/02
8/28/02
10/2/02
11/11/02
1/9/03
4/3/03
7/23/02
8/13/02
9/17/02
10/24/02
11/14/02
12/11/02
1/21/03
2/18/03
3/13/03
4/17/03
5/27/03
6/17/03
7/9/02
8/13/02
9/10/02
10/8/02
11/12/02
12/10/02
1/14/03
2/11/03
3/11/03
4/8/03
5/13/03
6/10/03
10.2 Feedback Mechanisms
In addition to the feedback opportunities available through public meetings and hearings,
there are also a number of additional mechanisms available for the public to provide
feedback.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 86
Hotline and E-mail Address
The public is encouraged to provide input and feedback on the City’s Storm water
program implementation. In addition to the public meeting opportunities detailed above,
the public can call the Storm Water hotline at (760) 602-2799 to request information,
give comments, or make illegal discharge reports. During regular work hours, the Storm
Water Protection Program staff answers this number.
In addition, the public can send e-mails directly to the Storm Water Protection Program
at stormwater@ci.carlsbad.ca.us. There are also several other public contact phone
numbers and City e-mail addresses that the public can use. Other City departments
forward on comments and questions to the Storm Water Protection Program as needed.
The public can access a Storm Water Protection Program web page through the City’s
website at www.ci.carlsbad.ca.us/cserv/storm.html which provides information about the
storm water program and best management practices.
Direct interaction
The City continues to rely on the interactions between City staff and the public to convey
messages about storm water protection and pollution. City staff have received targeted
training to increase their understanding of urban runoff issues. Staff interaction with the
public also provides additional opportunities for the City to obtain a direct feedback about
BMPs, ordinances, and pollution prevention efforts.
Public Surveys
Surveys help the City understand how the public perceives storm water management
and can help foster better planning and management programs. The City of Carlsbad
was involved in three surveys during FY 02-03.
The Social and Behavioral Research Institute at California State University, San Marcos,
on behalf of the City of Carlsbad, annually conducts a Public Opinion Survey of
residents. The survey entails a Random-Digit Dial methodology of over 1,000 Carlsbad
residents to obtain information about attitudes and knowledge of City services, facilities,
and issues, and also includes demographic questions for further analysis and
interpretation. There were no direct storm water related questions during the FY 02-03
survey, however several questions are being drafted for FY 03-04 survey. The results of
the Public Opinion Survey are printed in the Annual State-of-Effectiveness Report
published in January of each year. This report is available for download from the City’s
website. The results from the FY03-04 survey will be included in the next JURMP
Annual Report.
During this reporting period, two storm water specific surveys were conducted. The first
was conducted by the City Storm Water Protection Program and focused on commercial
and industrial business inspections. The questions and results are detailed in Appendix
10-1. The second survey was conducted in collaboration with the NCSWP and was a
Random-Digit-Dial phone survey on storm water and watershed awareness. This survey
included over 600 participants in the Carlsbad Watershed, and was conducted by the
SDSU Social Science Research Institute. The results of this survey will be presented in
next years report.
The City will continue to use the information from these surveys to incorporate the
public's needs and desires into the overall goals of the Storm Water Protection Program.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 87
General Outreach
Efforts through printed ads, press releases, media interviews, and water bill stuffers
continue to keep the public informed of new storm water requirements, updates, and
public participation opportunities.
10.3 Community Events and Volunteer efforts
Volunteer Cleanup Events
During this reporting period, four volunteer events were held in Carlsbad. This included
the Coastal Cleanup Day on September 21, 2002, and a cleanup held on the weekend
following Earth Day in April. Carlsbad partnered with the Cities of Oceanside and Vista
for a Tri-City cleanup effort along Buena Vista Creek and Lagoon. Carlsbad hosted two
sites and over 60 volunteers participated. Approximately 60,000 pounds of trash were
removed from sites along Buena Vista Creek and Lagoon. The City also partnered with
The Environmental Trust for an Earth Day cleanup event held at the Calavera preserve.
The City of Carlsbad participated in 10 community events held in Carlsbad and other
locations across the County. These events are summarized in the following table.
Table 10.2. FY 02-03 Community Events
Date Event Sponsored By: # of Participants
August 8, 2002 Automotive Industry
Workshop
Storm Water Outreach
Workgroup
44
September 21,
2002
Buena Vista Creek
Cleanup
Cities of Carlsbad,
Oceanside & Vista
60
September 21,
2002
Tamarack Beach
cleanup
Surfrider, City of Carlsbad 40
October 17, 2002 Agriculture and
Landscape Industry
Workshop
Storm Water Outreach
Workgroup
20
February 26, 2003 Mobile Trade Industry
Workshop
Storm Water Outreach
Workgroup
29
March 30, 2003 Environmental Day Carlsbad Flower Fields 200+
April 27, 2003 Cleanup at Calavera
Preserve
The Environmental Trust,
City of Carlsbad
80
April 27, 2003 Earth Day in Balboa
Park
San Diego Earth Works 600+
May 21, 2003 Public Works Fair City of Carlsbad 500
May 22, 2003 Eating and Drinking
Establishment
Workshops
Storm Water Outreach
Workgroup
22
Citizen’s Academy
Twice a year, the City hosts an event called “Citizen’s Academy”. This seven-week
course (one night per week) teaches City residents about how the City government
operates and how public services are provided. This provides an excellent opportunity
for citizen participation in City government. An overview of the Storm Water Protection
Program, including permit and regulations, program activities, and residential BMPs was
presented at both academy’s this reporting year. In addition, all printed material was
available at the academy and presentations were given using the EnviroScape
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 88
watershed model. Approximately 100 residents attended the two Academy sessions
held on September 26, 2002 and February 20, 2003. This has been a highly successful
and popular event, which has a waiting list for new participants.
Storm Drain Stenciling
Stenciling storm drain inlets with painted (“No Dumping – Drains to Ocean”) messages
reminds citizens and businesses not to pollute waterways. Stencils are available upon
request to businesses and residents who are interested in stenciling private storm drains.
10.4 Other Public Participation Opportunities
Internship Program: The City recruited two students from the University of California,
San Diego to participate in the new internship program. Interns worked on a variety of
activities including commercial and industrial inspections, data management, and
outreach and education. Interns wrote a Senior Thesis as part of their internship. Hallie
Thompson presented her Thesis based on her work with the Storm Water Protection
Program at the Second Annual Clean Water Summit held in San Diego on June 20,
2003.
10.5 Self-Assessment
Program Strengths
The City actively seeks ways to provide two-way communication with the public. This is
shown by some of the current City programs, such as the popular “Citizen’s Academy”
and the annual “State-of-Effectiveness Report” which includes a Citywide public opinion
survey of at least 1,000 residents. The City has internal teams dedicated to finding the
most effective ways of communicating with the public and providing opportunities for the
public to become more involved.
Program Improvement Areas
The City would like to have more volunteer involvement and opportunities for the public.
To accomplish this, the City plans to hire a Community Volunteer Coordinator during FY
03-04 to guide and direct the City’s volunteer and community support programs. The
new volunteer coordinator is expected to work with the storm water program to assess
opportunities for the public to become more involved in pollution prevention efforts with
the City.
More advertising of the storm water program could help increase the public participation
in pollution prevention efforts. Print media and promotional items (i.e., key chains,
pencils, and etc) are the most cost-effective and widespread way to advertise the
program.
Surveys help the City understand how the public perceives storm water management
and can help foster better planning and management programs. The Social and
Behavioral Research Institute at California State University, San Marcos, on behalf of the
City of Carlsbad, annually conducts a Public Opinion Survey of residents. There were no
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 89
direct storm water related questions during the FY 02-03 survey, however several
questions are being drafted for FY 03-04 survey.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 90
Section 11
Assessment of JURMP Effectiveness
11.0 Overview
The Permit requires each copermittee to develop a long-term strategy for assessing the
effectiveness of its individual JURMP. The permit language states:
“The long-term assessment strategy shall identify specific direct and indirect measures
that each Copermittee will use to track the long-term progress of its individual JURMP
towards achieving improvements in receiving water quality. Methods used for assessing
effectiveness shall include the following or their equivalent: surveys, pollutant loading
estimations, and receiving water quality monitoring. The long-term strategy shall also
discuss the role of monitoring in substantiating or refining the assessment”.
City staff participated, with the Copermittees, in a regional effort to draft common
elements for assessment. During FY 02-03, Carlsbad participated in a copermittee
workgroup to address comments by the Regional Board that this component does not
contain the measurable goals necessary to quantify and track progress. A final
document, entitled “A Framework for Assessing the Effectiveness of Jurisdictional Urban
Runoff Management Programs”(Framework) was submitted to the Regional Board on
October 16, 2003. The City will use this document as a guideline for refining the
assessment strategy and for developing additional assessment measures during FY 03-
04. The following subsections restate some of the Framework document and discuss
current and proposed measures of JURMP effectiveness.
11.1 Program Planning, Implementation, and Assessment
Effectiveness assessment is part of on ongoing and iterative process consisting of three
primary elements:
y Program Planning;
y Program Implementation, and;
y Effectiveness Assessment
Program Planning
To be successful, effectiveness assessment should first be addressed in the program
planning stages. This should include the establishment of meaningful implementation
targets and the development of clear measures for assessing success. There are four
key components of program planning that must be completed prior to program
implementation:
1. Source characterization
2. BMP selection
3. establishment of targeted outcomes, and
4. establishment of assessment measures.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 91
The City uses source characterization to document the numbers, location and nature of
contaminant sources in the City. This is accomplished through the development and
maintenance of source inventories, such as the municipal, industrial, commercial, and
construction inventories included in this report. While some of these inventories were
first developed from various databases and directories, they will continue to be
confirmed, refined, and matched to water quality and program assessment in coming
years.
After the sources have been characterized to determine the threats to water quality, the
City must ensure the implementation of BMPs that will most cost-effectively reduce
pollutant loadings from these sources. To ensure that the program is effective, the
BMPs and control strategies selected must be regularly reviewed and updated as
needed.
It is crucial that quantifiable, targeted outcomes be established up front each year rather
than after the fact during program assessment. This helps to increase measurability and
establishes a clearer basis for understanding the cost-effectiveness of program
implementation over time.
Once the desired outcomes of program implementation have been clearly defined,
specific measures must be developed to assess the City’s success in achieving them.
Program Implementation
Program implementation occurs annually on a fiscal year basis. While the goal is to
track a variety of measures first established during program planning, it is important
during the early stages for the program to be flexible to incorporate lessons learned
along the way.
Effectiveness Assessment
Effectiveness assessment includes three broad categories of activity: (1) water quality
assessment, (2) program assessment, and (3) integrated assessment. The long-term
objective is to bridge the existing informational and data gaps in order to integrate water
quality and program assessment strategies.
Water quality assessment refers to the use of sampling data and related information to
draw conclusions regarding the condition of or changes to the condition of receiving
waters or discharges to those waters. Monitoring of discharges and receiving waters is
important for obtaining baseline information and trends in order to identify or confirm
water quality problems and the constituents or stressors causing them.
Program assessment includes the activities conducted to fulfill permit mandates and
measures that provide feedback on the effectiveness of all program activities. This
currently includes an accounting of implementation activities (e.g., number of inspections
conducted, miles of street swept, amount of debris collected from MS4s), but should be
expanded to more sophisticated techniques, such as assessing spatial distribution of
implementation activities in order to most accurately identify and address priority areas.
Integrated assessment is the long-term process of attempting to establish causal
relationships between the program implementation activities and changes to water
quality. Many program activities are required to be conducted, but there is not enough
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 92
data or information to determine if those activities actually do result in improvements in
receiving water quality. Trying to find these “cause and effect” relationships is very
difficult due to the sheer number and variety of BMPs and control programs being
concurrently implemented at any given time.
11.2. Targeted Outcomes
The Framework document established 6 levels of outcomes. Beginning with level 1 and
ending with Level 6, each type of outcome represents a gradation from activity-based to
water quality-based outcomes. Ultimately, the long-term objective is to establish clear
relationships between Levels 1 and 6.
Level 1: Compliance with Activity-based Permit Requirements.
This level consists of the many activities either prescribed by, or established under, the
Permit. Examples include the establishment of discharge prohibitions, inventory
updates, completion of required inspections, and other general messages distributed
through outreach programs. A fundamental feature of Copermittee programs is the
explicit establishment of specific programs and activities such as these, which are
assumed, but not proven, to be beneficial to water quality. While many of the
assumptions underlying the establishment of required activities may be correct, there are
currently few means of quantifying or establishing causal relationships that will make
these efforts more measurable. The City will continue to work with the other
copermittees to investigate the basis for these assumed relationships.
The following table tracks some of the City of Carlsbad program activity measures,
which are discussed in detail in the previous report sections.
Table 11.1 FY 02-03 Program Activity Measures
JURMP section Targeted Activities Measure of
success (%
completed)
MUNICIPAL Inventory #
inspected
# cleaned Qty.
removed
%
inspected/
cleaned
MS4 – catch
basins
3068 3068 2430 5 tons 100 %/79 %
Brow ditches 89,760 lin.
feet
89,760 l.
ft.
2,327 l. ft. 89.8 tons 100 %/2.6
%
channels 14,800 lin.
feet
14,800 l.
ft.
26,480 l.
ft.
20.7 tons 100 %/179
%
Street sweeping 2230 tons
Roadside litter 310 cu.yds.
High Priority 17 17 100 %
Medium Priority 19 17 89 %
Low Priority 79 63 80 %
INDUSTRIAL Inventory #
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 93
inspected
High Priority 105 105 100 %
Medium Priority 321 144 45 %
Low Priority 347 129 37 %
COMMERCIAL Inventory #
inspected
High Priority 608 351 58 %
RESIDENTIAL Tons collected FY 01-
02
Tons collected FY 02-03
Haz. waste 33.1 67.81 205 %
increase
LAND USE Discretionary permits
rev.
# required
SWPPP/SWMP
65 65 100 %
CONSTRUCTION # high priority sites ID’d # high sites inspected
All active grading
permits are rated high >134 >134 100%
IC/ID # complaints received # responded to
Illegal Discharge 156 156 100%
Identified Eliminated
Illegal Discharges 128 128 100%
Illicit Connections 1 1 100%
Dry weather sites 60 targeted sites 60 sampled sites 100%
EDUCATION # events (workshops,
etc)
# attendance
All Public 48 >2,944
Municipal job spec. 71 >747
Printed Electronic
Materials
distributed
>92,000 >19,300
PUBLIC PARTIC. # opportunities provided
81
Tracking of many of these activities is useful for assessing compliance with the program,
but is not yet tied to the long-term assessment of improved water quality.
In addition to these on-going program activities and measures, the City of Carlsbad
conducts a citywide Performance Measurement program that results in an annual report
entitled “State of Effectiveness Report”. This effort was initiated in 1999 and the first
annual report was published in February 2001. This is a systematic approach that is
designed to continuously assess service and program effectiveness and efficiency.
While performance measurement is a fairly common practice in the private sector, there
is not a standard model for the public sector. The City’s goal has been to create and
improve a measurement system that identifies key outcomes that the City is trying to
achieve. The result of this effort is to develop an organization that focuses on
continuous improvement.
The performance measurement program provides a feedback loop between
organizational effort and the ability to achieve and sustain desired outcomes. This is an
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 94
annual cycle, starting each January when the results of the citywide public opinion
survey are finalized and presented to the City Council along with the “State-of-
Effectiveness Report”. The Carlsbad City Council reviews the report and uses it to set
priorities and strategic goals. The results are then communicated to staff to aid in the
development of management goals and department budgets for the coming fiscal year.
The City then hires a company to conduct a telephone public opinion survey each Fall.
The annual “State-of-Effectiveness” report contains the results of the public opinion
survey, along with the performance measures broken out by Strategic Goal. For FY 02-
03, the Council identified nine strategic goals that address Top Quality Services,
Transportation, Balanced Community Development, Parks/Open Space/Trails, Water,
Environmental Management, Finance, Communication, and Learning.
Individual performance measures are developed by departments under the strategic
goals. The City departments annually collect the necessary data and compare results to
benchmark values. The benchmark levels are set very high, since they are the target
level of performance that the department is striving to achieve. Following is a summary
of some of the Performance Measures under the Environmental Management Strategic
Goal for FY 02-03.
Environmental Management Strategic Goal
Strategic Goal
“Be an environmentally sensitive community by focusing on: Clean storm water, sewage
collection and treatment, solid waste, and cost effective and efficient use of energy
including alternative energy sources.”
Sewer
• Service Delivery:
o Volume of Spills: Annual volume of reported sewage spills will be zero
gallons per mile of sewer main.
Results: 32.5
o Volume of Spills Recaptured: Annual volume of reportable spills
recaptured will be 100% of spills.
Results: 22%
o Station Facility Maintenance: At least 90% of all pump station electrical
moving parts, wet wells, generators, valves and pumps are tested and
repaired annually.
Results: 81% (Actual production varies by activity).
o Sewer Main Cleaning: Clean all priority sewer lines according to their
established maintenance schedule.
Results: 82%
• Cost:
Annual cost of service per million gallons of sewage will not exceed $2,236
Results: $1,873
• Customer Satisfaction:
90% of survey respondents rate sewer services as good or excellent.
Results: 93%
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 95
Solid Waste
• Waste Diversion Rate:
Achieve 50% or more diversion annually to meet compliance with AB 939
Results: projected at 55% (official 2002 results are not yet available).
• Cost:
Carlsbad adjusted service rates for commercial and residential customers will
rank in the lowest one-third when compared to other cities in San Diego County.
Results: Solid waste consumer adjusted billing rates, for commercial and
residential customers, are the lowest in San Diego County.
• Customer Satisfaction:
90% of customers rate Solid Waste Services as good or excellent
Results: 86% (89% for trash collections services and 83% for recycling
services).
Storm Water
• Service Delivery:
Each sampling measure (Dissolved Oxygen, Fecal Coliform, Transparency or
Turbidity) in the receiving water to achieve a good rating 100% of the time.
Results: 92%
• Cost:
As this is a new measure, a benchmark has not yet been established.
• Customer Service and Satisfaction:
o 90% of reports of washing or dumping incidents happening at the time of the
report are dispatched within 30 minutes.
Results: 66%
o 90% of the public report having heard or seen messages regarding ways to
prevent water pollution.
Results: 58%
Environmental Management Summary
Sewer: The benchmark for sewage spills was not met. Of the 7,550 gallons spilled,
7,200 gallons were the result of one spill (this total number is lower than the required
reports to the county in appendix 8-4, as the Performance Measure only addresses the
spills related to failures of the City’s system that the City can address and work to
prevent, not those occurring in private systems) which flowed into Buena Vista Lagoon.
Staff has implemented mitigation efforts, such as monitoring and more frequent cleaning
to reduce impacts in the future. Since the outcome of this measure is the impact to the
environment, staff also measures the amount of spills that are recaptured and returned
to the sewer collection system, with the benchmark being 100%. Staff was only able to
recover 21.8% due primarily to the 7,200 gallon spill discussed above.
Operating costs for the sewer system achieved benchmark. Operating and maintenance
costs, including cost of services charged to the City by the Encina Waste Water
Treatment Facility for treatment of Carlsbad sewage flows, have fluctuated over the past
several years. This is reflective of a system that is continuing to increase in size as
development continues. When benchmarked against our partner agencies, we had the
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 96
lowest cost per million-gallons treated. This may indicate that the city is within
acceptable industry standards.
Ninety-three percent of survey respondents rated sewer services in Carlsbad as good or
excellent. This is above the desired benchmark of 90%.
Collectively, the sewer collection system performance measures indicate that the system
is meeting customer expectations in a cost efficient manner. However, service delivery
results are below the benchmark standard and could indicate potential future problems if
not corrected. Staff will continue to research and evaluate operating and maintenance
practices to maintain a high level of customer satisfaction at a reasonable cost when
compared to other jurisdictions, and improve service delivery standards to prevent
potential future problems with the integrity of the sewer system.
Solid Waste: Diversion rates for 2002 are not yet available from the California
Integrated Waste Management Board (CIWMB); however, Staff expects the diversion
rate to continue to meet the benchmark. Based upon an estimated projection, the City
should have a 55% diversion rate for 2002.
Residential and commercial adjusted billing rates are currently the lowest in the County.
For comparison purposes, the adjusted rate is used for this analysis. The adjusted rate
removes the franchise fee and other City imposed fees from the residential and
commercial rate. The adjusted rate represents what is paid to the hauler. However, a
difference in ranking exists between the adjusted and unadjusted rates. The unadjusted
rate represents what the residents and commercial customers actually pay each month.
Carlsbad rates were increased in 2003 to include a storm water fee for both residential
and commercial customers. This is the first increase in seven and a half years. As a
result, the unadjusted rate for residential customers now is the sixth least expensive in
San Diego County, which places the City in the middle of the cost ranking structure. The
commercial rate became the second most expensive rate in San Diego County.
Over the past three surveys, the solid waste collection satisfaction has decreased
slightly each year. However, the survey provided no insight into decrease of customer
satisfaction. Therefore, for the 2003 survey, the recycling and trash collection services
were rated separately in an attempt to better understand customer service satisfaction
levels. The trash collection rated higher than the recycling services. Although customer
satisfaction remained high when compared to other contracted services surveyed, trash
and recycling collection customer satisfaction levels are below the benchmark for the
forth-consecutive year. Staff is currently conducting analysis of the existing solid waste
services for potential program enhancement or additional services.
Collectively, the solid waste performance measures indicate that the program is
operating effectively with respect to cost, quality and customer service. However, the
analysis performed in spring 2003 indicates the program will no longer be AB 939
compliant, which mandates jurisdictions to divert at least 50% of waste from the waste
stream, if services remain the same. As a result, staff will be assessing services for
enhancement such as automated trash, automated single-stream recycling, door-to-door
household hazardous waste collection, special collection events for household
hazardous waste and e-waste and composting. Efforts will be taken to evaluate the
efficiency of all programs and identify opportunities for continued improvement.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 97
Storm Water: Three new measures to gauge the quality of the Storm Water Protection
Program have been added this year. The service delivery component measures water
quality in Carlsbad’s creeks and lagoons. Current efforts are focused on Agua Hedionda
Lagoon and Agua Hedionda Creek as an initial pilot program. With this limited scope,
and results from one sampling event, conditions were rated “good” on 11 out of 12
samples. The benchmark has been established to receive a “good” rating 100% of the
time. There are many factors that are not under the City’s control that can affect storm
water and surface water quality. As a result, it will be difficult to meet the benchmark for
this measure on a continual basis.
Cost efficiency looks at the cost to provide various services associated with the Storm
Water Protection Program and include; cost per business inspected, cost per outfall
monitored, outreach and education cost per capita, and maintenance cost per mile of
storm water conveyance system maintained. Initial data have been gathered, but a
benchmark has not yet been determined.
Customer service and satisfaction measures the response time for active complaints and
gauges the effectiveness of the outreach and education program as reported by results
from the citywide public opinion survey. Staff was able to respond to active complaints
within 30 minutes 66% of the time. In addition, 58% of survey respondents reported that
they had heard or seen messages regarding ways to prevent water pollution.
Data for these performance measures will continue to be collected, analyzed and
compared to benchmark levels. Action plans will be drafted and implemented as
necessary.
Level 2: Changes in Knowledge/Awareness.
The most immediate and basic outcome of many urban runoff program activities is a
change in the knowledge, awareness, or attitudes of target audiences (learning that
storm drains and sanitary sewers are separate systems, that everyday activities
contribute to storm water pollution, etc.). Such changes are most often targeted through
outreach or training programs; once obtained, they presumably form the basis of
behavioral change and therefore of BMP implementation.
City of Carlsbad Public Opinion Survey
This is the annual public telephone survey conducted as part of the City’s Performance
Measurement and “State-of-Effectiveness” report described above. For the past few
years, this survey has been conducted by the Social and Behavioral Research Institute
at California State University, San Marcos. Respondent household telephone numbers
are selected for contact using Random-Digit-Dial methodology with a minimum sample
size of 1,000. Several storm water awareness questions were asked of respondents
during the Fall 2003 survey. The results of these questions will be detailed in the FY 03-
04 JURMP Annual Report.
Industrial/Commercial Survey
Inspected businesses were invited to complete a short written survey to measure
knowledge of BMPs and storm water pollution prevention post inspection and to assess
their satisfaction with the City’s storm water compliance inspection process. The results
of this survey are found in appendix 10-1.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 98
While the survey was short and is not a true scientific survey (based on survey type and
the small population size represented), the results are helpful in a number of areas,
including knowledge/awareness, customer service, and business opinion.
One “knowledge” question simply asked “What does the term “BMPs” stand for in the
Storm Water Program?” While there were 67% of businesses that knew what the term
meant, there were still 33% who had an incorrect answer or did not know. If this is
broken out by business size (# of employees), there is a trend showing that smaller
businesses are much less familiar with BMPs and the storm water regulations than are
larger facilities.
Table 11.2. Business survey results
Number of Employees at the Business Survey Questions
<10 11-50 51-100 >100
What does the term BMP
mean?
54% correct 38% correct 92% correct 100% correct
Were you aware of the
City’s Storm water program
prior to the inspection?
38% yes 46% yes 58% yes 75% yes
Watershed Survey
The Carlsbad Watershed copermittees hired Rea & Parker Research to conduct a
watershed public awareness survey. This was a Random-Digit-Dial methodology
telephone survey of a minimum of 400 respondents in the Carlsbad Watershed. This
survey asked questions that addressed resident attitudes, knowledge, awareness and
behavior. This survey was completed in July 2003, and the results will be presented in
future Watershed annual reports.
6th Grade Classroom Education - Pre and Post Tests
During FY 02-03, the City contracted the Resource Conservation District of Greater San
Diego County (RCD) to conduct the “Classroom Watershed Program” for second and
sixth grade classrooms in Carlsbad, as described in section 9 of this report. Sixth grade
classes received a pre and post demonstration test to measure changes in knowledge.
Following are the results from the 6th grade classrooms.
Table 11.3 6th Grade Pre-and Post test scores
# students Pre-Test
Score
Post-Test
Score
Average
Score
Increase
% Score
increase
19 6.79 8.53 1.74 20.37
26 5.85 8.30 2.44 29.46
15 6.20 8.80 2.60 29.55
17 6.18 8.88 2.71 30.46
25 5.56 7.72 2.16 27.98
Average 27.56
On average, knowledge increased 27% after the demonstration. A copy of the pre- and
post-tests are in appendix 11-1.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 99
The City plans to continue to conduct these classroom watershed presentations during
FY 03-04, and the results will be reported in next year’s annual report.
Website activity
The City has a website page with storm water information. This site received 2,906 hits
during FY 02-03. In addition, the City’s web page that contains HHW and recycling
information received 1,679 hits. This information will be evaluated in future reports, as
the City will continue to update the websites and provide additional information to the
public.
Complaints
The City responded to 156 reports of potential illegal discharges. Approximately 128
were found to be valid complaints (others were not violations, such as minor ground
water issues or permitted discharges). This is up 22 % from FY 01-02, where the storm
water program responded to 121 reports of illegal discharges with approximately 106
valid complaints. This increase in reports may signify increased awareness by
employees and the community of how to identify and report illegal discharges to the City,
however, that cannot be accurately determined. The City plans to increase publicity of
the hotline in FY 03-04 and does anticipate an increase in reports.
Identifying the types of illegal discharges most commonly reported will help indicate
problem areas and activities, and can focus outreach and education efforts to those
areas. Most of the complaints still originate from residential sources. When commercial
sources are identified, most are found to be mobile businesses (power washers, carpet
cleaners, pool maintenance, and landscapers) operating at residences. During FY 02-
03, approximately 25% of the reports were related to home improvement projects (small
residential construction activities involving discharges of cement/concrete slurry, paint
wash water, and the improper disposal or storage of landscaping materials and soil.
This percentage was essentially the same for FY 01-02. The outreach activities for
commercial operations and residential activities are detailed in sections 4 and 5. The
City will continue outreach and enforcement efforts in these areas and track progress.
Level 3: Behavioral Change/BMP Implementation.
Building on increases in knowledge, a key goal of jurisdictional programs is to affect
significant and lasting changes in the behavior of municipal employees, residents,
business representatives, and other target audiences. Outcomes may range from
compliance with discharge prohibitions, to implementation of BMPs, to active
stewardship of watershed resources. Since this is the level at which actions are actually
taken, quantifying BMP implementation through surveys or other means provides an
important step toward establishing load reductions.
Industrial/Commercial Survey
The business awareness survey, previously referenced, indicates that smaller
businesses (less than 50 employees) are less knowledgeable about the storm water
program and BMP information. This was further evidenced by illegal discharge
investigations, which were dominated by mobile businesses and small commercial
facilities, and did not include any large industries. On one hand, the mobile businesses
may be more visible to the public than industrial facilities. Since many of these small
mobile businesses do not obtain City business licenses as required, they can often be
harder to locate to provide outreach and education materials. The results also show that
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 100
the City could be more effective at reducing illegal discharges and improving BMP
implementation if inspections and education resources were focused on the small
businesses instead of the Permit mandated annual inspections of high priority industries,
which are already regulated under the State General Industrial Permit.
Surveys.
Both the citywide Public Opinion Survey and the watershed telephone survey asked
behavioral questions related to storm water and water quality issues. While the
respondents reports of their behavior can not be guaranteed to be completely accurate,
continued survey data will help show if long-term behavior changes are occurring.
These results will be presented in the next annual report.
Monitoring.
City inspectors will review high priority industrial monitoring reports for FY 03-04 and
compare results to benchmark values and FY 02-03 results. This may help indicate if
appropriate BMPs have been implemented at an industrial facility to prevent polluted
runoff, or whether additional source or treatment control BMPs are necessary.
Enforcement
During FY 02-03, there were 10 incidents of escalated enforcement actions from
residential activities, and approximately 17 for commercial operations and 5 for industrial
operations. Escalated enforcement actions are used when necessary to obtain
compliance with BMPs.
Table 11.4. Comparison of FY 01-02 to FY 02-03 Enforcement mechanisms
Type of Action % in FY 01-02 % in FY 02-03
Verbal Warning 44 % 27 %
Informational letter or
warning
24 % 57 %
Notice of Violation 2 % 16 %
Cease and Desist Order <1 % <1 %
The Storm Water Protection Program has focused energies during the first year of
JURMP implementation on educating the public and informing residents and businesses
how to comply. In most instances, a verbal notice was sufficient for compliance. Once
repeat violations occur after the responsible party has been informed, the City escalates
enforcement actions to obtain compliance. It is anticipated that this trend may continue
in order to ensure BMP implementation with repeat violators.
Level 4: Load Reductions.
The primary goal of BMP implementation is to reduce the loading of pollutants to storm
water discharges. An important emphasis of annual program assessments is the
estimation of load reductions resulting from various program activities. Assuming that
such reductions are properly targeted to existing or potential water quality problems,
load reductions should in turn result in improvements to discharge and receiving water
quality. Quantifying load reductions represents an important intermediate endpoint for
assessments.
During FY 02-03, the City hired Rick Engineering Company to conduct a Regional
Treatment BMP Feasibility Study for the Agua Hedionda Watershed in Carlsbad. The
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 101
study was designed to identify potential locations for retrofit of existing
desilting/detention basins and then to evaluate several treatment BMPs for the sites.
This study was not completed during the current reporting period, so no information is
available at this time. However, the results and modeling from this study may be used in
the coming years to estimate loading from various land uses and treatment units, and to
monitor and evaluate performance of specific BMP treatment devices.
Level 5: Changes in Discharge Quality.
In many respects, changes in discharge quality are the most direct expression of
successful program implementation since receiving water quality reflects much more
than discharges from the municipal separate storm sewer system (MS4). Measurably
improving the quality of discharges both into and from the MS4 is therefore an important
type of targeted outcome.
Coastal Outfall monitoring
As mentioned in subsection 8.1, the City collects samples of various storm drain outfalls
as part of the Permit mandated Coastal Outfall Monitoring Program. If water is flowing
from the outfalls, samples are collected from the outfall and in the receiving water, and
are analyzed for total coliform, fecal coliform and enterococci. At the beginning of the
fiscal year, the City contracted with the County Department of Health to monitoring the
eight active outfalls to the beach. Starting in November, 2002, the program required that
the storm water outfalls to the lagoons also be monitored. This added over 50 additional
outfall locations for monthly (wet season) or biweekly (dry season) monitoring. The City
then contracted with D-Max Engineering Inc. to monitor all of the outfalls.
Of the 58 sites routinely monitored in FY 02-03, only 6 outfall had flow at each
monitoring event and 19 had intermittent flow. The rest did not have any flow during all
monitoring events.
The monitoring and follow-up activities are detailed in the Adaptive Monitoring Plan.
Storm drain sample results are compared to the 95th percentile criteria established in the
plan. For the Ocean locations, all 34 samples were paired samples. There were 10
ocean outfall samples exceeding the 95th percentile for Total Coliform, 4 for fecal
coliform and 4 for enterococcus. None of the corresponding paired ocean water
samples exceeded the REC-1 standards. For the lagoon locations, there were 56 paired
samples taken, and 122 single storm drain samples taken. Single samples were taken
when the lagoon was too far away or inaccessible to take a paired sample. Of the 178
storm drain samples taken, there were 17 exceeding the 95th percentile for Total
Coliform, 14 for Fecal coliform and 3 for Enterococcus. Exceedances of the 95th
percentile did not correlate with any corresponding exceedances in the receiving water.
In most cases, the flow from the outfalls was intermittent and very low volume. In many
cases, the flow does not actually reach the receiving waters, but dissipates in the sand
or sediment.
The City will continue to conduct the Coastal Outfall Monitoring Program and to conduct
follow-up investigations as detailed in the Adaptive Plan.
Dry Weather Field Screening and Analytical Monitoring Program
The City has conducted an annual Dry Weather Analytical and Field Screening
Monitoring program since 1995. The purpose of the monitoring program is to detect and
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 102
eliminate illicit connections and illegal discharges to the storm drain system. For the
past six years, the City has contracted this work out to D-Max Engineering, Inc. The dry
weather monitoring program report for FY 02-03 and follow-up activities are found in
Appendix 8-1.
The City also hired D-Max Engineering to conduct additional data analysis of all years
existing data. While the program has been conducted since 1995, the list of analytes
changed with the new permit, so some of the new parameters were only measured for
the past two years. However, D-Max analyzed and charted the existing results by
watershed, by land use and by conveyance type (see appendix 11-2). In many cases,
there are too few data to draw any conclusions. However, these data will continue to be
collected annually and results reviewed in future reports.
Level 6: Changes in Receiving Water Quality.
The ultimate objective of the Permit programs is the protection and improvement of
water bodies receiving discharges from the MS4. Targeted changes to receiving water
quality can include a variety of outcomes such as compliance with regulatory
benchmarks, biological integrity, beneficial use attainment and protection. Regardless of
the outcomes targeted, it is important to keep in mind that receiving water quality often
reflects considerably more than the quality of a City’s MS4 discharge. In addition,
receiving water quality can be adversely impacted by other events that are not under the
control of the City, such as other permitted NPDES discharges, birds and wildlife
(impacting bacteria levels), atmospheric deposition and so on.
On May 9, 2003, the City of Carlsbad submitted a Concept Proposal Package to the
State Water Resources Control Board for a Prop. 13 grant proposal to perform bacteria
source identification on Agua Hedionda Lagoon. The project outlined how the future of
Agua Hedionda Lagoon hinges on providing a balance between economic and
ecological needs and how the grant would allow for a proactive, technically sound
Bacteria Source Identification and Water Quality Improvement Project to achieve that
end. The project as proposed would have allowed for improvement of water quality
through the implementation of comprehensive bacteria reduction measures in the Agua
Hedionda lagoon and watershed. A stakeholder group would have been identified and
encouraged to participate in the project, and technical experts would have been included
in the study design. Unfortunately, this project did not get selected by reviewers and did
not proceed to the second step in the selection process.
The City plans to undertake additional activities during FY 03-04 in order to begin
establishing receiving water baseline data to use for future evaluations. Some activities
were conducted in FY 02-03, and will be reviewed with FY 03-04 data in next year’s
report.
Expansion of Dry Weather Program
The Dry Weather Field Screening Program is aimed primarily at identifying illegal
discharges in the storm water system. D-Max Engineering Inc. conducted this program
for the City during FY 02-03. The City elected to expand the program to include four
additional sites in the receiving waters to provide baseline data. This included new
monitoring sites on Buena Vista creek, Agua Hedionda Creek (at the Mass Loading
Station site), Encinas Creek, and San Marcos creek. Each of these tributaries is also
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 103
part of the 4 separate watersheds that are in Carlsbad. The results of this investigation
for FY 02-03 are found in Chapter 7 of the Dry Weather Report (appendix 8-1). It is
anticipated that these will become annual sampling points and provide comparisons from
one year to the next.
Performance Measures
One of the City performance measures includes a pilot program of additional water
quality monitoring on Agua Hedionda Lagoon and Creek. This was not started until the
beginning of FY 02-03, so the results will be available in next year’s report. A
description of the storm water performance measures is in appendix 11-3.
Coastal Monitoring Data
The City collected 34 samples of the ocean water (paired samples were collected when
the storm drain was flowing) during FY 02-03. There were no exceedances of the REC-
1 standards in the Ocean for total coliform, fecal coliform or enterococci.
There were 56 paired samples collected from outfalls to lagoons during FY 02-03. Of
the 56 receiving water samples taken, there were only a few samples exceeding
benchmarks: Four for total coliform (2 in Batiquitos and 2 in Agua Hedionda); twelve for
fecal coliform (7 in Batiquitos and 5 in Agua Hedionda); and six enterococci (2 in
Batiquitos and 4 in Agua Hedionda). There was wide variability between outfalls,
monitoring events, and between dry and wet seasons, and there was little, if any,
correlation between a high receiving water result and a high storm drain result. For the
paired samples exceeding the REC-1 standards, all of the corresponding storm drain
results were below the 95th percentile.
Buena Vista Lagoon and Batiquitos Lagoon are both designated Ecological Reserves,
and the public is not allowed to enter the water for recreation (the Basin Plan specifically
prohibits contact recreational (REC-1) uses in Buena Vista Lagoon except for fishing
from shore or boat). These lagoons have areas designated for wildlife habitat (Least
Tern nesting areas, etc.), and undoubtedly, the birds and other wildlife contribute to the
bacteria levels in the lagoon.
The City will continue to implement this program and to conduct follow-up investigations
in accordance with the Adaptive Plan.
Volunteer Water Quality Monitoring
Some of the Lagoon foundations and others who have participated in the Watershed
Stewardship Training are interested in conducting volunteer water quality monitoring in
the Carlsbad Watershed, possibly in coordination with the San Diego Stream Team.
Discussions are underway between these groups and the City of Carlsbad in hopes of
being able to put together a plan in FY 03-04 for monitoring some of the creeks in
Carlsbad and throughout the watershed.
While there are important issues to address regarding quality assurance issues with
volunteer monitoring, this group is enthusiastic about putting an acceptable plan together
to gather valid data. This could be beneficial for the City since resources are limited for
expanding the current water quality monitoring programs.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 104
Regional Workbench Consortium
City of Carlsbad staff attended a conference hosted by the Regional Workbench
Consortium on May 29, 2003. The Workbench is a collaborative network of university,
government, industry, and community-based partners. The conference showcased the
research projects completed in the previous year, and ongoing proposals that the group
was working on. The main objectives of the group are to promote sustainability science;
3D model Building and visualization in support of watershed management, planning and
education; tools for federating spatial data on toxics, promoting cross-border
collaboration, and promoting community based planning programs. The Workbench
website further explains their mission and project (www.regionalworkbench.org).
During FY 03-04, the City will investigate the feasibility of working with the Workbench to
set up a website interface to show Carlsbad water quality information
http://geo.sdsc.edu/ilya/maps/toxic_geo/main2.htm. The purpose would be to educate
the public by allowing them to view water quality data and other information spatially,
and to provide information and opportunities for additional research. The entire depth of
the project has not been defined, but it will continue to be explored during FY 03-04.
11.3 FY 03-04 Action Plan
Information from water quality monitoring, complaints and the Federal Clean Water Act
303(d) Impaired Waterbodies List indicate that bacteria, sediment and nutrients are
priority constituents of concern in Carlsbad. These constituents will be addressed in FY
03-04 through a number of new and expanded activities described below.
Bacteria
Current lab testing is not yet perfected and readily available to determine whether the
source is human (sewage spills, encampments), domestic animals (dogs, cats, horses),
or wildlife (birds, coyote, raccoon, possum, etc.). Results from the coastal outfall
monitoring program are inconclusive, as there is rarely a direct correlation between a
high result in the storm drain and an exceedance in the receiving water, and vice versa.
The Agua Hedionda Microbiological Study conducted in 2000 attempted to identify
bacterial sources using ribotyping, but results also were inconclusive. Until field and
laboratory ribotyping procedures are perfected and affordable, the source can not be
accurately identified. In the meantime, the City will continue to address bacteria from
urban sources through the following activities:
1) Pet Waste:
a) Continue to educate residents about picking up after pets (see pet waste
brochure developed in FY 01-02).
b) Assess if there are additional public places to provide bags and proper disposal
containers.
c) Consider organizing volunteer groups to help disseminate information at popular
dog walking sites along beaches, lagoons and other trails.
2) Illegal Encampments: This controversial issue goes beyond City boundaries, as
many of the people who inhabit these encampments are not legal residents of the
United States.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 105
a) The City may remove illegal encampments on public property, especially those in
sensitive habitat and mitigation areas. Currently, these areas have bilingual
posting to discourage habitat destruction.
b) Offer assistance to businesses and organizations to locate housing for local
migrant workers.
3) Monitoring and Investigations:
a) Move the Coastal Monitoring Program from contractors to in-house staff.
b) Contract with a new lab capable of meeting negotiated turn-around times in order
to conduct timely upstream investigations.
4) Sewage Spills:
a) Continue to implement the Sewer Overflow Prevention Plan/Response Plan, and
track results as part of the Performance Measurement system.
b) Continue to educate businesses and residents about sewer lateral maintenance
to prevent sewer blockages and overflows.
Sediment
The Permit requires the City to address sediment resulting from human activity. The
City will continue to address sedimentation through the following activities:
1) New Construction:
a) Continue SUSMP implementation with SWPPP requirements.
b) Continue to conduct site inspections and require sediment and erosion control
BMPs with enforcement as necessary.
2) Existing development – residential
a) Continue to educate residents and landscape companies about sediment and
erosion control BMPs.
b) Continue to respond to complaints and implement enforcement actions as
necessary.
3) Street Sweeping
a) Conduct street sweeping as scheduled
b) Continue to sweep as needed in response to complaints.
4) Storm Drain Maintenance
a) Continue to perform catch basin cleaning and documenting high priority areas.
b) Continue to clean City brow ditches, drainage ways, and basins.
c) Investigate additional ways to prioritize and improve cleaning effectiveness.
Nutrients
Ammonia and nitrate continue to exceed action levels in dry weather results for certain
areas. In response, the following activities are planned for FY 03-04:
1) Inspections
a) Conduct unannounced inspections of automotive shops and dealers in Car
Country Carlsbad. Review MSDS for use of ammonia based cleaning products
and recommend alternatives if available.
b) Inspect agricultural operations as needed or in response to complaints.
2) Education
a) Facilitate an open dialogue with agricultural operations and work with other
technical experts such as Natural Resources Conservation Service and UCSD
Cooperative extension, if possible.
b) Educate landscape companies about pesticides, fertilizers and irrigation
practices, along with any IPM activities occurring at the Regional level.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 106
c) Organize workshops for residents on lawns and gardens and pollution
prevention.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 107
Section 12
Fiscal Analysis Component
12.0 Overview
During FY 02-03, the City funded all storm water program activities from the general
fund, with the exception of the Storm Water Facility Capital Improvement Program,
which may be funded from a variety of sources (see Table 12.1). The increase in
program costs over the past several years has put a strain on the General Fund and will
over time force reductions in other City services. To prevent this from happening, the
City formed a storm water financing team in FY 01-02 to study potential funding
mechanisms. At that time, the City commissioned an Alternative Financing Mechanisms
Study, which was prepared by Brown and Caldwell. The recommendation from the
financing study, as amended by the City Leadership Team, was to pursue four separate
funding sources.
The first of these sources is the establishment of a new processing fee for the review
and inspection of Storm Water Pollution Prevention Plans (SWPPP’s) for construction
related activities and business-related commercial/industrial activities. The second
source is the establishment of new and/or increased fines and levies against storm water
code violators. The third source is to impose utility surcharges on the City’s water,
sewer and/or solid waste service bills to pay for these storm water activities reasonably
related to the provision of utility and solid waste services. The fourth source is the
creation of a new storm water utility charge to pay for property related storm water
activities and potentially for major repair and replacement of storm water collection and
treatment facilities.
During FY02-03, this storm water financing team reviewed these potential sources, and
prepared a document titled “Storm Water Pollution Prevention Program Alternative
Financing Mechanism Study Report”, (report – see appendix 12-1) which will be
presented to the City Council during FY 03-04. This report recommends that the City
pursue the establishment of new construction related SWPPP processing fees and
imposition of solid waste service surcharges.
The City determined that nearly all of the pollutants discharged into the City’s storm
water system are classified as solid waste under state and local codes. Based on this
information and other findings, the report proposes a Solid Waste Service fee increase
for residential and commercial service users to fund certain storm water protection
program activities. The amount of the fee increase will be calculated based upon the
apportioned costs to the business and residential service users and their contribution to
the pollutant loading. In the case of the Commercial/Industrial SWPPP Inspection
Program, all costs will be apportioned exclusively to commercial service users. The
Solid Waste Service fee increase will generate approximately $1.3 million annually in
new revenues to fund the City’s storm water protection program activities as noted
above.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 108
The report also recommends that the City establish new development processing fees to
pay for City costs to review and inspect construction related SWPPP’s. At the City’s
current rate of development, the new SWPPP review and inspection fees will generate
approximately $180,000 annually in revenues to pay for these services.
The following table summarizes the potential funding sources for specific programs or
activities as outlined in the report.
Table 12.1. Program activities and funding sources recommended from the report.
Program/Activity Funding Source(s)
Storm Water Facility Capital
Improvement Program
Developer Impact Fees, Developer
Exactions, General Fund, Gas Tax,
TransNet Sales Tax, Federal and State
Grants
Storm Water Facility Maintenance and
Operation Program including Street
Sweeping, Litter Removal and Storm
Event Readiness and Patrolling
Solid Waste Service Fees, General Fund
Storm Water Program Administration Solid Waste Service Fees
Illicit Detection and Illegal Discharge
Enforcement Program
Solid Waste Service Fees, General Fund,
Fines
Commercial/Industrial SWPPP
Inspection Program
Solid Waste Service Fees (charged to
commercial service customers only)
Construction Related SWPPP Review
and Inspection Program
Developer Fees
The total annual cost to fund the City’s storm water program activities for FY 2003-04 as
identified in table 12.1 is $1,611,527 (excluding the Storm Water Capital Improvement
Program costs discussed in Section 12.1 below). The FY 02-03 budget detail is in
appendix 12-2.
12.1 Storm Water Facility Capital Improvement Program
Capital expenditures for new or upgraded storm water facilities are generally funded
from developer revenues generated by the City’s adopted Local Drainage Area Fee
program, developer exactions, or the City’s General Fund. Occasionally, new drainage
facilities or repairs and/or rehabilitation of existing drainage facilities are funded from
other road-related funding resources such as the Gas Tax, TransNet Sales Tax, or
Federal and State Grants. The City’s adopted Capital Improvement Program (CIP)
budget includes funding for $32.7 million dollars in storm water facility costs to build-out
of the City. Funding for additional drainage facilities are included within the funding for
various other City road improvement and civic projects. The exact amount of funding for
drainage improvements that is included within the funding of other projects is not
identified in the CIP budget.
The City is committed to funding the construction of all new and upgraded storm water
facilities from its Development Impact Fee Program, the General Fund, and other
revenue sources as described above; however, the City will continue to investigate
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 109
formation of a Storm Water Utility as a possible alternative source of funding to replace
General Fund contributions.
12.2 Storm Water Facility Maintenance and Operation Program
For the purpose of this financial analysis, the Storm Water Maintenance and Operation
(M&O) Program within Carlsbad includes cleaning and minor repairs to storm drain lines
and inlets, street sweeping, litter removal, storm event preparations, and patrolling. The
total annual cost to provide these services, as detailed in the FY 2003-04 Operating
Budget, is $436,679. Historically, the cost to provide these services was funded by the
City’s General Fund. If the proposed new funding mechanisms are adopted by the
Council in 03-04, $334,748 of the M&O costs will be funded through the revenues
generated from the Solid Waste Service fee increase. The remaining $101,931 in M&O
costs will continue to be funded from the City’s General Fund.
12.3 Storm Water Program Administration
The cost to administrate the City’s Storm Water Program includes expenditures for
annual JURMP reporting, GIS updates, records maintenance, wet weather monitoring,
NPDES fee payments, education and outreach, and general program administration.
The total annual cost for administration is $631,934, funded from the General Fund. If
the proposed new funding mechanisms are adopted by the Council in 03-04, the full cost
for administration of the program will be paid from the revenues generated from the Solid
Waste Service fee increase.
12.4 Illicit Detection and Illegal Discharge Enforcement Program
The Illicit Detection and Illegal Discharge Enforcement Program includes activities to
detect and investigate the discharge of non-permitted pollutants into the City storm
drainage system. This also includes any activities required to eliminate non-permitted
discharges and/or otherwise enforce compliance with the storm water permitting
regulations. The total annual budgeted costs for the City’s Illicit Detection and Illegal
Discharge Enforcement Program for FY 03-04 is $231,900. This figure does not include
any cost for legal actions taken to enforce compliance with the Illicit Detection and Illegal
Discharge Enforcement Program. The cost for any legal action taken against an
illegal/illicit discharger will be paid from the General Fund or fines levied against the
respective illegal/illicit discharger.
These activities have been funded from the General Fund. If the proposed new funding
mechanisms are adopted by the Council in 03-04, $230,600 of the program costs will be
paid from the revenues generated from the Solid Waste Service fee increase and $1,300
will be paid from the General Fund.
12.5 Commercial/Industrial SWPPP Inspection Program
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 110
The City’s Commercial/Industrial Storm Water Pollution Prevention Plan (SWPPP)
Inspection Program includes the review of business related SWPPP’s together with
periodic site inspections to ensure compliance with the City’s Storm Water Protection
Program. The total annual cost for the City’s Commercial/Industrial SWPPP Inspection
Program is $106,050. This has been funded from the General Fund. If the proposed
funding mechanism is approved, the full cost for Commercial/Industrial SWPPP
Inspection Program will be paid from the revenues generated from the Solid Waste
Service fee increase charged to commercial service customers.
12.6 Construction Related SWPPP Review and Inspection Program
The City’s Construction Related Storm Water Pollution Prevention Plan (SWPPP)
Review and Inspection Program includes the review of construction related SWPPP’s
together with regular site inspections during project construction to ensure
owner/developer compliance with the City’s Storm Water Protection Program. The total
annual cost for the City’s Construction Related SWPPP Review and Inspection Program
will vary from year to year depending upon the level of development within the City. The
new processing fees will ensure that adequate revenues will be generated to pay for all
City construction related SWPPP reviews and inspections.
Based upon current development activity levels, the City anticipates the annual program
costs to be $180,000. This has been funded from the General Fund. If the new funding
mechanisms are approved, the full cost for the Construction Related SWPPP Review
and Inspection Program will be paid from the revenues generated from the collection of
development processing fees.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 111
Section 13
Special Investigations
There were no special investigations conducted during FY 02-03.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 112
Section 14
Conclusions and Recommendations
14.0 Overview
During FY 02-03, the City implemented the Permit requirements and the program
components of the JURMP. Identified program strengths as well as improvement areas
for FY 03-04 are outlined in each report section. As more programs and activities are
implemented, there is a clear need for better databases for tracking and reporting all of
these activities and the BMPs being implemented. Tying all of these activities to
changes in water quality still presents a considerable challenge. This is part of the long-
term assessment strategy that will take time to develop trends and to determine cause
and effect relationships between pollution prevention and water quality management.
The City will continue to work with the Copermittees to develop additional effectiveness
measures, in addition to developing measures on program effectiveness within the City.
14.1 Recommended activities for FY 03-04
Information from water quality monitoring, complaints and the Federal 303(d) list indicate
that bacteria, sediment and nutrients are priority constituents of concern in Carlsbad.
The City proposes to address these constituents during FY 03-04 through the activities
described below.
Bacteria
Current lab testing is not sufficient or readily available to determine whether sources of
bacteria are human (sewage spills, encampments) related or from domestic or wild
animals. Results from the coastal outfall monitoring program are inconclusive, as there
is rarely a direct correlation between a high result in the storm drain and an exceedance
in the receiving water, and vice versa. The Agua Hedionda Microbiological Study
conducted in 2000 attempted to identify bacterial sources using ribotyping, but results
also were inconclusive. Until field and laboratory ribotyping procedures are perfected
and affordable, the source cannot be accurately identified. In the meantime, the City will
continue to address bacteria from urban sources through the following activities:
1) Pet Waste:
a) Continue to educate residents about picking up after pets (see pet waste
brochure developed in FY 01-02).
b) Assess if there are additional public places to provide bags and proper disposal
containers.
c) Consider organizing volunteer groups to help disseminate information at popular
dog walking sites along beaches, lagoons and other trails.
2) Illegal Encampments: This controversial issue goes beyond City boundaries, as
many of the people who inhabit these encampments are not legal residents of the
United States.
a) The City may remove illegal encampments on public property, especially those in
sensitive habitat and mitigation areas. Currently, these areas have bilingual
posting to discourage habitat destruction.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 113
b) Offer assistance to businesses and organizations to locate housing for local
migrant workers.
3) Monitoring and Investigations:
a) Move the Coastal Monitoring Program from contractors to in-house staff.
b) Contract a new lab capable of meeting negotiated turn-around time in order to
conduct timely upstream investigations.
4) Sewage Spills:
a) Continue to implement the Sewer Overflow Prevention Plan/Response Plan, and
track results as part of the Performance Measurement system.
b) Educate businesses and residents about sewer lateral maintenance to prevent
sewer blockages and overflows.
Sediment
The Permit requires the City to address sediment resulting from human activity. The
City will continue to address sedimentation through the following activities:
1) New Construction:
a) Continue SUSMP implementation with SWPPP requirements.
b) Continue to conduct site inspections and require sediment and erosion control
BMPs with enforcement as necessary.
2) Existing Development – Residential
a) Continue to educate residents and landscape companies about sediment and
erosion control BMPs.
b) Continue to respond to complaints and implement enforcement actions as
necessary.
3) Street Sweeping
a) Conduct street sweeping as scheduled
b) Continue to sweep streets as needed in response to complaints.
4) Storm Drain Maintenance
a) Continue to perform catch basin cleaning and documenting high priority areas.
b) Continue to clean City brow brow ditches, drainage ways, and basins.
c) Investigate additional ways to prioritize and improve cleaning effectiveness.
Nutrients
Ammonia and nitrate continue to be present in dry weather results for certain areas. In
response, the following activities are planned for FY 03-04.
1) Inspections
a) Conduct unscheduled inspections of automotive shops and dealers at Car
Country Carlsbad. Review MSDS for use of ammonia based cleaning products
and recommend alternatives if available.
b) Inspect agricultural operations as needed or in response to complaints.
2) Education
a) Facilitate an open dialogue with agricultural operations and work with other
technical experts such as Natural Resources Conservation Service and UCSD
Cooperative Extension, if possible.
b) Educate landscape companies about pesticides, fertilizers and irrigation
practices, along with any IPM activities occurring at the Regional level.
c) Organize workshops for residents on lawn and garden care and pollution
prevention.
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 114
14.2 Proposed JURMP Revisions
Section 2.7.1 (action 5) and 2.7.2 (action 3), and 2.3.2
Previous language stated that the goal is to annually inspect 90% of the high priority
areas with an additional goal of biannually inspecting the Medium and Low priority
municipal areas. This is being revised to conform with the Permit language that states,
“At a minimum, each Copermittee shall inspect high priority municipal areas and
activities annually.” All high priority municipal areas and activities will be inspected
annually, and medium and low priority municipal facilities will be inspected as needed.
Section 8.9.2 (Action 2)
The bullets in this section list the preventive maintenance of the sanitary sewer system
and MS4. The first bullet states “annual inspection of portions of the conveyance system
(streets, gutters, pipelines, catch basins, inlets, channels)”. It is intended to state that
portions of the pipelines are inspected annually, as the entire MS4 pipelines are not
inspected annually. This will be revised as follows:
y Annual inspection of portions of the conveyance systems (streets, gutters,
catch basins, inlets, channels);
y Inspections of the conveyance system pipelines as needed;
City of Carlsbad JURMP Annual Report for July 1, 2002 - June 30, 2003 115