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HomeMy WebLinkAbout; ; JURMP Annual Report 2005-2006 NPDES Permit Order No. 2001-01; 2007-01-01 CCiittyy ooff CCaarrllssbbaadd JJuurriissddiiccttiioonnaall UUrrbbaann RRuunnooffff MMaannaaggeemmeenntt PPllaann AAnnnnuuaall RReeppoorrtt JJuullyy 11,, 22000055 –– JJuunnee 3300,, 22000066 City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 i 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. This Annual Report covers the period from July 1, 2005 through June 30, 2006, which corresponds to the City’s Fiscal Year 2005-2006 (FY 05-06). FY 05-06 represented Carlsbad’s fifth annual report, and 4th year implementing the JURMP. Since the last Annual Report submission, many procedures have been streamlined to efficiently manage data, monitor sites, track inspections and investigations, and manage other storm water related activities. 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. During FY 05-06, the City continued to promote a comprehensive pollution prevention program for the Carlsbad community, combining the activities of storm water, solid waste and water conservation. These three programs were brought under the umbrella of Environmental Programs in FY 03-04 in order to create a unified message, better educate the public, and allow easy access for the public. During FY 05- 06 the City continued to promote the use of the Environmental Programs phone number (760-602-4646), as well as a web page (www.carlsbadconserves.org). Section 2: Municipal The City’s municipal facilities include administration buildings, recreational areas, maintenance and storage 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 Best Management Practices (BMPs) are not properly implemented. During FY 05-06, the Storm Water Committee continued to meet monthly to discuss municipal storm water BMPs and pollution prevention issues. The Committee is comprised of approximately 14 members representing various City departments including Public Works, Fire Department, and the Building Department. The intent is to communicate problems and solutions among the group in order to share knowledge, discuss training opportunities, enhance compliance with the Permit, and to pass along any new information from the Regional Water Quality Control Board (Regional Board). In addition, the City continued implementing the Maintenance Assessment Program to measure the level of care provided at various City facilities. While this is a large program developed separate from the Permit or JURMP, there were some measures that overlapped or were related to storm water pollution prevention and BMP implementation. These related measures are reported in Section 11 of this report. During FY 05-06, D-Max Engineering Inc. (D-Max) conducted unannounced inspections of all “High” priority municipal facilities. This provided “another set of eyes” to make observations at municipal facilities and recommend corrective actions, when necessary. With the annual inspections by the State Department of Pesticide Regulations (DPR for Parks activities), municipal inspections by D-Max, in- house quarterly inspections, and staff training on storm water BMPs, personnel are more aware of the required maintenance practices in preventing storm water pollution. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 ii The City continued to implement a computerized asset management/work order system that allowed the Storm Drain Maintenance Crew to track the MS4 inventory, inspections, and maintenance activities conducted throughout the system. The Storm Drain Maintenance Crew used the system to set up preventive maintenance schedules for any facilities that needed to be inspected annually or for those requiring more frequent cleaning. This system allows better management of the inspection and cleaning schedule and improved tracking of the amounts and types of debris removed from the MS4. Comments from the Regional Board on the FY 04-05 JURMP Annual Report related to the Municipal program are addressed in this report as follows: Review Letter Comment # Section Addressed 1 2.2 2 2.3 3 2.3 4 2.3 5 2.3 6 2.4 Section 3: Industrial The City currently tracks over 470 industrial facilities within its jurisdiction. Major industry types include airport services, refuse and sewage management, pharmaceutical research and development, high technology and electronics, golf apparel and equipment manufacturers, and several light industry parks. Industrial activities can cause storm water pollution and degrade receiving water quality if performed with disregard for the environment. During FY 05-06, the City updated the prioritized industrial inventory, mapped all industries, inspected 351 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 by submitting copies of inspection reports and correspondence with high and medium priority industries. The City took 18 enforcement actions against industries to achieve compliance in FY 05-06. The City will continue to inspect all high priority industrial facilities annually, inspect medium and low priority facilities on a complaint basis and/or as resources are available, and continue to review industrial monitoring data and compare results to benchmark values and previous years results. The Regional Board is currently revising the language and procedures outlined in the State General Industrial Permit. When the permit is reissued, the City would like to host a workshop for all industries in Carlsbad to discuss the new permit guidelines, compliance issues and address any concerns business might have about the new permit. The Storm Water Protection Program developed and continues to use Knowledge and BMP Effectiveness Assessment measures for industries. These assessments continued to be conducted by inspectors during onsite facility inspections. Please refer to Section 3 of this report for more information. Comments from the Regional Board on the FY 04-05 JURMP Annual Report related to the Industrial Inspection program (#7) are addressed in Section 3.5 of this report. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 iii Section 3: Commercial The City currently tracks over 500 high priority commercial facilities. Commercial facilities can generate a variety of pollutants depending on the types and locations of activities performed. Major commercial types include automobile maintenance, restaurants, pressure washing, masonry and concrete work, carpet cleaning, and landscaping activities. The City continued to implement a comprehensive program to reduce urban runoff originating from existing commercial sites and sources. During FY 05-06, the City updated the commercial inventory, mapped all “high” priority commercial facilities, provided education and outreach on BMPs, inspected 443 commercial sites, and conducted enforcement activities to ensure compliance. The City took a total of 56 enforcement actions against commercial businesses during FY 05-06 in order to achieve compliance. In June 2006, the City hosted a free pollution prevention workshop for area businesses that prepare and/or sell food and beverages. Approximately 300 businesses were invited to attend and invitations included information about storm water and BMPs. The workshop provided the food service industry with important educational tools to comply with the City’s pollution prevention requirements. Participants received training in storm water pollution prevention, trash and grease management, and the requirements of the Carlsbad Municipal Code. Featured speakers from the City, Waste Management, and the San Diego County Green Business Program provided information about storm water requirements, pollution prevention strategies, and BMPs. Section 5: Residential The City encompasses approximately 42 square miles and has an estimated population of 98,607 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 focus of the City’s pollution prevention strategy is a proactive information and education program that utilizes public presentations, fact sheets, direct mailers, brochures, website, and other media to increase knowledge and awareness of storm water pollution prevention efforts. Targeted activities for residential areas include vehicle washing, storage, and maintenance, lawn and garden care, home improvement projects, pet waste disposal, swimming pool maintenance, household hazardous waste (HHW), and trash and debris cleanup and disposal. The Storm Water Protection Program continued to distribute information addressing these residential BMPs and required several minimum BMPs to be implemented. In March 2006, the City developed a new brochure for the mobile service providers including carpet cleaners, plumbers, pressure washers, mechanics, porta-potty services, and any other mobile business that provide services at various off-site locations. Mobile service materials and residuals such as cleaners, grease, soapy water, dirt, debris, and other pollutants often find their way to our streets and storm drains. This brochure was designed for mobile service providers, their employees and anyone that hires a mobile service provider. During FY 05-06, the “Best Management Practices for Mobile Service Providers” brochure was mailed to every applicable commercial business on the storm water inventory. During FY 05-06, the City distributed storm water educational information for residential activities, expanded an advertising campaign, hosted or participated in 13 residential outreach events, offered four oil recycling drop-off sites and two HHW collection sites for residential use, responded to 107 reports of illegal discharge, and issued 37 enforcement actions to achieve compliance. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 iv In FY 05-06, the Storm Water Protection Program continued to work closely with other City programs and departments to address such issues as water conservation, code enforcement, outreach, and pollution prevention. The City also continued to advertise Environmental Programs and continued to seek the most efficient and effective ways to educate the public. The Storm Water Protection Program received several complaints directly related to or caused by poor water conservation practices (over irrigation etc.). The Storm Water Protection Program continues to work closely with the City’s Water Conservation Specialist to address these issues with residents. Section 6: 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 impacts of development activities on receiving water quality. Land-use planning gives 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. The City continued to implement 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. In FY 05-06, there were 53 discretionary projects that were reviewed and required to submit applicable storm water pollution prevention plans (SWPPP). For FY 06-07, the City will continue to work on 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. Comments from the Regional Board on the FY 04-05 JURMP Annual Report related to the Land Use Planning program are addressed in this report as follows: Review Letter Comment # Section Addressed 8 6.1 9 6.2 10 6.3 Section 7: 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 project proponents implement measures to ensure that pollutants 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. During FY 05-06, the City updated the construction inventory, inspected all high priority sites, conducted outreach and education to developers, engineers, contractors, and City staff, and used enforcement actions to obtain compliance when necessary. All active grading permits were ranked as high priority and inspected weekly. Inspectors used enforcement actions as necessary to achieve compliance, including issuing 15 field memos, 1 correction notice, and 14 stop work notices. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 v The City continued to implement the procedures developed in both the ministerial permit report developed in June 2004, and the minimum BMPs report developed in May 2004, and to train inspectors on these procedures. The City continued to distribute the “Pollution Prevention Guide to the Construction Industry” brochure. The City also continued to work with the North County Outreach group to develop new brochures for the construction industry. Comments from the Regional Board on the FY 04-05 JURMP Annual Report related to the Construction program are addressed in Section 7 of this report as follows: Review Letter Comment # Section Addressed 11 7.4 12 7.3 13 7.1 14 7.5 15 7.7 Section 8: Illicit Discharge Detection and Elimination The City continued to conduct a comprehensive and proactive program for detecting and eliminating illegal discharges to the storm drain system. The City’s program actively seeks to identify and eliminate illicit discharges and connections by conducting investigations, responding to spills and sewage overflows, conducting monitoring, and performing routine cleaning and maintenance activities on the sewer and MS4. The public continued to use the storm water hotline and e-mail address to report illegal discharges to the storm drain system. The Storm Water Protection Program responded to reports of illegal discharges and has been trained in water quality sampling techniques. Complaints of illegal discharges were documented and tracked in the City’s “Suite Response - Request for Action” (RFA) system. The RFA system was used each time there was a complaint through the hotline, email, in-person, or during field discovery related to an actual or potential illegal discharge. The Storm Water Protection Program is committed to responding in a timely manner to all illegal discharge reports. During FY 05-06, staff responded to 93% of reports of discharges “happening now” within 30 minutes. The Storm Water Protection Program responded to 107 reports of illegal discharges to the storm drain system. In addition, 420 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 Maintenance and Operations, Utility Operations, Construction Maintenance, and Streets Department. 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. There were 23 outfall sites routinely monitored by the storm water program. The City also continued to implement the Sewer Overflow Prevention Plan/Response Plan. The City responded to 19 sewage spills or overflow reports, with a total of 98 gallons recovered and approximately 1,509 gallons entering the environment. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 vi A Performance Measurement System has been implemented 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. For FY 05-06, the City plans to continue to collect data for the Performance Measures and Maintenance Assessment program and to analyze alternative work methods to improve the balance of scheduled versus unscheduled maintenance. This will include, but not be limited to, the use of contract services, temporary help, and/or consolidation of services with other Public Works departments. Section 9: Outreach and Education The 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. During FY 05-06, the City continued to be actively involved in outreach and education at 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 a new storm water educational brochure, continued an advertising campaign, collaborated with local non-governmental organizations, hosted or participated in 17 outreach events, and distributed information through various media. The City also distributed promotional items such as notepads, pens and key chains with pollution prevention messages. These new and existing printed materials, items, and electronic messages resulted in over 1,000,000 impressions. Section 10: Public Participation The City led and/or 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. During FY 05-06, the City also conducted a Public Opinion Survey of 1,000 residents that included questions about storm water pollution. During FY 05-06, the City’s Community Volunteer Coordinator continued to find volunteers to assist the Storm Water Protection Program with various activities, including cleanup and outreach events. The City continued to recruit students from the University of California, San Diego to participate in an 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. Section 11: Effectiveness Assessment Information collected in surveys, public comments, inspections, investigations, monitoring and other activities during the year were assessed to identify any trends and determine new or modified courses of action. During FY 05-06, the City continued participating in a Copermittee workgroup to draft common elements for effectiveness assessment and for the “Report of Waste Discharge.” The City made progress with effectiveness assessment measures during FY 05-06, using the Watershed Treatment Model to assess the effectiveness of storm water programs (Deb Caraco, Center for Watershed Protection). In addition, the City will continue to conduct monitoring programs in the MS4 and receiving water bodies to provide additional data to assess water quality. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 vii Section 12: Fiscal Analysis The total operating costs to fund the Storm Water Protection Program activities for FY 05-06 was $1,258,562. This includes actual expenditures for personnel and operating costs from the Storm Water Protection Program budget, along with costs for street sweeping and litter pick-up. However, this total does not include the Storm Water Capital Improvement Program costs. Section 13: Special Investigations Water quality data was collected for two special investigations conducted in FY 05-06. One is referred to as Performance Monitoring and collected samples on Agua Hedionda Creek (at the Mass Loading Station site) and three lagoon sites. The second was a special investigation at the City’s historic Leo Carrillo Ranch Park. Section 14: Conclusion During FY 05-06, the City successfully implemented the Permit requirements and the program activities described in the JURMP. Identified program strengths as well as improvement areas for FY 06-07 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 additional effectiveness measures, in addition to implementing the identified measures on program effectiveness within the City. The City will also be conducting a thorough review of all internal NPDES programs in FY 06-07 to ensure compliance with the Permit prior to implementing the new Order expected to be formalized in January of 2007. Information from JURMP activities, WURMP activities, as well as the 303(d) List indicated that bacteria, sediment and nutrients are constituents of concern in Carlsbad. The City proposes to continue addressing these constituents through a number of existing or new activities, which include education, inspections, monitoring and maintenance. I TABLE OF CONTENTS Executive Summary _______________________________________________________ i Section 1 Introduction___________________________________________________1 1.0 Overview 1.1 Report Organization Section 2 Municipal ____________________________________________________3 2.0 Overview 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 ____________________________________________________14 3.0 Overview 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 __________________________________________________28 4.0 Overview 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 __________________________________________________40 5.0 Overview 5.1 Threat to Water Quality Prioritization 5.2 Pollution Prevention 5.3 Best Management Practices Implementation 5.4 Enforcement of Residential Areas and Activities 5.5 Self-Assessment II Section 6 Land-Use Planning ____________________________________________50 6.0 Overview 6.1 Assessment of General Plan 6.2 Modification of Development Project Approval Process Actions 6.3 Revisions to Environmental Review Process Actions 6.4 Education on New Development and Redevelopment 6.5 Self Assessment Section 7 Construction _________________________________________________55 7.0 Overview 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 _______________________61 8.0 Overview 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 HHW and Oil Recycling Programs 8.6 Ordinance Enforcement 8.7 Spill Response and Sanitary Sewer System Maintenance 8.8 Self-Assessment Section 9 Outreach and Education _______________________________________74 9.0 Overview 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 (i.e. Educational Institutions, Water Districts, Sanitation Districts, etc.) 9.6 Self-Assessment Section 10 Public Participation ___________________________________________84 10.0 Overview 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 III Section 11 Assessment of JURMP Effectiveness _____________________________89 11.0 Overview 11.1 Targeted Outcomes 11.2 Self-Assessment Section 12 Fiscal Analysis ______________________________________________109 12.0 Overview 12.1 Storm Water Facility Capital Improvement Program 12.2 Storm Water Facility Maintenance and Operation Program 12.3 Storm Water Protection 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 12.7 Self-Assessment Section 13 Special Investigations _________________________________________112 13.0 Overview 13.1 Performance Monitoring Section 14 Conclusions and Recommendations _____________________________119 14.0 Overview 14.1 Highlighted Activities Performed to Meet Permit Requirements 14.2 Highlighted Activities in Addition to Permit Requirements 14.3 Highlighted Recommendations for Improvement 14.4 Water Quality Improvements or Degradation 14.5 Conclusion TABLES Table 3.1 SIC Groupings by Type and Priority Table 3.2 Industrial Businesses Rated for Each Score Table 3.3 Summary of Inspections, Corrective and Enforcement Actions Required at High Priority Industrial Facilities in FY 05-06 Table 3.4 Number of Industrial Enforcement Actions in FY 05-06 Table 4.1 Summary of Commercial Businesses for Source Types Table 4.2 Commercial High Businesses Rated for Each Score Table 4.3 Summary NOVs Issued to Commercial Businesses in FY 05-06 Table 4.4 Enforcement Actions at High Priority Commercial Businesses in FY 05-06 Table 4.5 Summary of Administrative Citations Issued in FY 05-06 Table 5.1 Constituents of Concern and Examples of Residential Sources Table 5.2 Items Collected During April 22, 2006 HHW Event. Table 5.3 Summary of Environmental Program Division Complaints Table 5.4 Targeted Neighborhood Education Table 5.5 Summary of Residential Enforcement Actions in FY 05-06 IV TABLES (Continued) Table 7.1 Summary of Enforcement Actions at Construction Sites in FY 05-06 Table 8.1 Number and Types of Environmental Programs Complaints/ Issues for FY 05-06 Table 8.2 Total Numbers of Issues in RFA for FY 05-06 by Department Responding Table 8.3 Total Numbers of Illegal Discharges and Illicit Connections Identified from Residential, Commercial and Industrial Sources Table 8.4 Locations in the Carlsbad that Accept Used Motor Oil for Recycling Table 8.5 HHW Amounts Collected at Permanent Facilities in FY 05-06 Table 8.6 HHW Amounts Collected by the Door-to-Door Program in FY 05-06 Table 8.7 Total Number of Enforcement Actions Taken for Residential, Commercial and Industrial Sources for FY 05-06 Table 8.8 Station Facility Maintenance Since FY 2003 Table 8.9 Sewer Main Cleaning Since FY 2003 Table 8.10 Volume of Spills Table 8.11 Volume of Spills Recaptured Table 9.1 Department and Positions for Job Specific Storm Water Training Table 9.2 Carlsbad Elementary Schools Watershed Awareness Program Table 9.3 Dates of Publication of the Environmental Programs Advertisement Table 9.4 Outreach Events for Residents, General Public, and School Children Table 10.1 Public Meetings Held During the Reporting Period Table 10.2 Community Events FY 05-06 Table 11.1 FY 05-06 Program Activity Measures Table 11.2 Results of Environmental Question 1. Table 11.3 Industrial Knowledge Assessment Scores from Inspections Table 11.4 Top Responses to “What things are you doing to reduce water pollution? Table 11.5 Industrial BMP Assessment Scores from Inspections Table 11.6 Comparison of Enforcement Mechanisms by Year and Percentage Table 11.7 Lawn Care Education Model Input Table 11.8 Loading Reduction from Existing Lawn Care Education Table 11.9 Pet Waste Education Program Model Input Table 11.10 Loading Reduction from Existing Pet Waste Education Program Table 11.11 Erosion and Sediment Control Model Input Table 11.12 Loading Reduction from Existing Erosion and Sediment Control Programs Table 11.13 Washoff Reductions for Weekly Street Sweeping Percentages Table 11.14 Street Sweeping Model Input Table 11.15 Loading Reductions from Existing Street Sweeping Activities Table 11.16 Illicit Connection Model Input Table 11.17 Loading Reductions from Illicit Connection Removal Table 11.18 Loading Reductions from SSO Repair/Abatement at 75% Target Table 11.19 Matrix of Current Monitoring Within City of Carlsbad Watersheds Table 12.1 Summary of Program Activities and Current Funding Sources Table 13.1 Water Quality Sampling Benchmarks Table 13.2 Water Quality Measure Results Table 13.3 Water Quality Measure Results 2003-2006 V FIGURES Figure 3-1 Discharge from Syntron Bioresearch Figure 5-1 Residential Pledge Card developed by the North County Outreach Work Group Figure 9-1 Solana Center Educator with Students Figure 13.1 Performance Monitoring Site Map GRAPHICAL DATA Chart 11.1 Types of Illegal Discharges FY 05-06 Chart 11.2 Bacteria Geometric Mean per Year Chart 11.3 Average Detergent Concentrations Chart 11.4 pH by Year Chart 11.5 Ammonia by Year Chart 11.6 Nitrate by Year Chart 11.7 Ortho-phosphate by Year Chart 11.8 Coastal Storm Drain Outfall 95th Percentile Exceedances Chart 11.9 Lagoon Receiving Water Exceedances Chart 13.1 Fecal Coliform by Site and Month Chart 13.2 Total Coliform by Site and Month Chart 13.3 Enterococcus by Site and Month Chart 13.4 TSS by Site and Month Chart 13.5 Turbidity by Site and Month Chart 13.6 Dissolved Oxygen by Site and Month VI APPENDICES Appendix 1 1-1 Acronyms Appendix 2 2-1 Municipal Inventory 2005-2006 2-2 Municipal Sites Mapped 2005-2006 2-3 FY 05-06 Storm Water Committee Meeting Topics Summary 2-4 Municipal Inspection Report Appendix 3 3-1 Industrial Inventory 2005-2006 3-2 Industrial Sites Map 2005-2006 3-3 SW-100 SIC Procedure 3-4 Streamlined Inspection Form 3-5 Notice to Clean 3-6 Notice of Violation Form Appendix 4 4-1 Commercial Inventory 2005-2006 4-2 Commercial Sites Map 2005-2006 4-3 Best Management Practices for the Mobile Service Industry Brochure Appendix 5 5-1 Household Hazardous Waste Door-to-Door Collection Brochure 5-2 Put Toxic Waste in Its Place Fact Sheet 5-3 Clean Sweep Street Sweeping Door Hanger 5-4 Public Work’s At Your Service Brochure 5-5 Pet Waste Brochure – Front Only Appendix 6 6-1 Discretionary Projects Subject to Priority Project Permanent Storm Water BMP Requirements 6-2 Development Services Training 2005-2006 Appendix 7 7-1 2005-2006 High Priority Construction Sites 7-2 Rough Pad Stabilization 7-3 Internal Construction Training 2005-2006 7-4 External Employee Training 2005-2006 VII APPENDICES (Continued) Appendix 8 8-1 Dry Weather Follow Up Report 2005-2006 8-2 Complaint Resolution Report 2005-2006 8-3 City Sewer Overflow Report 2005-2006 8-4 Leucadia Waste Water District Spills 2005-2006 8-5 Other Spills 2005-2006 Appendix 9 9-1 Municipal Employee Storm Water Training 2005-2006 9-2 2006 Annual Drinking Water Quality Report 9-3 Pledge Card 9-4 Solana Center Classes Flyer 9-5 Environmental Programs Ad Recycle 9-6 Environmental Programs Ad Conserve 9-7 Environmental Programs Ad Dispose 9-8 Environmental Programs Ad Prevent Appendix 12 12-1 Storm Water Budget 2005-2006 Cover photographs courtesy of: Chris Adams Deborah Lea Nancy Lucore City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 1 Section 1 Introduction 1.0 Overview The City of Carlsbad’s (City) 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 Copermittees listed in the Permit was required to develop 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 fifth Annual Report details the activities conducted during the reporting period of July 1, 2005 through June 30, 2006, which corresponds to the City’s Fiscal Year 2005-2006 (FY 05-06). The Permit also 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 is a municipal corporation, following the Council-Manager form of government. City Departments fall under one of five major service areas (MSA’s): Public Safety, Administrative Services, Public Works, Community Development, and Community Services. While the City created the Storm Water Protection Program to help implement the Permit, program implementation is carried out by several departments within different MSA’s. This allows for program implementation and new requirements to be incorporated into daily activities of City employees, instead of being viewed as completely new requirements without a connection to on-going services. The City 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 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 more intertwined as waterbodies and implementation strategies cross programmatic and jurisdictional boundaries. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 2 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 effective in reducing urban runoff pollutants and flow; identification of water quality improvements or degradation; and a budget for the upcoming year. A list of acronyms is provided in Appendix 1-1. 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 Permit and the 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, 2005 – June 30, 2006 3 Section 2 Municipal Component 2.0 Overview The City’s municipal facilities are composed of administration buildings, recreational areas, buildings, maintenance yards, reservoirs, water pump stations, sewer lift stations, road systems, parking facilities, the storm drain system, pressure regulator vaults, and fire stations. These are areas where municipal staff work or provide public services. 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 have the potential to contribute to urban runoff if BMPs are not properly implemented, maintained, and assessed. The City has implemented a program to prevent or reduce pollutants in urban runoff from 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. Prioritization of municipal facilities was determined by type of activities conducted onsite, proximity to an Environmentally Sensitive Area (ESA), compliance inspections, wastes generated, and pollutant discharge potential (see criteria in Section 2 of the JURMP). As pollutant sources are abated and discharge potential decreases, the municipal facilities priority ranking may change. However, if a facility is designated as high priority as defined by the Permit (e.g., corporate yards) it will not be reprioritized on the inventory list. During FY 05-06, 13 facilities were designated and inspected as “high” priority municipal facilities. Municipal facility locations were mapped by first geocoding each location's address against the City 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. A copy of the mapped High Priority municipal facilities is found in Appendix 2-2. 2.2 Pollution Prevention Practices and Best Management Practices Implementation The City’s approach is to promote pollution prevention as an activity for all municipal employees and locations. Since 1991, the City has implemented a procurement policy that directs the purchase and use of recycled products. Purchasing staff are 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. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 4 Specific pollution prevention measures may vary from one site to another, so they are evaluated separately at each facility. All high priority municipal facilities implemented site specific Storm Water Pollution Prevention Plans (SWPPP) and associated training programs. Furthermore, the pollution prevention BMPs identified in the JURMP were implemented at all municipal facilities. These pollution prevention BMPs include: • Affirmative Procurement – Use alternative, safer, or recycled products. • Reduce the amount of hazardous materials by implementing natural controls. • Redirect storm water flows away from areas of concern. • Reduce use of water. • Reduce storm water flow across facility site. • Recycle and reuse waste products and waste flows. • Move or cover potential pollution from storm water contact. In addition, the City required the following minimum pollution prevention practices (detailed in SWPPPs or inspection reports) at all municipal 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 for City contractors. • Redirect storm water flows and conduct storm drain maintenance: Employees perform regular visual inspections of the storm drains to identify unauthorized discharges and clean as needed. • Recycle: City departments must recycle appropriate items and implement the City procurement policy to purchase and use recycled products. • Move or cover potential pollution sources from storm water contact: Corporate yards protect materials and products that could potentially contribute to storm water pollution by storing them indoors, or covering them, and providing them with secondary containment as needed. In April 2006, the City purchased battery recycling containers for employee use. These new containers have been placed at various locations throughout the City and are maintained by the General Services staff. The battery recycling containers have provided an excellent pollution prevention opportunity for City employees. The Storm Water Committee continues to meet monthly to discuss municipal storm water BMPs and pollution prevention issues. The committee is comprised of City employees representing various divisions of Public Works, the Fire Department, and the Building Department. The intent is to communicate problems and solutions, share knowledge, enhance conformance with the Permit, and to pass along updates from the Regional Board. Agendas were distributed in advance and meeting summaries were sent to members and appropriate managers after each meeting. A summary of discussion items is found in Appendix 2-3. 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. Specific BMPs are identified in SWPPPs and/or inspection reports. Specific pollution prevention measures may vary from one site to another and are evaluated separately at each facility. The City implements and assesses the effectiveness of BMPs through regular staff training, self-inspections, third party inspections by a contractor, and SWPPP implementation. The following includes a description of specific pollution prevention activities and storm water BMPs implemented during FY 05-06 by various City departments and facilities. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 5 Maintenance and Operations, Construction/Maintenance Division The Maintenance and Operations, Construction/Maintenance Division is responsible for maintaining the water, sewer, and recycled water infrastructure for the City. This division carries out the preventive maintenance programs as well as emergency response for line breaks and spills. Those involved with Maintenance and Operations (M&O) activities received training on waste minimization techniques for hazardous and solid waste, spill prevention, response and cleanup practices. Following are some of the new and ongoing BMPs implemented for FY 05-06: • Native soils are used whenever possible to backfill trenches. • Staff has minimized the amount of dirt and soil stockpiled onsite. • Gravel bags have been placed along the downstream flow path to reduce the silt. • “Gutter Buddies” have been installed and maintained at all storm drain inlets. • Standardized BMPs for “Potable Water Discharges” have been implemented. • Approximately 400 tons of Recycled - Class II - Base Material was used to backfill trenches. • Approximately 100 tons of Asphalt/Cement wastes were hauled to Hanson Aggregates for recycling into Class II base. This is a substantial increase over previous years. • Silt fences and other slope BMPs were improved and reinstalled to protect the outdoor storage yard from additional erosion. • A rock shaker plate was installed at the driveway entrance to the storage yard to prevent dirt or mud tracking onto the parking areas. The driveway ramp going from the parking lot to the pipe yard was replaced and the rock shaker driveway was also rebuilt. • Gravel bags, sand bags, silt fences, hay rolls were purchased for the outdoor storage yard. Approximately $2,468 was spent to purchase these new and improved BMPs. • Oil and fuel storage was relocated to a designated area with 290 gallon catch containment area. • Per the City’s JURMP, BMP implementation guidelines, material usage inventories continued to be decreased in FY 05-06. Approximately 69 tons of metal fittings inventory were recycled. • Approximately 1,050 tons of recycled asphalt was used to patch/repair streets and rights of way. • A concrete area was created where offsite flow enters the property to slow down the velocity of storm water and reduce erosion prior to entering the storm drain. • Rock was used to diffuse the flow and reduce erosion. • The M&O SWPPP and site map was revised to detail all equipment and materials storage within the facility and provide the amounts of material stored for construction purposes. Fleet Maintenance Fleet Maintenance Division (Fleet) provides routine preventive maintenance and repairs for all City vehicles and equipment. Fleet also performs smog inspections, responds to roadside service calls for City vehicles, and supplies the fuel and maintenance service for City vehicles and the Encina Wastewater Authority. The following are pollution prevention and BMP implementation efforts for FY 05-06: • A designated pressure washer area continues to be used to wash vehicles, engines, and undercarriages. The pressure washer drain discharges to a separator then to sanitary sewer. • A floor scrubber and mop were used to clean the repair shop floor. Wash water is disposed of inside the shop to the sanitary sewer. • Oil, fuel, antifreeze, or other liquids spills were cleaned with absorbent and put into marked drums, which were removed by a contracted hazardous waste hauler. • Used batteries were stored in plastic containers and picked up weekly. • Brake shoe cores were stored in plastic containers until returned to the vendor for recycling. • The public waste oil disposal site has been closed and the tanks moved and covered pending removal from the yard. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 6 • Drip pans were used to capture leaks from vehicles stored outdoors. Spills are cleaned up using absorbent, which is then stored in marked containers and removed by the hazardous waste hauler. • Recycled oil is purchased for use in fleet vehicles, and used oil is recovered for recycling. • Recycled antifreeze is used and waste was stored in poly drums inside the shop. Fleet recycled 300 gallons of antifreeze during FY 05-06. • All scrap metal was recycled at a local scrap metal supply shop. • Training was conducted on BMPs, inspection intervals, and basic house keeping. • Fleet BMPs were amended to include inspection of the outside area including the waste oil drop off area, dumpsters, and the hazardous waste bunker. • A revised site map was been developed and included in the SWPPP. Oak Maintenance Yard The Streets Department operates out of the Oak Maintenance yard and is responsible for the maintaining approximately 582.4 lane miles of roadway, 6,683 streetlights, 149 signalized intersections, over 5,000 storm drains and inlets, and all sidewalks in the public right-of-way. In addition, the Storm Drain Maintenance Crew operates out of this yard and manages the street sweeping contract for all public streets. The following are pollution prevention and BMP implementation efforts for FY 05-06: • A new bio-swale was created and the majority of surface storm water flow from the maintenance yard has been redirected to the swale. • All materials and machinery were covered or enclosed with new canopies. • Maintenance yard cleaning and sweeping was increased to weekly. • One hundred sign blanks were used to install/replace street signs. • The following amounts and types of material were recycled during this reporting period: o 880 tons of asphalt used for patch/repair on streets and rights of way. o 227 tons of cement used for patch/repair on sidewalks. o Over 500 pounds of aluminum signs were recycled or reused. 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. The Fire Department implemented the following BMPs in FY 05-06: • Fire Department staff began attending the Storm Water Committee meetings on a regular basis. • When possible, awareness was heightened at fire scenes to minimize the potential for excessive water flow. • Awareness was also heightened at incident scenes to contain potential discharges once the scene had been stabilized to prevent pollutants from entering the storm drain system. • The Fire Department continued to implement the new spill response procedure for incidents that occur on City streets. • The Fire Department began working more closely with the Storm Water Protection Program to conduct a series of meetings to review BMP implementation and perform one-on-one training. Parks Maintenance Division The Parks Maintenance Division is responsible for maintaining, preserving, and enhancing approximately 346 acres of parks, athletic fields, streetscapes, beach accesses, and landscapes at various civic facilities. This includes the maintenance of 16 neighborhood or community parks, 14 special use areas, and over 625 acres of open space/undeveloped areas. During this reporting period, staff addressed the improvements recommended by the Storm Water Protection Program, D-Max Engineering, and in-house quarterly inspections. The following pollution prevention BMPs were implemented in FY 05-06: City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 7 Parks Maintenance Yard • Trees and vegetation near storm drain discharge areas were trimmed more frequently than trees located in other areas. • Rock gravel bag collars were installed around storm drain outlets. • Bare or sparsely vegetated pervious areas were landscaped to prevent erosion. • Irrigation frequency was decreased by utilizing multiple starts with fewer days. • An annual yard clean-up was completed. Trash, unused materials, and excess equipment was discarded and disposed of in a proper manner. • All water holding containers were inverted to prevent stagnant water discharges. Park Maintenance (all park yards and parks) • All organic debris from landscaping was blown away from curbs, gutters, and parking areas and recycled during the mowing process. • Organic material was minimized by double cutting areas to reduce the accumulation of thatch. • Sweeping equipment was used to pick up leaves and debris in turf areas. • All irrigation systems were inspected weekly and repaired as necessary to prevent excess runoff. • A weekly clean-up and quarterly inspection program was implemented for all yards and parks. • All pertinent BMPs were combined into personalized folders for individual employee use. • Bi-weekly storm water training was performed and documented. • A master manual was prepared for all maintenance sites and storm water related activities (Training/ Inspection/ BMPs, etc). Poinsettia Park Maintenance Facility • The synthetic turf soccer field has resulted in minimal maintenance with no watering requirements or chemical applications. • Straw wattles were installed around the maintenance yard fence line for erosion control purposes. • Equipment is regularly cleaned or washed on pervious dirt areas to prevent runoff. • The maintenance yard is cleaned up weekly. • New gravel bags were installed at all storm drain discharge inlets. Stagecoach Park Maintenance Facility • Stagecoach Park was retrofitted with synthetic turf on fields two and three. With this addition, watering requirements were greatly reduced. • The dirt storage lot was resurfaced with new asphalt and asphalt curb. • Three new canopies were purchased to cover equipment and materials. • All paint and chemicals stored onsite were secured in new storage lockers. In addition, spill containment trays were purchased for the storage lockers. • New fuel storage lockers were purchased. The Parks Maintenance Division continues to utilize chips generated from tree trimming activities for erosion control and weed abatement on banks, slopes, and bare ground. Staff purchased and replaced the deteriorated straw tubes on the slopes at Buena Vista School, Magnolia School, Carlsbad High Tennis Courts, Poinsettia Park maintenance yard, and La Costa Canyon Park. Straw blankets were also utilized wherever applicable. In addition, the Parks Maintenance Division purchased ornamental chips and bark for use around buildings and high profile landscape areas. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 8 2.3 Maintenance of Municipal Separate Storm Sewer System (MS4) The Storm Drain Maintenance Crew is responsible for inspecting, cleaning, and performing routine maintenance of the City’s MS4. The City implements BMPs for maintenance activities with an emphasis on preventing and reducing the quantity of pollutants entering the MS4. In addition, the Streets Department generally performs minor repairs and limited construction activities on certain MS4 structures. The Streets Department and M&O also collect and properly dispose of all waste resulting from storm drain maintenance. The maintenance of the MS4 involved multiple activities, which are summarized below. Catch Basin/Inlet Cleaning There are currently 3,671 catch basins and inlets in the City and approximately 3,000 of these inlets are stenciled with storm water protection messages. Set criteria were used to prioritize the inspection process with an emphasis placed on those catch basins in high traffic areas. If during inspection, a basin or inlet was observed to have any obstruction, debris was removed with an inlet plucker from ground level. Further cleaning by a vactor truck occurred as necessary. In FY 05-06, staff inspected and cleaned 1,200 basins and inlets and removed 24 tons of material. In addition, 35 debris catchers were installed in inlets and 45 fossil filters were installed city-wide. In FY 04-05, the City approved the purchase of a trailer mounted vacuum system to be used solely for storm drain maintenance activities. During FY 05-06, this dedicated equipment increased efficiency for the storm drain maintenance program as well as reduced the need to share vacuum equipment with M&O. Curbed Streets and Uncurbed Roads Street sweeping is conducted by subcontractors who collect, manage, and dispose of swept materials as well as maintain sweeping equipment. During FY 05-06, 13,000 miles of roadway and all public parking areas were swept annually. All sediment and debris was removed and transferred to an approved disposal site. In addition, the litter removal program continued as a full-time, year-round program, consisting of a two-person crew. The crew removed approximately 1,150 cubic yards of litter and debris. In FY 04-05, the Streets department reported that parked vehicles were interfering with the street sweeping program. It appeared that residents were not removing their vehicles from the street during regular street sweeping schedules. The vehicles made it difficult for the street sweeper to access all areas of the street. In March 2006, the City developed a new street sweeping notification door hanger. The door hanger was developed to help notify residents of street sweeping schedules so that they can move their cars and allow the street sweeper better access to clean the curb face and gutter. A copy of the street sweeping door hanger can be found in Appendix 5-2. Open Drainage Facilities In accordance with the JURMP, all identified open drainage facilities were inspected and cleaned during FY 05-06. The City has established an ongoing regular voluntary program for the collection of debris and trash in natural stream and storm drain channels. Storm drain channels were inspected and cleaned as necessary. Maintenance of the MS4 is a shared responsibility between residents and the City. All storm drain channels located on private property are the responsibility of private property owners. Therefore, it is not possible for the City to clean or inspect all channels that discharge into the public MS4. The City does however maintain those portions of private storm drain structures that are within 10 feet of the curb face or City right-of-way. During FY 05-06, the Storm Drain Maintenance Crew inspected and cleaned only those channels that required maintenance. The City will work with the Copermittees to address storm channel maintenance activities and to pursue permitting to conduct future maintenance. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 9 Currently, there is an estimated 23,500 lineal feet of public brow ditches in Carlsbad. In FY 05-06, the City reviewed the previously reported 89,760 lineal feet of brow ditches and determined that approximately 23,500 lineal feet were publicly owned. Maintenance of the MS4 is a shared responsibility between residents and the City. All brow ditches located on private property are the responsibility of private property owners. The City does however maintain those portions of private brow ditches that are within 10 feet of the curb face or City right-of-way. During FY 05-06, the Storm Drain Maintenance Crew inspected and removed 6.5 tons of sediment and debris from those brow ditches that required maintenance. As required by the JURMP, the following storm drain channels were inspected and 600 pounds of trash was removed prior to the wet season: • Buena Vista Channel • Kelly Drive Channel • Park and Kelly Outfall • Park and Andrea Outfall • Park and Valencia Outfall • Park and Neblina Outfall Desiltation Basins During FY 05-06, all three publicly owned desiltation basins were inspected and 200 pounds of trash was removed. The three desiltation basins that are the responsibility of the City include: • Desiltation Basin #13 (23,000 square feet) - SW end of Faraday Ave., south of Lot 102 of CRC • Desiltation Basin #43 (50,000 square feet) - Camino Hills and Faraday, NE corner • Desiltation Basin # 30 (1,500 square feet) - SW corner of Marron and Monroe In addition, during FY 05-06 the City conducted 56 inspections of privately owned desiltation basins in an effort to rate the quality, location, and maintenance needs of each basin. This information was documented and may be used to further develop and implement an outreach program for private property owners. Storm Patrol During storms, street crews were dispatched to handle storm related emergencies in a timely manner. Each crew was assigned to a pre-determined zone to respond to emergencies and to check inlets and outfalls for blockages. After the storm event, street crews primarily handled emergencies, maintained proper water flow, protected the natural waterways from contamination, and ensured public safety. Major debris removal and storm clean up was performed after emergencies were resolved. In FY 05-06, staff spent 220 staff hours at various locations throughout the City. 2.4 Management of Pesticides, Herbicides, and Fertilizers Actions Parks Maintenance Division In conjunction with the Integrated Pest Management (IPM) program, the Parks Maintenance Division continued to utilize slow release fertilizers in an effort to reduce the frequency of applications while minimizing the potential of fertilizer runoff. In some cases, staff reduced the recommended amount of fertilizer per 1,000 square feet by 50% to minimize flush of growth on turf which in turn reduced the amount of clippings. To help monitor fertilizer applications, the Parks Maintenance Division began using fertilizer reports to track material applied, rates, and locations. In accordance with the new IPM practices, weed control applications were withheld at several school sites maintained by the City. Staff is continuously searching for alternative methods of pest control that are proven to be safe and effective. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 10 As required by the DPR, all chemical applications are reported to the County Agriculture Department on a monthly basis. The Parks Maintenance Division currently has 17 Certified Qualified Applicators on staff. As identified in the JURMP, all BMPs were implemented to address pesticide, herbicide, and fertilizers sources of pollution. Specifically, BMPs implemented during FY 05-06 include: • Education: A training program for identifying and defining chemicals, proper handling, applying, storing, disposing, irrigating, and using non-synthetic alternatives has been implemented. All training information including BMPs were provided to personnel to keep in personalized folders for individual use. In addition, a master application manual that includes all storm water BMPs, training, and inspections was also prepared. • Non-chemical applications: Some pest problems can be eliminated or controlled by handpicking, pruning, or spraying with water. Many pest problems can be reduced or eliminated by removing affected leaves or plant parts. During FY 05-06, organic material in turf (which attracts pests) was minimized by double cutting areas to reduce accumulation of thatch. At Poinsettia Park synthetic turf was used on the soccer field, which requires minimal maintenance and no chemical applications. Insecticide application is performed on an as needed basis and is usually contracted out to a pest control operator after diagnosis. • Native Vegetation: The Parks Maintenance Division continues to explore opportunities to use native vegetation to control pests, reduce chemical application, and maintain the aesthetic values of the Parks and medians. • Schedules for Irrigation and Application – Irrigation systems are monitored and inspected on a weekly basis in an effort to minimize water loss due. In addition, the use of evapo-transpiration (ET) gauges for controlling the irrigation system helped to reduce watering times based on evaporation and transpiration of plants and turf. ET gauges are installed at Poinsettia, Stagecoach, and Calavera Park. These gauges also helped staff to adjust watering times at other locations that were not connected to the gauge. During FY 05-06, all irrigation systems were inspected weekly and repaired as necessary to prevent excess runoff. At Poinsettia Park synthetic turf is used on the soccer field, which requires minimal maintenance and no watering. The synthetic turf has proven to be successful in eliminating the use water for irrigation. 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 use Roundup employees are 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 and Measures requirements. Roundup is used for minor weed control six to eight times per year. After usage, quantities applied are reported to the County of San Diego Department of Agriculture. Other mechanical control methods (i.e. shovels, hoes) are used whenever possible. 2.5 Inspection of Municipal Areas and Activities The Storm Water Protection Program conducted pre-inspections at all “high” priority municipal facilities. The purpose of the pre-inspections was to ensure all facilities were ready for the formal inspection and had the proper documentation in order. These pre-inspections were also an excellent opportunity to facilities coordination and interdepartmental communication. D-Max Engineering (D-Max) was contracted to conduct formal storm water compliance inspections for all of the high priority municipal facilities during FY 05-06. During each inspection, the D-Max inspectors reviewed the municipal facility’s SWPPP, BMP implementation plans, and facility self-inspection records. 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. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 11 After the inspection, an inspection report that included corrective actions, recommended BMPs, and other relevant information was provided to the facility manager. Copies of the inspection reports are on file at the facility and with the Storm Water Protection Program. The facility manager then addressed any recommendations or requirements. Documentation of self-inspections and corrective actions are maintained in files at the appropriate facility. The summary of all inspection report recommendations and facility corrective actions are listed in Appendix 2-4. 2.6 Enforcement of Municipal Areas and Activities Actions Runoff from municipal facilities may pose a threat to water quality if BMPs are not adequately implemented or maintained. BMP implementation and assessment occurs through facility self- inspections, third party inspections, and through on-going employee training. 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 05-06, however the Public Works Director sent each high priority municipal facility a letter requesting that all corrective actions be implemented in a timely manner. The Public Works Director also conducted followed up site visits to the high priority municipal facilities to ensure compliance. 2.7 Self-Assessment Program Strengths During FY 05-06 every edition of Public Works departmental newsletter featured updates on the Storm Water Protection Program and Environmental Programs. Employees were notified by e-mail when these newsletters were published and posted on the City’s intranet, and hard copies were given to employees who did not have access to computers. During the spring of 2006, the Environmental Specialist II, the Water Conservation Specialist, and the Storm Drain Maintenance Crew completed the eight hour “Hazardous Waste Operations and Emergency Response Training” in San Diego. This course is designed for employees that are expected to identify emergency situations involving hazardous materials. Staff was trained to recognize, report, and assist in emergency response. This course fulfills the requirements under OSHA 29 CFR 1910.120. In May and June of 2006, the Public Works Director participated in several commercial and industrial storm water inspections with Environmental Programs staff. During the inspections, the Public Works Director received additional and current information about inspection procedures, storm water compliance issues, enforcement actions, and general inspection –related issues of concern in the City. In addition, the Public Works Director also accompanied staff during the storm drain maintenance and inspection activities and water quality monitoring activities. In March 2006, the City developed a new street sweeping notification door hanger. The door hanger was developed to help notify residents of street sweeping schedules so that they can move their cars and allow the street sweeper better access to clean the curb face and gutter. The City continued the monthly meetings of the Storm Water Committee, with representatives from Public Works, Public Safety and the Building Department. This committee allows the sharing of ideas and issues with storm water pollution prevention, BMPs and training. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 12 The City continued to contract out high priority municipal inspections in order to provide an outside set of eyes for inspecting and determining compliance. These inspections were unannounced in order to best assess compliance. With the annual inspections by the State DPR, municipal inspections by D-Max, in- house quarterly inspections, and staff training on storm water BMPs, staff were more aware of the required BMPs for preventing storm water pollution. During FY 05-06, the Storm Drain Maintenance Crew continued attending the weekly Storm Water Protection Program staff meetings. Their attendance at these coordination meetings has facilitated information sharing and problem solving within the program. The Storm Water Protection Program, in coordination with other City departments, continued to implement the Spill Response and Cost Recovery Plan procedure to define the process for protecting the storm drain system and environment through a coordinated response to spills and releases of potentially hazardous materials on public property or right of ways. This procedure applies to the City personnel who may be involved in spill prevention, containment and response activities. Whenever possible, the cleanup of non-hazardous materials is conducted by the responsible party (industrial, commercial, or residential) while cleanup of hazardous materials (in all cases) will be conducted by a licensed waste hauler or under the direction of the San Diego County Hazardous Incident Response Team (HIRT) in accordance with the Joint Powers Agreement with the City of Carlsbad. Program Improvement Areas The City’s Fleet Department historically served as a location where the community could dispose of used motor oil. Since 2002, the City no longer offers disposal at that location. Signs were placed to remind residents of this change. However, the signs have not been updated since 2002 and do not reflect the Environmental Programs logo, phone number, website, or appropriate disposal locations. As a result residents continue to illegally drop off used motor oil and other household hazardous waste at the Fleet gate. The Environmental Programs Division is working with the Fleet Department to develop more appropriate and accurate signs. Toward the end of FY 05-06 a formal “Catch Basin Inspection Program” was established. The City has reassigned resources and improved a work order system so that inspections and cleaning of catch basins could occur on a routine and scheduled basis. As a result of this formal program, the City expects that 100% of catch basins will be inspected and cleaned as needed during FY 06-07. This program is scheduled to begin in July 2006 and will be discussed during the next reporting period. During FY 05-06 the City conducted 56 inspections of privately owned desiltation basins in an effort to rate the quality, location, and maintenance needs of each basin. This information was documented and may be used to further develop and implement an outreach program for private property owners. During FY 06-07, the City will be updating and mapping all desiltation basins within the City. This information will be used to assess the status of each basin and work with private property owners to develop more proactive maintenance schedules. The Storm Water Protection Program staff began working with the City Attorney’s office to revise the City’s ordinance to reflect current enforcement levels and mechanisms. Revision and Council approval should be complete by the end of FY 06-07. Storm Water Protection Program and Environmental Programs Division will be working with the Information Technology Department to revise the City’s webpage and provide updated information about storm water BMPs. The webpage updates should be completed by the end of FY 06-07. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 13 Although all “high” priority municipal facilities have SWPPPs in place, the Storm Water Protection Program will be working with these municipal facilities to develop standardized SWPPPs, spill response plans, and training programs. The Fire Department will consider the following improvements for FY 06-07: • Initiating a new policy on vehicle washing to include no discharge of wash water to the storm drain system off fire station property. Options include using sandbags or temporary berms to divert wash water to landscaping, or washing vehicles at the City’s permanent vehicle washing facility at Fleet. • Creating a comprehensive program for each station to include an updated facility-specific SWPPP, Spill response procedure, training records, inspection records, and related materials. • Conducting storm water training as needed but no less frequently than annually. • Consideration of creating a storm water committee specific to the Fire Department consisting of Fire Department staff. • Updating the inspection program to include annual self-inspections prior to the rainy season. • Consider finding a location for the engineer’s test to reclaim the water. The City will continue to work with Copermittees to address storm channel maintenance activities and to pursue permitting to conduct future maintenance. The Regional Board is currently revising the language and procedures outlined in the Permit. When the Permit is reissued, the City will ensure that the appropriate municipal employees understand the new Permit guidelines, compliance issues, and address any concerns municipal employees might have about the new Permit requirements. The Storm Water Protection 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 facilities. A dedicated storm water database would help the program function efficiently and effectively, and allow for better tracking and reporting of effectiveness measures. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 14 Section 3 Industrial Component 3.0 Overview The City continues to track, inspect, and monitor all industrial facilities within its jurisdiction. Major industry types in Carlsbad include airport services, refuse and sewage management, a power plant, pharmaceutical research and development, golf equipment manufacturers, and several light industry parks. The City has implemented a program to inspect industrial facilities, ensure compliance, and reduce pollutant runoff. During FY 05-06, the City maintained an inventory of 473 industrial facilities. During FY 05-06, the City updated the industrial inventory, mapped all industries, and inspected all high priority industries, 121 medium industries, and 179 low priority industries. There were 51 “High” priority industries on the inventory at the end of FY 05-06. Of those 51, 41 inspections were required to be conducted and all 41 High Priority industrial sites were inspected in FY 05-06. The change between 51 inventoried High Priority industrial sites and the 41 inspections conducted is accounted for as follows: • 2 moved, • 3 were out of business, • 1 was excluded, • 4 were reclassified to lower priorities because of low potential threat to water quality. The remaining 41 “High” priority industrial sites were inspected in FY 05-06 and represented 35 individual businesses on the Storm Water Inventory. The total high, medium and low priority inspections conducted in FY 05-06 equaled 351. These 351 inspections not only included physical inspections, but also reviews, phone contacts, and drive by surveillance to determine business status, provide education and outreach materials, and require BMP implementation in accordance with the City ordinance, Permit, and/or General Industrial Storm Water Permit (General Permit). These activities are described in the following subsections. 3.1 Source Identification and Threat to Water Quality Prioritization Storm water inspectors identify pollution sources, assess their threat to water quality, and require the implementation of BMPs to eliminate sources at industrial facilities. The Storm Water Protection Program works closely with the Finance Department to obtain accurate information about new business activities, types (home based or commercial locations), contacts, and other related data. Each quarter, the Storm Water Protection Program downloads, sorts, maps, and prioritizes these new businesses. These new businesses are then added to the inventory list and scheduled for inspection. In some cases information provided on business license applications is not correct and other information must be gathered before an inspection can be scheduled. These pre-inspection evaluations help the City determine if a business’ activities are subject to the Storm Water Protection Program’s inspection requirements. The two types of pre-inspection evaluations the Storm Water Protection Program uses are: 1. Reviews: Business license and other relevant information reviewed to determine whether the businesses should be inspected by the Storm Water Protection Program. 2. Telephone Contacts: If the review fails to provide enough information about the business, the business in contacted by phone to determine their status and schedule an inspection if necessary. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 15 After physical inspections, reviews, or telephone contacts any changes to a business’ priority or status were recorded on the Storm Water Inventory List and in the Permits Plus database. The FY 05-06 year- end inventory is in Appendix 3-1. Data related to industrial businesses is managed on a continual basis as per departmental procedures and JURMP requirements. All documents related to industrial businesses were filed according to priority and status (active, inactive, excluded, or out of business). Appendix 3-2 contains a map of all prioritized industries on the current inventory. In February 2006, the SIC code procedure was revised. The revision included the addition of new SICs and the removal of others found to be non-applicable. A copy of the SIC procedure can be found in Appendix 3-3. At the end of FY 05-06, the inventory included 51 high priority, 177 medium priority, and 245 low priority industries. Table 3.1 provides a summary of industrial facilities for source type. A total of 28 SIC code groupings related to industrial high and medium facilities were identified. Table 3.1: SIC Groupings by Type and Priority Industrial Sector Ind High Ind Med 0782: Landscape Counseling 1 0 1500: General Contractor 1 0 1700: Special Trade Contractor 1 0 20XX: Food and Kindred Products 1 11 2261: Finishers of Broad Woven Fabrics 0 2 23XX: Apparel and Other Finished Products 0 7 2431: Millwork, Veneer, Plywood, Etc. 1 1 2434: Wood Kitchen Cabinets 0 1 24XX: Lumber and Wood Products 0 1 25XX: Furniture and Fixtures 0 4 2675: Die-Cut Paper, Paperboard, and Cardboard 1 0 27XX: Printing, Publish, and Allied Products 0 16 28XX: Drugs 3 11 28XX: Chemical and Allied Products 3 1 30XX: Rubber and Miscellaneous Products 0 2 3199: Leather Goods, NEC 0 1 3299: Pressed and Blown Glass 0 1 3231: Glass Products Made of Purchased Glass 1 1 3241: Cement Hydraulic 1 0 3355: Rolling and Drawing of Non-Ferrous Metal 0 1 34XX: Fabricated Metal Products Except Machinery 0 7 35XX: Industrial and Commercial Machinery and Computers 0 21 36XX: Electronic and Other Electrical Equipment and Components 1 21 37XX: Transportation Equipment, Including Boat and Building Repair 0 4 38XX: Measuring, Analyzing, and Controlling Instruments 0 25 39XX: Miscellaneous Manufacturing 4 18 4119: Local Passenger Transportation, NEC 2 0 42XX: Motor Freight Transportation and Warehousing 3 0 42XX: Public Warehousing and Storage 1 16 45XX: Transportation By Air 19 0 49XX: Electric, Gas, and Sanitary Services 6 0 5199: Non-Durable Goods 1 0 TOTAL 51 177 City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 16 3.2 Pollution Prevention Pollution prevention activities are proactive approaches industries can take to identify and reduce sources of pollution. Proactive pollution prevention when framed in the context of appropriate BMP identification, use, and maintenance is a key component to improving regional water quality. Pollution prevention measures are specific to industrial types and activities. Industries were informed of pollution prevention opportunities during site inspections, in outreach materials, and through correspondences. City inspectors required the following minimum best management practices (detailed in individual facility inspection reports and/or brochures) for all industrial facilities. • 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 General Permit requirements. • Use dry cleanup methods. Washing or cleaning activities that involve the use of a water hose or pressure washing system require the use dry clean up methods (mops, brooms, rags or wire brushes to clean pavement, buildings and equipment as much as possible). • 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. Industries may be required to modify downspout locations in order to redirect storm water flows away from potential pollutant sources. • Trash Management. Sweep up around dumpsters and other areas to prevent trash and debris from accumulating. Dumpsters must be kept closed when not in use. All trash must be kept in appropriate sized containers until it can be hauled away. • Recycle, Reduce and Reuse. Recycle cans, bottles, newspaper, office paper, and cardboard whenever possible. When inspecting solid waste collection areas, inspectors noted if recyclable materials (cardboard, green waste, etc.) were placed in dumpsters. All high priority industries were required to develop and implement a Storm Water Pollution Prevention Plan (SWPPP). In addition, some medium and low priority facilities were also required to develop and implement SWPPPs if their activities had the potential to contribute to storm water pollution. These businesses were usually given 60-90 days to develop and submit the SWPPP to the Storm Water Protection Program for review and approval. During follow up compliance inspections, businesses were required to show documentation that the SWPPPs had been implemented as required. If the inspector found deficiencies, the facility operator was required to revise the SWPPP and ensure compliance procedures and BMPs were implemented as outlined in the plan. The City continued to provide a sample SWPPP template to industries as a guide for preparing site specific plans. The sample SWPPP was also provided upon request when the current SWPPP was found to be deficient. 3.3 Best Management Practices Implementation The City required all industries to implement the minimum BMPs and specific BMPs applicable to industrial activities. BMP information was made available during inspections, in printed materials and direct mailings, at workshops, on the storm water website and hotline, during presentations, and at outreach events. A complete listing of all education and outreach events held during FY 05-06 can be found in Section 9 of this report. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 17 Printed Material and Direct Mailings During FY 05-06, the City continued to distribute the “Best Management Practices for Businesses – Commercial and Industrial” brochure containing the list and description of the required minimum BMPs. Over 300 of these brochures were distributed during FY 05-06. Inspections and Site Visits Industrial operators select and implement appropriate source and treatment control BMPs as directed by the Storm Water Protection Program, City Planning Department, and/or City Engineering Department. BMPs are considered effective if they address the pollutants of concern and are specific enough to prevent or reduce the likelihood of an illegal discharge. The City may require BMP implementation based on problems identified during site inspections. All industrial facilities were required to implement minimum BMPs, those identified for specific industrial activities, or as directed by the City. During FY 05-06, the City revised the streamlined inspection report to facilitate prompt and proactive correction of violations. The revised streamlined inspection form now includes space to report previous enforcement actions, new storm water contacts, and a detailed list of required corrective actions. The revised form has proven to be time saving, cost effective, and successful in attaining compliance from regulated facilities. Detailed inspection reports also continue to be used for businesses that have not been previously inspected or if the facility requires a more complex inspection (i.e. high priority facilities, egregious violators). If corrective actions were required, follow-up inspections were conducted to verify compliance. A copy of the revised streamlined inspection form can be found in Appendix 3-4. Website and Hotline Information about water conservation, trash management, and storm water has been combined to one centralized hotline and web page accessed at www.carlsbadconserves.org. The hotline is answered by Storm Water Protection Program during business hours and provides a detailed voice message after hours. In addition, outreach materials continue to be revised to include the Environmental Program’s hotline number, storm water hotline number, and web page address. Industries can call the hotline to request BMP information or download the information from the Environmental Programs and the Storm Water Protection web pages. During FY 05-06, there were 2,750 visits to the storm water web page and 12,860 hits on the Environmental Programs web page. Community and Professional Groups On December 13, 2005, the City’s Environmental Specialist II attended the Industrial Environmental Association annual conference in San Diego. On March 9, 2006, the Acting Environmental Programs Manager and Environmental Specialist II attended an Industrial Environmental Association water committee meeting and made a presentation about the City’s storm water compliance program. The presentation also included an update on industrial compliance, information about fire sprinkler discharge, and distribution of BMP information. Workshops On June 13, 2006, the City hosted a free pollution prevention workshop for area businesses that prepare and/or sell food and beverages. Approximately 300 businesses were invited to attend and invitations included information about storm water and BMPs. The workshop provided the food service industry with important educational tools to help businesses comply with the City’s pollution prevention requirements. The 40 participants received assistance and training in storm water pollution prevention, trash and grease management, and the requirements of the Carlsbad Municipal Code. Featured speakers and panelists from the City of Carlsbad, Waste Management, and the San Diego County Green Business Program were also on hand to provide businesses with the most current information about storm water requirements, pollution prevention strategies, and best management practices. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 18 BMP and Knowledge Assessment Tools In FY 04-05, the Storm Water Protection Program developed a BMP and Knowledge Assessment tool to measure an individual industrial operator’s knowledge of storm water issues and assess the implementation of BMPs onsite. The assessment tool is used by inspectors during site visits where commercial operators are rated using the following criteria: Overall Knowledge Assessment For Knowledge Assessment, inspectors rank personnel from 1-5 per the following scale: Level 1: Individual has never heard of the storm water program, requirements, or BMPs. This individual does not know what BMPs are or understand how to implement them. Level 2: Individual has a general awareness of water quality issues, but does not understand the requirements of the storm water program, BMPs, or pollution prevention. Level 3: Individual has a general understanding of storm water issues (“I’ve heard something about that”), but not specific storm water requirements or BMPs required for the facility. Level 4: Individual has a clear understanding of BMPs but may not have a clear awareness of the connection between pollution prevention and water quality. Level 5: Individual demonstrated an in-depth knowledge of the storm water program and BMPs consistent with the facility’s activities and operations. Overall BMP Assessment For BMP Assessment, inspectors rank the facility from 1-5 per the following scale: Level 1: An illegal discharge was noted during the inspection. Enforcement actions such as a NOV and/or citation are required. Level 2: BMPs have not been implemented. Several violations were noted during the inspection, however an illegal discharge was not observed. A detailed inspection report and/or written warning was issued. Level 3: BMPs have been implemented throughout the site, but not properly or adequately maintained. Violations were noted during the inspection and a verbal warning was issued. A detailed inspection report or written Warning Notice may follow. Level 4: BMPs implemented effectively, however minor violations associated with communal areas or good housekeeping practices (i.e., dumpsters open, leaves in the parking lot, etc.) were noted during the inspection. Level 5: All BMPs implemented effectively. No violations noted during the inspection. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 19 Table 3.2 shows the number of instances in raw score and percentage that industrial businesses rated for each score, with 5 being the highest score possible. There were a total of 355 businesses assessed for Knowledge, and 424 assessed for BMP implementation. Table 3.2: Industrial Businesses Rated for Each Score Rating Knowledge Assessment (raw score) Knowledge Assessment (%) BMP Implementation (raw score) BMP Implementation (%) 1 11 3% 31 7% 2 42 12% 29 7% 3 92 26% 74 18% 4 75 21% 158 37% 5 135 38% 132 31% Total 355 100% 424 100% The number of BMP Assessments collected is usually higher than the number of Knowledge Assessments collected, because on at least 69 occasions, a company representative was not available to complete the Knowledge Assessment. According to the results of the Knowledge Assessment, 85% of the businesses surveyed had at least a general understanding of storm water issues. Although this number represents a significant effort to educate industrial businesses about storm water issues, it could be higher if there was less turnover at inspected sites. As far as BMP implementation, the results show that the City has been successful in ensuring that the businesses have implemented BMPs throughout the sites at least 86% of the time. The City will continue to work with businesses to not only educate them about storm water issues, but also ensure BMPs are implemented and maintained. 3.4 Industrial Monitoring Program The Regional Board requires regulated industries to conduct monitoring as outlined in the General Permit. The Carlsbad Municipal Code also allows the City to require non-permitted facilities to conduct monitoring. Permitted facilities are required by the State to maintain self-audit reports, SWPPPs, monitoring reports, and annual reports onsite. City inspectors reviewed monitoring results during inspections to verify that monitoring was conducted as required. The monitoring results, when available, were entered into a database so that annual comparisons could be made. A spreadsheet has been developed to track monitoring results received from regulated industrial facilities. The spreadsheet was revised during FY 05-06 and contains enough results to provide feedback to industries. During FY 05-06, the City analyzed monitoring results, made comparisons, and provided recommendation to those industrial facilities that exceeded benchmark values. These recommendations included, but were not limited to, SWPPP revisions, implementation of new BMPs, reinforcement of implemented BMPs, and increased employee training. In addition, if and when monitoring was not completed as required the City issued NOVs and notified the Regional Board of non-compliance issues. During FY 05-06, as in previous years, the City has found that some high priority industries did not conduct the annual monitoring as required. City inspectors forwarded this information on to the Regional Board on a case by case basis. The most common reasons cited for not completing the required monitoring were lack of storm events or the participation in an approved group monitoring effort. The City will continue to annually inspect the high priority industries, collect monitoring data, maintain the database, and whenever possible provide feedback to industries on the effectiveness of the monitoring program and BMPs. If benchmark values routinely exceed the established parameters, the City will follow up with written notification to the facility and Regional Board and require corrective actions and/or additional BMPs to prevent or reduce the identified pollutant at its source. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 20 3.5 Inspection of Industrial Sites The City conducted high, medium, and low industrial inspections at approximately 75% of all the prioritized facilities in accordance with the program described in the JURMP. All high priority industrial sites were inspected by the City. 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 non-compliant or placed on a compliance schedule. Each month, several businesses were selected from the master inventory list for inspection and/or review. The City usually conducted unscheduled, follow-up, and compliance inspections at businesses that had been previously inspected. If a new business could not be excluded by review or telephone survey, then a site visit was scheduled and a comprehensive inspection conducted. Inspections were scheduled within two weeks of contacting the business. Telephone surveys continue to determine status of home-based businesses listed as low priority industries on the inventory. Twenty-eight businesses initially identified as high, medium, or low industries were surveyed by phone. In most cases, this screening procedure determined that the wrong SIC code had been assigned during the business license application process. Home-based businesses are not typically true manufacturing facilities. In addition, City code prohibits home-based business from conducting activities outdoors or storing materials outdoors. If a business was excluded from additional inspection or regulation, the City followed up with correspondence that included a listing of the minimum BMPs required for all businesses as well as any specific industrial activity related BMPs. In addition to physical inspections and telephone surveys, the City also reviewed an additional (including home based businesses) 83 industries during FY 05-06. During the review process, the inspector evaluated the industry using relevant information from other City departments, databases, or licensing programs. A business could be excluded during the review process if it was found that their activities were not regulated by the City or General Permit. The most common reason businesses were excluded was because of an incorrect SIC code designation. Of the 83 businesses reviewed in FY 05-06, 12 were found to be out of business, 53 were found to be active, one was a duplicate entry, and 17 were excluded from additional inspection. If the business was found to be active and not a home-based location, a physical inspection was conducted to assess potential threat to water quality. Appendix 3-1 includes the name, location, SIC, priority, and types of industrial inspections conducted in FY 05-06. 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. In December 2005, a new Notice to Clean form and NOV form were created to help facilitate prompt and proactive response from businesses. A copy of the new Notice to Clean form can be found in Appendix 3-5 and a copy of the revised NOV form can be found in Appendix 3-6. During FY 05-06, the City responded to 6 complaints of illegal discharges originating from industrial sites or activities. When a storm water complaint was received about an industrial site or source, or an illegal discharge was observed or suspected, the City conducted a storm water inspection or investigation. 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 implement corrective actions. In judging the degree of severity, City inspectors also took into account any history of similar incidents or discharges. Table 3.3 includes a summary of corrective actions required by the City after inspections at high priority industrial facilities. This table also includes 35 independent businesses which represents 41 different high priority locations inspected as required during FY 05-06. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 21 Table 3.3: Summary of Inspections, Corrective and Enforcement Actions Required at High Priority Industrial Facilities in FY 05-06. Enforcement Required Business Name Insp. Date Corrective Actions If Required FY 05-06 2004-2005 2005-2006 Randall International 08/15/05 Revise and update SWPPP. Provide records of employee training. Ensure samples are collected using established protocols. None NOV Acushnet Company 08/15/05 Regularly sweep outdoor areas. Protect materials stored outdoors. Clean in and around storm drains. None None Legoland 08/16/05 Implement SWPPP as required by the Permit. Update SWPPP to include pollution prevention team. Ensure all employees are training on storm water. Never use a water hose to wash down spilled materials. Dispose of old and unused equipment Regularly sweep outdoor areas. Protect materials stored outdoors. Metal Parts should be stored in covered areas. Clean in and around storm drains. None NOV NRG Cabrillo Power Operations 08/24/05 Protect materials stored outdoors. Metal parts should be stored in covered areas. Keep dumpsters closed when not in use. Develop a storm drain maintenance program. Label storm drains. Revise and update SWPPP. Ensure all employees are trained on storm water. None Warning Notice Hawthorne Rent-It Service 08/25/05 Regularly sweep outdoor areas. Protect materials stored outdoors. Metal parts should be stored in covered areas. Replace broken sand and rock bags. Label storm drains. Revise and Update SWPPP. None Warning Notice Isis Pharmaceuticals 09/20/05 No violations noted during the inspection. None None Hanson Aggregates 09/26/05 Update and revise the SWPPP. None None Graphic Converting, Inc. 10/05/05 Storm drains need cleaning. Ensure all employees are training on storm water. NOV None Melles Griot Laser Division 10/19/05 Regularly sweep outdoor areas. Protect materials stored outdoors. Keep dumpsters closed when not in use. Clean storm drain in the loading bay. Update SWPPP to include pollution prevention team. None None Beckman Coulter 10/26/05 Regularly sweep outdoor areas. Protect materials stored outdoors. Clean in and around storm drains. Keep spill clean up materials readily available. None None Callaway Golf Ball1 Company 11/04/05 Regularly inspect outdoor areas and sweep up debris. Protect materials stored outdoors Clean in and around storm drain. Ensure all employees are training on storm water. NOV None Schumacher Company 11/17/05 Regularly sweep outdoor areas. Protect materials stored outdoors. Clean in and around storm drains. Ensure all employees are training on storm water. None None 1 Includes three Callaway Golf high priority facilities. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 22 Enforcement Required Business Name Insp. Date Corrective Actions If Required FY 05-06 2004-2005 2005-2006 La Costa Limousine 12/07/05 Regularly inspect outdoor areas. Protect materials stored outdoors. Keep dumpsters closed when not in use. Develop a storm drain maintenance program. Revise and update SWPPP. Conduct storm water monitoring according to protocols. Ensure all water in washing area is contained onsite. None Warning Notice Meadowlark Water Reclamation Facility 12/09/05 No violations noted during the inspection. None None Allied Waste Company 12/16/05 Regularly inspect outdoor areas. Protect materials stored outdoors. Clean in and around storm drains. Ensure all employees are training on storm water. None None Waste Management 12/16/05 No violations noted during the inspection. None None Mercy Air 01/24/06 No violations noted during the inspection. None None McClellan-Palomar Airport 01/26/06 Ensure tenants are trained on storm water requirements. None None Express Air Aviation 01/26/06 Store hazardous materials and used oil in proper containers. Provide spill kits in the hazardous materials storage area. Increase sweeping of outdoor areas. Verbal Warning None Aviation Service Company 01/26/06 No violations noted during the inspection. None None Leading Edge Aviation 01/26/06 No violations noted during the inspection. None None A&P Aircraft Detailing 02/03/06 No violations noted during the inspection. None None Aero Pacific 02/03/06 No violations noted during the inspection. None None Civic Helicopters 02/03/06 No violations noted during the inspection. None None Hanger One Inc. 02/03/06 No violations noted during the inspection. None None Jet Source Inc.2 02/03/06 No violations noted during the inspection. None None Quality Aircraft Care 02/03/06 No violations noted during the inspection. None None West Coast Jet Services 02/03/06 No violations noted during the inspection. None None Western Flight3 02-03-06 No violations noted during the inspection. None None Federal Express Corporation 02/07/06 Regularly inspect outdoor areas. Ensure all employees are training on storm water. Inspect and replace storm drain filters as need. NOV None Oceanside Glasstile Company 02/24/06 Sweep up glass fragments near dumpsters. Keep drums covered in loading area. Ensure dumpsters remain closed when not in use. None None Encina Waste Water Facility 03/28/06 Regularly inspect outdoor areas. Protect materials stored outdoors. Ensure all storm drains are regularly maintained. Ensure all employees are training on storm water. None None Leucadia Waste Water District 06/15/06 No violations noted during the inspection. None None North Coastal (Palomar) Landfill 06/27/06 No violations noted during the inspection. None None Aalto Scientific Ltd 06/29/06 Revise/Develop a SWPPP and monitoring plan. Protect materials/products stored outdoors. Store metal products/parts in covered areas only. Store all hazardous materials in covered areas. Ensure employees are trained. None NOV 2 Jet Source represents 4 high priority industrial locations. 3 Western Flight represents two high priority industrial locations. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 23 The Enforcement Response Plan continued to be used by City inspectors to identify, document, and respond to storm water violations. See the City’s Enforcement Response Plan (FY 01-02 JURMP Annual Report) for a detailed description of the typical escalating enforcement procedures. The Storm Water Protection Program has two full-time environmental specialists and four part-time interns to conduct inspections. In addition to completing 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), the Environmental Specialists are continually trained on code enforcement, inspection procedures, laws and regulations, and investigation techniques. Storm Water Protection Program staff attended the following training during FY 05-06: • July 2005 Clean Water Summit, San Diego Ca • July 2005 Communicating Between the Lines, San Diego, Ca • August 2005 Deal With Difficult People, Carlsbad, Ca • November 2005 High Impact Communications, Carlsbad, Ca. • March 2006 Hazardous Waste Operations and Emergency Response, San Diego, Ca • May 2006 Introduction to the Incident Command System, Carlsbad Ca. These training courses, in addition to the Enforcement Response Plan, helped the Storm Water Protection Program appropriately identify and respond to storm water violations. The City took a total of 18 enforcement actions against industrial facilities during FY 05-06. These are listed in Table 3.4. Table 3.4. Number of Industrial Enforcement Actions in FY 05-06 Industrial Priority Verbal Warning Written Warning Notice of Violation Notice to Clean Administrative Citation High 0 2 2 0 0 Medium 1 4 2 0 0 Low 1 1 3 2 0 Totals 2 7 7 2 0 High priority industrial facilities typically had fewer violations and enforcement actions than medium and low priority sites. In general, high priority industrial facilities usually have a better understanding of storm water requirements and are more strictly regulated than medium or low facilities. They may also have additional permit and compliance activities for air quality, hazardous materials, or wastewater discharges. Escalated enforcement actions were taken when necessary to achieve compliance. In some cases, an informational letter or written warning was escalated to a NOV if compliance was not achieved with the first action. More detailed information on complaint response and illegal discharge investigations is found in Section 8. The following is a discussion of the NOVs issued to high priority industrial facilities during FY 05-06. Aalto Scientific Aalto Scientific has been covered under the General Permit since 2004 (WID 9-37I019035). The SIC code currently assigned to Aalto Scientific is 2835 (In Vitro and In Vivo Diagnostic Substances). Aalto Scientific staff had previously implemented a number of BMPs throughout the facility to prevent the discharge of pollutants to the storm drain conveyance system. However, during the FY 05-06 inspection City staff found that BMPs had not been maintained. In addition, Aalto Scientific was not able to provide documentation of key components of the SWPPP. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 24 On July 7, 2006, the City issued a NOV to Aalto Scientific requiring immediate corrective action to address the storm water violations observed during the inspection. On August 8, 2006, the City received correspondence from Aalto Scientific documenting the implementation of corrective actions. Follow-up inspections to verify compliance are regularly conducted at this facility. Legoland Legoland is large amusement park located on approximately 120 acres in Carlsbad. Although Legoland is primarily involved in activities covered under SIC 7999 (Amusement Parks), the maintenance, painting, and storage areas have a high potential to contribute to storm water pollution. These areas of activity have been classified as 4119 (Transportation Related Activities) by the Regional Board. On August 16, 2005, the City conducted a follow up compliance inspection of Legoland operations and found several violations of the General Permit and Carlsbad Municipal Code. During the August 15, 2005, inspection City inspectors found that Legoland employees had recently washed dirt and debris to the storm drain. City inspectors also observed a spill in the storage area that had not been immediately cleaned. No attempts were made by Legoland employees to report or clean up the spill. Upon discovery of the spill, Legoland was immediately required to clean up the spill and provide information on the nature of the substance. On August 23, 2005, the City issued a NOV to Legoland (copy sent to Regional Board) requiring documentation of employee training, SWPPP revisions, and spill response procedures to be submitted to the City by September 6, 2005. On September 6, 2005, the City received correspondence from Legoland documenting the implementation of corrective actions. Randall International As a mandatory industry Randall International is required to comply with the requirements of the General Permit. However, because of several organizational changes they have not been able to maintain compliance with the General Permit. On August 15, 2005, the City conducted an annual compliance inspection of Randall International and found that staff could not provide documentation that the storm water program had been implemented as required by the General Permit. On August 18, 2005, a NOV was sent to Randall International requesting documentation of the SWPPP, Monitoring Plan, storm water sampling results, and employee training program. The inspection report required a response by August 30, 2005. On August 29, 2005, Randall International responded to the NOV stating that the requested documents had been developed and will be continuously maintained. 3.7 Non-Compliance Notification Action Plan All industrial facilities were required to maintain compliance with the Carlsbad Municipal Code and 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 if the facility was considered non-compliant or if the 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 it 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.). City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 25 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 provided verbal notification to the Regional Board within 24 hours, followed by a written report within 5 days. There was one incident of this nature that occurred during FY 05-06. On November 9, 2005, a City Construction Inspector received a call from the construction site superintendent at the Carlsbad Oaks North project stating that during the normal dewatering activities, a large amount of foam was observed at the discharge point (Figure 3-1). The Construction Inspector had the site crew immediately stop pumping and contain the area. The Storm Water Protection Program immediately responded and found a large plume of foam in a pit of murky water. Storm water inspectors determined that the product could not be identified and called Carlsbad Fire Department (CFD) to respond. Storm water personnel located the source at Syntron Bioresearch (2774 Loker Ave. West, Carlsbad, Ca 92008: Industrial Medium). After discussions with Syntron Bioresearch employees, it was determined that a 50 gallon drum containing a concentrated industrial soap product had leaked and discharged to the storm drain system. CFD determined that the product had the probability to be hazardous and that the area would need to be protected. CFD notified the County of San Diego Department of Environmental Health Hazardous (DEH) Materials personnel. County DEH staff also found that the material had the potential to be hazardous. They worked with Syntron Bioresearch to have the impacted storm drain system cleaned and materials properly disposed of offsite. County DEH also notified the Office of Emergency Services (OES) about the release. City personnel monitored the cleanup efforts and followed up with a NOV to Syntron Bioresearch. 3.8 Self-Assessment Program Strengths In June 2006, the City held a successful restaurant workshop which attracted 40 participants representing several industrial and commercial businesses throughout Carlsbad. The participants received assistance and training in storm water pollution prevention, trash and grease management, and the requirements of the Carlsbad Municipal Code. Featured speakers and panelists from the City of Carlsbad, Waste Management, and the San Diego County Green Business Program were also on hand to provide businesses with the most current information about storm water requirements, pollution prevention strategies, and best management practices. In May 2006, the City revised the streamlined inspection report so that industries can effectively and promptly implement correction of violations. The revised streamlined inspection form now includes spaces to report previous enforcement actions, new storm water contacts, and a detailed list of necessary corrective actions. The revised form has proven to be successful in attaining compliance from regulated facilities. In December 2005, a new Notice to Clean form was created to help facilitate prompt and proactive response from businesses. The new Notice to Clean form was designed based on the success and format of the Notice of Violation form created in May 2005. Figure 3-1 Discharge from Syntron Bioresearch City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 26 The City continued to maintain regular communications with the Industrial Compliance Unit of the Regional Board. In addition to copies of inspection reports and other correspondence with high and medium industries, the City regularly coordinated compliance issues with the Regional Board over the phone and through emails. On several occasions, the Regional Board expressed their appreciation of the City’s professionalism, responsiveness, and implementation of the storm water program. The City continues to recruit interns from local universities to work with storm water staff. During FY 05-06, the Storm Water Protection Program had four interns working on various projects, including industrial inspections, data management, water quality monitoring, and outreach and education. Their assistance with inspections, monitoring data entry, and investigations increased productivity and helped the program achieve inspection goals. Trash management continues to be a problem at some industrial sites throughout the City. Waste Management developed a camera program to identify problem areas and forward information to the City for additional enforcement. Waste Management has been providing this information on a quarterly basis. When trash violations are noted at industrial businesses, City inspectors followed up either during the next scheduled inspection or immediately, depending on the severity of the complaint. This program has been beneficial in tracking businesses with continuous trash problems and initiating enforcement actions for those egregious violators. Program Improvement Areas The Storm Water Protection Program staff began working with the City Attorney’s office to revise the ordinance to reflect current enforcement levels and mechanisms. Revision and Council approval should be complete by the end of FY 06-07. In late FY 05-06, the Storm Water Protection Program began drafting a “Best Management Practices Manual” that includes the minimum and required BMPs for activities and pollutant sources. The manual will be continually worked on during FY 06-07 and should be completed by early FY 07-08. The City will provide an update on the progress of the manual in the next annual report. Storm Water Protection Program procedures will be reviewed and revised as appropriate during the next reporting year. Results of this effort will be reported in the FY 06-07 annual report. The Storm Water Protection Program staff will be working with the Information Technology Department to revise the webpage and provide updated information about storm water BMPs. The webpage updates should be completed by the end of FY 06-07. During FY 05-06, staff continued to revise the brochures and fact sheets and update them to reflect changes in the program. A complete revision of all brochures will take some time to complete. However it is expected that this project will be completed by late FY 07-08. Fire sprinkler maintenance is an important safety concern for industrial facilities. Most fire sprinkler systems can accumulate rust, heavy metals, and other pollutants that, if discharged to storm drains, could be a source of pollution. In Carlsbad, fire sprinklers are required to be checked annually. This regular service could release as much as 235 gallons of contaminated water into our waterways and may cause harm to aquatic habitats and wildlife. The Storm Water Protection Program currently has limited BMP information available to industrial facilities or contractors on how to deal with these discharges. A BMP brochure or fact sheet was drafted in FY 04-05, however the City is still working on finalizing this brochure and researching alternative methods of disposal and discharge. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 27 The Regional Board is currently revising the language and procedures outlined in the General Permit. The City highly anticipated the finalization of this document, unfortunately it has not been completed. When the General Permit is reissued, the City would like to host a workshop for all industries in Carlsbad to discuss the new General permit guidelines, compliance issues and address any concerns businesses might have about the new permit. The Storm Water Protection 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. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 28 Section 4 Commercial Component 4.0 Overview The City continues to track, inspect, and monitor high priority commercial businesses within its jurisdiction. Major commercial types in Carlsbad are automobile maintenance, restaurants, shopping centers, pressure washing, masonry and concrete work, carpet cleaning, and landscape services. These high priority activities have the potential to generate significant amounts of pollutants, if performed with disregard to the environment. The City has implemented a program to inspect high priority facilities, ensure compliance with applicable regulations, and reduce pollutant runoff from commercial sites and sources. During FY 05-06, the City maintained an inventory of 573 commercial businesses. During FY 05-06, the City updated and prioritized the commercial inventory, mapped all high priority commercial facilities, and inspected 443 high priority commercial businesses. Inspections not only included physical inspections, but also reviews, phone contacts, and drive bys all in an effort to conduct education and outreach, obtain compliance, ensure BMP implementation, and use escalated enforcement actions, when necessary. These activities are further described in the following subsections. 4.1 Source Identification and Threat to Water Quality Prioritization Storm water inspectors identify pollution sources, assess the potential threat to water quality, and require BMP implementation to eliminate pollution sources from commercial businesses. Each year hundreds of new businesses are established in Carlsbad. The Storm Water Protection Program works closely with the Finance Department to obtain information about new businesses, including activities, SIC codes and descriptions, business types, and contact names and numbers. Each quarter the Storm Water Protection Program downloaded, sorted, mapped, and prioritized new businesses by SIC and business type. These new businesses were then added to the inventory list and scheduled for inspection. In some cases information provided on business license applications was not correct and a pre-inspection evaluation was necessary. Pre-inspection evaluations helped determine if a business’ activities were subject to storm water requirements. Two types of pre-inspection evaluations were used: 1. Reviews: Business license information and other relevant data was reviewed to determine whether the business should be inspected and tracked by the Storm Water Protection Program. 2. Telephone Contacts: If the review fails to provide enough information, the inspector will contact the business by phone to determine their status and schedule an inspection if necessary. After physical inspections, reviews, or telephone contacts, any changes to a business’ priority or status was recorded on the Storm Water Inventory List and/or in the Permits Plus database. New businesses were also found by referral from other agencies, field discovery, or business directories. The updated FY 05-06 year end commercial inventory can be found in Appendix 4-1. Data related to commercial businesses is managed on a continual basis per departmental procedures and JURMP requirements. All documents related to commercial businesses were filed according to status (active, inactive, excluded, or out of business). Appendix 4-2 contains a map of all high priority commercial facilities on the FY 05-06 inventory. Because restaurants and automotive facilities represent the largest commercial groups, the map contains separate symbols for the locations of these facilities. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 29 At the end of FY 05-06, the inventory included 573 high, commercial businesses. This compares to 504 high priority commercial businesses identified at the beginning of the reporting year. The high priority commercial businesses on the inventory continue to be reviewed in response to complaints and as resources become available. As a part of the City’s watershed activities, staff conducted inspections at 95% of all restaurant facilities during FY 05-06. In February 2006, the SIC code identification and assignment procedure was revised to include additional SICs not previously covered by staff review. In addition, several SICs that did not require review were removed from the procedure list. Table 4.1 provides a summary of commercial business by sources type. A total of 24 SIC code groupings related to high priority commercial activities were identified. Table 4.1 - Summary of Commercial Businesses for Source Types Commercial Activity # On Inventory 01XX: Agricultural Production Crops 14 02XX: Agricultural Production Livestock and Animal Specialties 2 07XX: Agricultural Services 44 1521: General Contractors 4 17XX: Construction Special Trade Contractors 65 5032 – Tile Cutting 1 51XX: Wholesale Trade Non-Durable Goods 3 5211: Lumber Services 1 5261: Retail Nurseries 4 53XX: General Merchandise Stores 4 54XX: Food Stores 22 55XX: Automotive Dealers and Gasoline Service Stations 47 58XX: Eating and Drinking Places 175 5912: Drug Stores and Proprietary Stores 2 5963: Direct Selling Establishments 1 65XX: Real Estate 15 7011: Hotels and Motels 6 7216: Dry Cleaning Plants 1 7217: Carpet and Upholstery Cleaning 13 7259: Equipment Leasing and Rentals 1 73XX: Business Services 72 75XX: Automotive Services Repair and Parking 58 76XX: Repair Shops 6 79XX: Amusement and Recreation Services 11 8059: Nursing Homes 1 TOTAL 573 Table 4.1 shows that the greatest number of commercial sources of pollution may be from restaurants. Restaurants contribute to storm water pollution through improper housekeeping practices that allow grease, trash, and cleaning products to discharge to streets and the storm drain system. Because restaurants have been identified as a significant pollutant source, the Storm Water Protection Program has intensified efforts to provide BMP information, conduct unscheduled inspections, and escalate enforcement actions, when necessary. Of the 175 active restaurants on the end of year inventory, 167 were physically inspected by the Storm Water Protection Program in FY 05-06. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 30 4.2 Pollution Prevention Pollution prevention activities are proactive approaches commercial businesses can use to identify and reduce pollution sources. Proactive pollution prevention, when framed in the context of appropriate and specific BMP identification and maintenance, is key to improving regional water quality. The City’s approach is to promote pollution prevention and BMP implementation to the maximum extent practicable. The City encouraged the use of BMPs during inspections, public events, in outreach materials, through direct mailings, and at workshops. City inspectors required the following minimum BMPs for all commercial businesses: • Move or cover potential pollution sources from storm water contact. Protect materials and products that could potentially contribute to storm water pollution by storing them indoors or covering them, and providing them with secondary containment as needed. • Use dry cleanup methods. Washing or cleaning activities that involve the use of a water hose or pressure washing system were required to use dry clean up methods (mops, brooms, rags or wire brushes to clean pavement, buildings and equipment as much as possible). • 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 be required to modify downspout locations in order to redirect storm water flows away from potential pollutant sources. • Trash Management. Sweep up around dumpsters and other areas to prevent trash and debris from accumulating. Dumpsters must be kept closed when not in use. All trash must be kept in appropriate sized containers until it can be hauled away. • Recycle, Reduce and Reuse. Recycle cans, bottles, newspaper, office paper and cardboard whenever possible. When inspecting solid waste collection areas, inspectors noted if recyclable materials (cardboard, green waste, etc.) were placed in dumpsters and recycled. SWPPPs were encouraged and/or required for commercial businesses based on inspection findings and potential threat to water quality. Commercial businesses were usually given 60-90 days to develop and submit the SWPPP to the Storm Water Protection Program for review and approval. During follow up compliance inspections, businesses were expected to provide documentation that the SWPPP had been implemented as required. If the inspector found deficiencies, the business was required to revise the SWPPP and ensure procedures and BMPs were implemented as outlined in the plan. The City continued to provide the sample SWPPP to commercial businesses as a guide for preparing site specific plans. The sample SWPPP was also provided upon request or when the current SWPPP was found to be deficient. 4.3 Best Management Practices Implementation The City required high priority commercial businesses to implement the minimum BMPs and specific BMPs applicable to each activity and pollutant source. BMP information was made available during inspections, in printed materials, at workshops, on the website and hotline, and at outreach events. A complete listing of all outreach and education events held during FY 05-06 is in section 9.4 of this report. Printed Materials and Direct Mailings During FY 05-06, the City continued to distribute the “Best Management Practices for Businesses – Commercial and Industrial” brochure containing the list and description of the minimum BMPs. This brochure was distributed to all commercial businesses during inspections and by direct mail to businesses that the City verified from the inventory. Over 300 of these brochures were distributed during FY 05-06. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 31 In March 2006, the City developed a new brochure for the mobile service providers, including carpet cleaners, plumbers, pressure washers, mechanics, porta-potty services, and any other mobile business that provides services at off-site locations. Materials from mobile service activities such as cleaners, grease, soapy water, dirt, debris, and other pollutants often find their way to streets and storm drains. This brochure was designed for mobile service providers, their employees and anyone that hires a mobile service provider. During FY 05-06, the “Best Management Practices for Mobile Service Providers” brochure was mailed to every applicable commercial business on the storm water inventory. A copy of this new brochure can be found in Appendix 4-3. In May 2006, the City sent two mailers to all landscape and pest control professionals in Carlsbad. The mailer not only included BMP information, but also an invitation to the May 9, 2005 “Integrated Pest Management Training for Landscape Professionals”, sponsored by the Unified Port of San Diego and the June 7, 2006, “Exotic Invasive Plant Workshop.” The City also continued to distribute the “Pollution Prevention Guide for the Construction Industry.” This brochure was developed to provide BMP and pollution prevention information related to materials storage, perimeter controls, building and staging areas, dumpsters and port-a-potty services, concrete trucks and pumpers, washout areas, and storm drain protection. The brochure was distributed to commercial businesses that conduct small remodeling or home improvement projects. Inspections and Site Visits Commercial businesses select and implement source and treatment control BMPs as directed by the Storm Water Protection Program, Planning Department and/or the Engineering Department. BMPs are considered effective if they address the pollutants of concern and are specific enough to prevent or reduce the likelihood of an illegal discharge. The City may require BMPs based on problems identified during site inspections. All commercial businesses were required to implement the minimum BMPs, those identified for specific commercial activities, or as directed by the City. During FY 05-06, the City revised the streamlined inspection report to facilitate prompt correction of violations. The revised form now includes space to report previous enforcement actions, new storm water contacts, and a detailed list of necessary corrective actions. Detailed inspection reports also continue to be used for businesses that have not been previously inspected or if the facility requires a more complex inspection (i.e. high priority facilities, egregious violators). If corrective actions were required, follow-up inspections were conducted to verify compliance. Website and Hotline Information about water conservation, trash management, and storm water has been combined to one centralized hotline and web page accessed at www.carlsbadconserves.org. The hotline is answered by the Storm Water Protection Program during business hours and provides a detailed voice message after hours. In addition, outreach materials continue to be revised to include the Environmental Program’s web page address and hotline number. During FY 05-06, there were over 2,750 visits to the storm water web page and 12,860 hits on the Environmental Programs web page. Workshops On June 13, 2006, the City hosted a free pollution prevention workshop for area businesses that prepare and/or sell food and beverages. Approximately 300 businesses were invited and invitations included storm water BMPs. The workshop provided the food service industry with important information on how to comply with pollution prevention requirements. Participants received training in pollution prevention, waste management, and the Carlsbad Municipal Code. Featured speakers from the City, Waste Management, and the San Diego County Green Business Program were also on hand to provide information about storm water requirements, pollution prevention strategies, and BMPs. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 32 On May 18 and June 1, 2006, the City co-sponsored two “Post-Construction Best Management Practices,” seminars held in Oceanside and Escondido. The seminars were designed to assist the development community in understanding the post-construction BMP requirements and provide information about expectations and specific jurisdictional requirements. The Storm Water Protection Program mailed 112 invitations to general contractors, which also included BMP information. The City sponsored a “Composting for the Health of Your Soil,” workshop on February 11, 2006. The Storm Water Protection Program distributed a flyer, information letter, and lawn and garden BMPs to all landscape and garden care businesses in Carlsbad. BMP and Knowledge Assessment Tools The Storm Water Protection Program continued to use the BMP and Knowledge Assessment to measure knowledge of storm water issues and assess the implementation of BMPs onsite. The assessment tool rated a commercial operator and site using the following criteria: Overall Knowledge Assessment: Inspectors rank personnel from 1-5 per the following Knowledge Assessment scale: Level 1: Individual has never heard of the storm water program, requirements, or BMPs. This individual does not know what BMPs are or understand how to implement them. Level 2: Individual has a general awareness of water quality issues, but does not understand the requirements of the storm water program, BMPs, or pollution prevention. Level 3: Individual has a general understanding of storm water issues (“I’ve heard something about that”), but not specific storm water requirements or BMPs required for the facility. Level 4: Individual has a clear understanding of BMPs but may not have a clear awareness of the connection between pollution prevention and water quality. Level 5: Individual demonstrated an in-depth knowledge of the storm water program and BMPs consistent with the facility’s activities and operations. Overall BMP Assessment Inspectors rank the facility per the following 1-5 BMP Assessment scale: Level 1: An illegal discharge was noted during the inspection. Enforcement actions such as a NOV and/or citation are required. Level 2: BMPs have not been implemented. Several violations were noted during the inspection, however an illegal discharge was not observed. A detailed inspection report and/or written warning was issued. Level 3: BMPs have been implemented throughout the site, but not properly or adequately maintained. Violations were noted during the inspection and a verbal warning was issued. A detailed inspection report or written Warning Notice may follow. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 33 Level 4: BMPs implemented effectively, however minor violations associated with communal areas or good housekeeping practices (i.e., dumpsters open, leaves in the parking lot, etc.) were noted during the inspection. Level 5: All BMPs implemented effectively. No violations noted during the inspection. Table 4.2 shows the number of instances in raw score and percentage that commercial high businesses rated for each score, with 5 being the highest score possible. There were a total of 203 businesses assessed for Knowledge, and 241 assessed for BMP implementation. Table 4.2: Commercial High Businesses Rated for Each Score. Rating Knowledge Assessment (raw score) Knowledge Assessment (%) BMP Implementation (raw score) BMP Implementation (%) 1 9 4 19 8 2 29 14 23 10 3 56 28 48 20 4 47 23 80 33 5 62 31 71 29 TOTAL 203 100% 241 100% The number of BMP Assessments collected is usually higher than the number of Knowledge Assessments collected, because on at least 38 occasions, a company representative was not available to complete the Knowledge Assessment. According to the results of the Knowledge Assessment, 82% of the businesses surveyed had at least a general understanding of storm water issues. BMP implementation results show that the City has been successful in ensuring that businesses implement BMPs throughout the sites at least 86% of the time. The City will continue to work with businesses to not only educate them about storm water issues, but also ensure BMPs are implemented and maintained. 4.4 Inspection of Commercial Sites The City conducted high priority commercial inspections at approximately 78% of all prioritized commercial businesses in accordance with the program guidelines described in the JURMP. Site visits, reviews, and telephone contacts were the primary methods used to educate and ensure storm water compliance at commercial businesses. The City conducted inspections of commercial businesses on a complaint basis and as time and resources became available. The City physically (excludes reviews, phone surveys, and drive bys) inspected 269 commercial businesses in FY 05-06. Storm water staff also reviewed, phoned, or conducted investigations at an additional 174 commercial facilities for a total of 443 businesses inspected during FY 05-06. At the end of the fiscal year there were 573 commercial businesses on the storm water inventory. Of these, 42 were found to be out of business, 14 had moved out of the City, one was a duplicate entry, 24 were excluded (based on several qualifying factors including SIC Code, location, business type, and probability to contribute to storm water pollution), 429 were active, and one was found to be not applicable (NA). The City defines NA to mean that the business has reviewed and the Environmental Specialist has determined it to have a low risk of storm water discharges. This determination also means that the business is not a high priority commercial operation. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 34 A large percentage of businesses on the inventory list were home-based businesses. Many commercial home-based businesses are involved in the mobile trade industry (carpet cleaning, power washing, etc.), which are considered high priority commercial activities. These home-based, mobile businesses were identified, contacted and mailed appropriate BMP information. Because site inspections are not required for home-based businesses, many were reviewed by City inspectors. During the review process the inspector evaluated a commercial business using any relevant information available in other City departments, databases, or licensing programs. A business could be excluded during a review if it was found that their activities were not regulated by the City or Permit. The most common reason businesses were excluded during the review process was because of an incorrect SIC code designation. Telephone surveys continue to be used to determine the status of certain types of home-based businesses on the commercial inventory. Thirty-seven home-based commercial businesses 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. The Carlsbad Municipal Code prohibits home-based businesses from conducting activities or storing materials outdoors. Once confirmed, home-based businesses were mailed specific BMP information. Each month, several businesses were selected from the master inventory list. The City usually conducted unscheduled, follow-up and compliance inspections at businesses that had been previously inspected. If a new business could not be excluded by review or telephone survey, then a site visit was scheduled and a comprehensive inspection conducted. Restaurants have been identified as a significant source of pollutants in the City. Restaurants contribute to storm water pollution through improper cleaning practices that allow grease, food particles, and trash to be either exposed to storm water or discharges into the street or storm drain. The City has identified 175 active restaurants within this jurisdiction. Restaurants represent over 30% of all commercial businesses tracked by the Storm Water Protection Program. In addition to conducting a restaurant workshop, the City also established an internal goal to conduct 90% of restaurant inspections during FY 05-06. The City was successful in this effort and was able to inspect 95% of all restaurants in Carlsbad. This effort resulted in 13 NOVs and 7 citations for violations of the Carlsbad Municipal Code in FY 05-06. This was the fourth year the City conducted the “Car Country Carlsbad Blitz.” Car Country Carlsbad is an automotive shopping mall consisting of 18 car dealerships. It is one of the largest auto malls in North San Diego County. Accordingly, several high priority commercial activities are concentrated in this small area of Carlsbad. These activities include pressure washing, mobile detailing, car washing, automotive maintenance, auto body repair, and hazardous material storage. In an effort to increase the Storm Water Protection Program’s visibility and step up enforcement actions, City staff conducted unscheduled inspections to verify compliance with applicable storm water requirements. The Carlsbad Municipal Code gives the Storm Water Protection Program the authority to require non- permitted facilities to conduct monitoring. The City has required one non-permitted facility in Carlsbad to implement a monitoring program. Costco Wholesale is a large retail store located less than 200 feet from Encinas Creek. Under a Conditional Use Permit (CUP) issued by the City’s Planning Department, Costco Wholesale is required to implement and maintain a water quality monitoring program and provide annual analytical results to the City. On June 28, 2005, Costco was issued a NOV for non-compliance related to trash, storm drain maintenance, and materials storage. The NOV required Costco to implement corrective actions and submit a BMP plan by July 12, 2005. In addition, the City found that Costco had not been implementing the monitoring plan as required. On July 15, 2005, Costco submitted the BMP plan as required. The City will continue to conduct scheduled and unscheduled inspections of Costco to verify compliance with the storm water regulations and the CUP. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 35 4.5 Enforcement of Commercial Sites and Sources The City conducted follow-up inspections to determine compliance with corrective actions outlined in the inspection report or enforcement notices. When a storm water complaint was received about a commercial source or an illegal discharge was observed or suspected, the City conducted a storm water compliance inspection or investigation. 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, City inspectors also took into account any history of similar incidents or discharges. Table 4.3 includes a summary of commercial businesses that received NOVs in FY 05-06. Table 4.3: Summary NOVs Issued to Commercial Businesses in FY 05-06 CMC Violations Commercial Business SIC Date of NOV Storm Water Trash Poolscape Unlimited 7389 7/5/05 15.12.050 15.12.080 TGI Friday's 5812 7/19/05 15.12.080 15.12.120 6.08.040 6.08.045 6.08.050 Coyote Bar and Grill 5812 7/20/05 15.12.050 15.12.080 Fidel's Norte 5812 7/20/05 15.12.050 15.12.080 Islands at Carlsbad 5812 7/21/05 15.12.050 15.12.060 15.12.080 6.08.040 6.08.045 6.08.050 Gary Team Painting 1721 7/29/05 15.12.050 15.12.080 Crazy Burro Dining Cantina 5812 8/2/05 15.12.050 15.12.080 San Diego International Floral Trade Center 6531 8/11/05 15.12.050 15.12.080 Don's Country Kitchen 5812 8/19/05 15.12.080 6.08.040 6.08.050 Islands Fine Burgers 5812 8/19/05 15.12.050 15.12.080 Palomar Hand Car Wash 7542 8/19/05 15.12.050 15.12.080 TGI Friday's 5812 8/31/05 15.12.080(D) Firestone Tire and Service 5531 11/2/05 15.12.050 15.12.080 Cessy's Taco Shop 5812 3/13/06 15.12.050 15.12.080 6.08.040 6.08.045 6.08.050 Bellefleur Carlsbad 5812 3/16/06 15.12.080 6.08.040 6.08.050 Grand Buffet 5812 3/20/06 15.12.050 15.12.080 6.08.040 6.08.045 Benihana 5812 4/17/06 15.12.050 15.12.080 6.08.040 6.08.045 City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 36 CMC Violations Commercial Business SIC Date of NOV Storm Water Trash Caliber Collision Centers 5531 4/21/06 15.12.080 6.08.090 Lotus Thai Bistro 5812 5/2/06 15.12.050 15.12.080 15.12.090 6.08.045 Barazone's Ristorante 5812 5/2/06 15.12.050 15.12.080 15.12.090 6.08.045 Village 76 Gas and Car Wash 5541 5/12/06 15.12.050 15.12.080 15.12.090 North County GMC Pontiac 5511 5/15/06 15.12.050 15.12.080 15.12.090 6.08.045 Plaza Camino Real 6512 5/30/06 15.12.050 15.12.080 6.08.040 6.08.045 J.C. Penney 5311 5/30/06 15.12.050 15.12.080 6.08.045 A1 Quality Carpet Care 7217 6/16/06 15.12.050 15.12.080 Commercial sites or sources were also selected for inspection based on results of Dry Weather Program field screening indicating a potential problem. As more water quality data are collected, it is expected that commercial sites may be chosen for inspection in future years based on their potential to discharge a constituent of concern to a specific water body. During FY 05-06, the City responded to 20 complaints of illegal discharges originating from commercial locations or activities. The Enforcement Response Plan continued to be used by inspectors to identify, document, and respond to storm water violations. See the City’s Enforcement Response Plan (FY 01-02 JURMP Annual Report) for a detailed description of typical escalating enforcement procedures. For FY 05-06, the Storm Water Protection Program had two full-time Environmental Specialists and four part-time interns to conduct inspections. Environmental Specialists are continually trained on code enforcement, inspection procedures, laws and regulations, and investigation techniques. Staff attended the following training during FY 05-06: • July 2005 Clean Water Summit, San Diego Ca • July 2005 Communicating Between the Lines, San Diego, Ca • August 2005 Dealing With Difficult People, Carlsbad, Ca • March 2006 Hazardous Waste Operations and Emergency Response, San Diego, Ca • May 2006 Introduction to the Incident Command System, Carlsbad Ca. These training courses, in addition to the Enforcement Response Plan, helped the Storm Water Protection Program appropriately identify and respond to storm water violations. The City took a total of 56 enforcement actions against commercial businesses during FY 05-06. The types and numbers of enforcement actions are listed in Table 4.4. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 37 Table 4.4. Enforcement Actions at High Priority Commercial Businesses in FY 05-06 Action Total FY 04-05 Total FY 05-06 Verbal Warning 2 3 Written Warning 18 19 Notice of Violation 32 21 Notice to Clean 4 3 Cease and Desist Order 0 0 Administrative Citation 9 10 TOTAL 65 56 During inspections and investigations the City required abatement of 20 illegal discharges. Most of these incidents involved construction and landscaping contractors, pool maintenance companies, mobile detailers, pressure washers, and carpet cleaning companies. Mobile service providers were added to the inventory and required to apply for business licenses. More detailed information on complaint response and illegal discharge investigations is found in Section 8 of this report. Escalated enforcement actions were taken when necessary to achieve compliance. In some cases, an Administrative Citation was issued if compliance was not achieved. In FY 05-06, 10 administrative citations were issued to commercial operators for violations of the Carlsbad Municipal Code (Table 4.5). Table 4.5: Summary of Administrative Citations Issued in FY 05-06 Business Name Date CMC Violation Fine Due Follow Up Inspection Chin's Szechwan 7/5/05 15-12-080 6.08.045 6.08.050 $300 08/05/05 McDonalds 7/21/05 6.08.040 6.08.050 $200 08/22/05 Daphne's Greek Café 7/29/05 15.12.080 6.08.040 $200 08/30/05 San Diego International Floral Trade Center 9/1/05 6.08.045 $200 10/03/05 Macy's Department Store 9/16/05 15.12.050 15.12.080 6.08.045 $600 10/18/05 El Pollo Loco 4/3/06 15.12.080 6.08.040 $200 05/05/06 San Diego International Floral Trade Center 4/4/06 15.12.050 15.12.080 15.12.090 $600 05/05/06 San Diego International Floral Trade Center 4/4/06 6.08.045 $500 05/05/06 Alejandro’s 5/18/06 6.08.040 $200 06/19/06 Macy's Department Store 5/30/06 15.12.050 15.12.080 6.08.045 $1,500 06/30/06 City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 38 4.6 Self-Assessment Program Strengths In June 2006, the City held a successful restaurant workshop which attracted 40 participants representing several commercial businesses throughout Carlsbad. The participants received training in storm water pollution prevention, trash and grease management, and the Carlsbad Municipal Code. In May 2006, the City revised the streamlined inspection to include space to report previous enforcement actions, new storm water contacts, and a detailed list of necessary corrective actions. The revised form has proven to be successful in attaining compliance from regulated facilities. In March 2006, the City developed a new brochure for mobile service providers including carpet cleaners, plumbers, pressure washers, mechanics, porta-potty services, and any other mobile business that provides services at off-site locations. During FY 05-06, the “Best Management Practices for Mobile Service Providers” brochure was mailed to all applicable commercial businesses in Carlsbad. The Storm Water Protection Program continues to use the effectiveness assessment measures for commercial businesses. This includes both knowledge and BMP implementation assessment conducted by the inspector. According to the results of the Knowledge Assessment, 82% of the businesses surveyed had at least a general understanding of storm water issues. The BMP Assessment results show that the City has been successful in ensuring that BMPs had been implemented at least 86% of the time. Trash management continues to be an issue at some commercial sites. Waste Management developed a camera program to identify problem areas and forward information to the City for additional enforcement. In FY 05-06, Waste Management continued to provide this information on a quarterly basis. When trash violations were noted at commercial businesses, City inspectors addressed the issue during the next scheduled inspection or at the time the compliant was received, depending on the severity of the complaint. This program has been beneficial in tracking businesses with continuous trash problems and initiating enforcement actions for egregious violators. The City continues to recruit interns from local universities to work with storm water staff. During FY 05-06, the Storm Water Protection Program had three interns working on various projects, including commercial inspections, data management, and outreach and education. Their assistance with inspections, water quality studies and monitoring, data entry, and investigations increased productivity and helped the program achieve inspection and investigation goals. The City’s goal was to respond to complaints “happening right now” within 30 minutes. This goal was met over 90% of the time during FY 05-06. 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. In the spring of 2006, the Storm Water Protection Program conducted the fourth “Car Country Carlsbad Blitz.” In an effort to increase the Storm Water Protection Program’s visibility and step up enforcement actions, City staff conducted these unscheduled inspections to verify compliance with Carlsbad Municipal Code. Overall, City inspectors found that dealerships were knowledgeable and aware of storm water compliance issues. Training programs and BMPs had been implemented at all of the inspected sites. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 39 Program Improvement Areas In FY 05-06, the Storm Water Protection Program staff began working with the City Attorney’s office to revise the ordinance to reflect current enforcement levels and mechanisms. Revision and Council approval should be complete by the end of FY 06-07. The Storm Water Protection Program and Environmental Programs Division will be working with the Information Technology Department to revise the webpages and provide updated information about storm water BMPs. The webpage updates should be completed by the end of FY 06-07.In late FY 05-06, the Storm Water Protection Program began drafting a “Best Management Practices Manual” that includes the minimum and required BMPs for activities and pollutant types. The manual will be continually worked on during FY 06-07 and should be completed by early FY 07-08. The City will provide an update on the progress of the manual in the next annual report. In FY 05-06, Storm Water Protection Program staff continued to review internal procedures and revise them as needed. Staff will work to ensure all program procedures are reviewed and revised as appropriate during the next reporting year. Results of this effort will be reported in the FY 06-07 annual report. Although the Storm Water Protection Program has developed outreach materials that address oil and grease, it continues to be a pollutant source, especially at restaurants. The Storm Water Protection Program will continue to work closely with M&O to develop a program to address grease trap maintenance and proper clean up and disposal of spilled grease. During FY 05-06, staff continued to revise brochures and fact sheets to reflect changes in the program. A complete revision of all brochures will take time to complete. However it is expected that this project will be completed by late FY 07-08. Fire sprinkler maintenance is an important safety concern for commercial businesses. Most fire sprinkler systems can accumulate rust, heavy metals, and other pollutants that, if discharged to storm drains, could be a source of pollution. In Carlsbad, fire sprinklers are required to be checked annually. This regular service could release as much as 235 gallons of contaminated water into our waterways and may cause harm to aquatic habitats and wildlife. The Storm Water Protection Program currently has limited BMP information available on how to deal with these discharges. A BMP brochure or fact sheet was drafted in FY 04-05 to address this pollution source, however the City is still working on finalizing this brochure. The Storm Water Protection 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 more efficiently and effectively, and allow for better tracking and reporting of effectiveness measures. Dry weather monitoring results continue to show elevated nitrate concentrations in the area of Car Country Carlsbad, Carlsbad Premium Outlets, and Carlsbad Flower Fields. High nitrate levels have also been discovered in groundwater beneath croplands due to excessive fertilizer use, especially in heavily irrigated areas with sandy soils. Storm water runoff can carry nitrate-containing fertilizers from farms and lawns into waterways. The City has conducted extensive inspections upstream of the sites with elevated results. To date, the Storm Water Protection Program has not been able to identity a source of the nitrates but will continue to monitor dry weather results, conduct frequent inspections, and require the implementation of pollution prevention BMPs that reduce or eliminate nitrates. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 40 Section 5 Residential Component 5.0 Overview The City encompasses approximately 42 square miles, with an estimated population of 98,607 residents (January 1, 2006, California Department of Finance). 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 outreach and education program that utilizes public presentations, fact sheets, direct mailers, brochures, complaint response, and the media to increase knowledge and awareness of pollution prevention and storm water BMPs. During FY 05-06, the City continued to develop and distribute storm water BMP information to residents, host and participate in outreach events, respond to illegal discharge reports, and conduct enforcement actions to achieve compliance. The Permit requires the City to develop and implement a program to ensure residents are aware of and comply with applicable storm water regulations. In order to comply with these requirements, a comprehensive program to reduce polluted urban runoff originating from residences has been implemented. These activities are further described in the following subsections. 5.1 Threat to Water Quality Prioritization One of the most important tasks is to identify pollution sources, assess the threat to water quality, and require the implementation of appropriate BMPs to eliminate those sources of pollution from residential locations. Each year, hundreds of new residents move into Carlsbad. Residents are typically the most common sources of pollution as identified by the JURMP. The City borders over 6 miles of coastline and has three coastal lagoons partially or completely within jurisdictional limits. Because of these water bodies and their tributaries, residential activities have the potential to impact water quality. Table 5.1 identifies the constituents of concern in Carlsbad and examples of residential sources. Table 5.1: Constituents of Concern and Examples of Residential Sources. Constituents of Concern Examples of contributing activities Primary • Bacteria Pet waste, sanitary sewer overflows, etc. • Sediment Landscaping, un-permitted grading activities, etc. • Nutrients Garden-care activities, materials storage, etc. • TDS Fertilizers, construction, agriculture Secondary • Pesticides Garden-care activities, residential pest control, etc. • Trash Storage of solid waste, green waste, etc. Residents are required to use BMPs when conducting high priority activities. Residents are provided information about how their activities can adversely impact water quality and what they can do to prevent pollution. The City continues to address residential activities through outreach efforts at the local, watershed, and regional levels using the most efficient and cost-effective methods available. In addition, high priority activities were also addressed during investigations of illicit connections, illegal discharges, or other public complaints. Specific education efforts are further detailed in Section 9 of this report. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 41 5.2 Pollution Prevention Pollution prevention includes proactive approaches residents can take to identify and reduce pollution sources. Proactive pollution prevention, when framed in the context of appropriate BMP identification, use, and maintenance is a key component to improving regional water quality. Education is the focus of the City’s residential pollution prevention efforts and is the best approach to increasing awareness, changing behavior, and providing timely enforcement of storm water violations. 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 specifically developed for residents. Pollution prevention messages 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 City has also successfully implemented a Household Hazardous Waste (HHW) program and continues to promote used oil recycling for all residents. During FY 05-06, the City collected and disposed (including recycled or diverted) of 464.63 tons of HHW. More information about the HHW program can be found in section 8.5 of this report. In February 2006, the Carlsbad City Council approved the creation and implementation of a new HHW door-to-door pick up program. The door-to-door collection program is contracted through Clean Harbors Environmental Services Inc. and offers residents a toll-free phone number (1-800-444-4244) to call for a disposal appointment. The program provides a means for Carlsbad residents to have HHW picked up from their homes and hauled away for a nominal fee. The service costs residents a $10 co-payment (the City share is $80 per collection) for pick-up and the maximum weight allowable is 15 gallons or 125 pounds. Appointments are typically made a week from the collection date and collections occur on Wednesday or Thursdays. In addition, residents can also dispose of HHW for free at three permanent facilities in Vista, Oceanside, and Poway. A copy of the HHW collection brochure is found in Appendix 5-1. The process for door-to-door collection is: • Residents collect HHW material at home. • Call Clean Harbors Environmental Services and schedules an appointment. • On the day of the appointment, residents place HHW material on their porch, in front of their garage, or in a safe location and in a sealed container. • Clean Harbors Environmental Services comes by and collects the materials. In April 2006, the City sponsored a free HHW disposal day where Carlsbad residents could dispose of up to 15 gallons or 125 pounds of HHW materials. The event attracted 232 residents and everyone was offered the Environmental Programs brochure as well as the Door-to-Door HHW brochure. The City collected and disposed of 18,298 pounds of HHW during this event. Table 5.2 shows the types and quantities of HHW collected at the event. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 42 Table 5.2: Items Collected During April 22, 2006 HHW Event. Containers Material TOTAL Pounds 2 Flourescent Bulbs 35 5 TVs/Monitors 2,500 2 Misc Electronics 1,000 1 CPU Towers 500 8 Latex Paint (55 gal drums) 4,800 1 Car Batteries 1,100 5 Paint 4,000 1 Oil Filters 21 5 Flammable Liquids (gas/petroleum distillates) 1,000 2 Flammable Liquids (diazinon/ malathion) 400 7 Propane 140 1 Toxic Solids 200 1 Cleaners/Fertilizers 500 9 Consumer Commodity 9 1 Corrosive Liquid Acidic Inorganic 200 1 Corrosive Liquid Acidic Organic 105 1 Corrosive Liquid Basic Organic 158 1 Aerosols 350 1 Batteries 180 2 Used Oil 800 1 Antifreeze 300 TOTAL 58 WEIGHT OF ALL HHW MATERIALS 18,298 Per Individual 78.87 The public continued to use the Environmental Programs hotline and e-mail address to request information about the HHW program, trash, and recycling. In addition, the City’s RFA system was used to track calls about Environmental Programs comments and questions from residents. During FY 05-06, the Environmental Programs Division responded to 59 complaints related to HHW, recycling, and solid waste. Table 5.3 includes a summary of these complaints. Table 5.3: Summary of Environmental Programs Division Complaints RFA Issue Type Number HHW: Comment or Suggestion 1 HHW: Complaint 1 Recycling: Comment or Suggestion 1 Recycling: General Information 9 Recycling: Complaint 8 Solid Waste: Comment or Suggestion 1 Solid Waste: Complaint 25 Solid Waste: General Information 5 Solid Waste: Missed Collection 8 TOTAL 59 City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 43 The City worked with Waste Management to add an additional day and items to the bulky item pickup schedule. Bulky item pick days for FY 05-06 were as follows: • July 23, 2005 • October 22, 2005 • January 28, 2006 • April 22, 2006 Water Conservation Program The City’s Water Conservation Specialist works with the Storm Water Protection Program to help address and reduce the discharge of irrigation and the pollutants it can carry. The Water Conservation Specialist responded to 315 related complaints during FY 05-06, including over-irrigation, leaks, and sprinkler line breaks in residential areas. Occasional work with Home-owners Associations and commercial property management companies is also part of the program. 5.3 Best Management Practices Implementation The City continues to implement a program to reduce contaminants in urban runoff originating from existing residential areas. BMP information was made available to residents during investigations, in printed materials and direct mailings, at workshops, on the storm water website and hotline, during presentations, and at outreach events. A listing of all education and outreach events for residential audiences is in Section 9 of this report. The City has identified minimum BMPs for high priority residential activities and worked to ensure that BMPs were implemented. City inspectors required the following minimum BMPs (detailed in various fact sheets and brochures) for all residential sources: • Move or cover potential pollution sources from storm water contact. Protect materials that could potentially contribute to storm water pollution by storing them indoors or covering them. • Use dry cleanup methods. Washing or cleaning activities that involve the use of a water hose or pressure washing system were required to use dry clean up methods (mops, brooms, rags or wire brushes to clean pavement, buildings and equipment as much as possible). • Residential car washing. Use soap sparingly, divert wash water to landscaped areas and pour buckets of soapy water down the sink. Never wash cars in the street or public right of way. • Pet Waste. Clean up after pets. Use a bag to pick up waste when walking pets. Flush pet waste down the toilet or dispose of in a sealed plastic bag and deposit in the trash. • Trash Management. All trash must be kept in appropriate sized containers until it can be hauled away. Frequently dispose of grass, debris, leaves, and other waste materials. • Recycle, Reduce and Reuse. Recycle cans, bottles, paper and cardboard whenever possible. • Reduce the Use of Landscape Chemicals: Decrease the use of lawn and garden care products such as pesticides, weed killers and chemical fertilizers. Consider using non-toxic pest control methods. Avoid over irrigation which washes these chemicals into the storm drain system. Printed Materials The Environmental Programs Division updated the “Put Toxic Waste In Its Place,” fact sheet to include the new HHW collection sites, phone numbers, addresses, Environmental Programs logo, web address, and map of disposal locations. During FY 05-06, the updated fact sheet was distributed by mail and at outreach events. A copy of the revised fact sheet can be found in Appendix 5-2. The City worked with the North County Outreach Group to develop a new informative pledge card designed to not only provide information about storm water and pollution prevention, but also collect data about local residents. This information will be used to develop mailing lists for future events (Figure5-1). City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 44 Figure 5-1: Residential Pledge Card Developed by the North County Outreach Work Group In March 2006, the City developed a new brochure for mobile service providers. This brochure was designed for mobile service providers, their employees, and residents that hire a mobile service provider. During FY 05-06, the “Best Management Practices for Mobile Service Providers” brochure was provided to residents during complaint investigations related to mobile service provider discharges. The City also continued to distribute the “Pollution Prevention Guide for the Construction Industry” developed by the North County Outreach Group. This brochure was developed to provide BMP and pollution prevention information related to materials storage, perimeter controls, building and staging areas, dumpsters and port-a-potty services, tracking controls, concrete trucks and pumpers, washout areas, dirt and grading, earthmoving equipments, and storm drain protection. The brochure was distributed to residents who conduct small remodeling or home improvement projects. In March 2006, the City developed a new street sweeping notification door hanger. The door hanger was developed to help notify residents of street sweeping schedules so that they can move their cars and allow the street sweeper better access to clean the curb face and gutter. A copy of the street sweeping door hanger can be found in Appendix 5-3. In June 2006, the City’s Public Works Department revised the “Public Works At Your Service” brochure. The revised brochure includes information about the Environmental Programs Division covering storm water, water conservations, and trash management. The brochure was sent to all Carlsbad residents. A copy of the revised brochure can be found in Appendix 5-4. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 45 Direct Mailers In the spring of 2006, the “Pet Waste” BMP brochure was revised to include the Environmental Programs logo, phone number and email address. The brochure was designed to educate residents about the effects of pet waste on storm water and the proper disposal of waste products. In June 2006, the revised brochure was mailed to all Carlsbad households with the City’s utility bills for trash and water. A copy of the revised pet waste brochure can be found in Appendix 5-5. The Carlsbad Community Services Guide is mailed three times a year to all Carlsbad households (approx. 40,000). The fall 2005 and summer 2006 editions included residential storm water BMPs and the Environmental Programs information. Website and Hotline Information about water conservation, trash management, and storm water has been combined to one centralized web page accessed at www.carlsbadconserves.org. The Environmental Programs hotline provides information about storm water, trash, and water conservation for the public. The hotline is answered by the Storm Water Protection Program during business hours and provides a detailed voice message after hours. In addition, outreach materials continue to be revised to include the Environmental Program’s web page address and hotline number. During FY 05-06, there were over 2,750 visits to the storm water web page and 12,860 visits to the Environmental Programs web page. Workshops The City sponsored two workshops entitled, “Learn How To Maintain a Smart Lawn” held on August 20, 2006, and “Composting for the Health of Your Soil”, held on February 11, 2006. At the workshops, residents received information on water conservation, mulching, plant selection, proper irrigation practices, home composting, and fertilizer and pesticide alternatives. This educational workshop clearly demonstrated the relationship between water conservation, solid waste, and storm water. Presentations On October 22, 2005, the City conducted a presentation for the Agua Hedionda Lagoon Foundation about the Carlsbad Watershed and storm water program. Twenty Carlsbad residents were in attendance and received information about BMPs and storm water protection. The participants were most interested in information about illegal discharges, pesticide application, and detention basin maintenance. Twice a year, the City hosts an event called “Citizen’s Academy.” This seven week course (one night per week) educates Carlsbad residents about 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 at the academy. Approximately 60 residents attended two academies held on September 22, 2005 and March 23, 2006. Events The Environmental Programs Division sponsored a composting bin sale event on June 17, 2006, in an effort to get more residents to compost trash instead of throwing it away. During FY 05-06 over 320 composting bins were sold to Carlsbad residents. The composting bins will be continuously on sale. In September 2005, the City sponsored its annual “Buena Vista Creek Clean Up” event. Over 230 volunteers, several of them Carlsbad residents, collected over 3 tons of trash and recyclables along Buena Vista Creek. The clean up effort was a part of the annual California Coastal Cleanup Day and was the second time the City had over 100 volunteers contribute their time at this event. Common items found included fast food containers, recyclable glass and plastic beverage containers, and cigarette butts. Larger items included tires, bed frames, carpets, and wood pallets. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 46 In celebration of Public Lands Day, the City’s Parks Department sponsored a clean up event at Lake Calavera. The event was held in September 2005 and attracted 25 volunteers who assisted with trash and debris removal. In November 2005, the City hosted the “Fall Festival at the Leo Carrillo Ranch” event, attended by over 820 Carlsbad residents. During the event Environmental Programs and Storm Water Protection Program staff was available to answer questions and distribute information about the pollution prevention BMPs. One September 11, 2005, the City held its annual “Fiesta Del Barrio” event in downtown Carlsbad. The event was designed to celebrate Carlsbad residents and make them more aware of the Barrio’s presence and historical significance. The Storm Water Protection Program was onsite to distribute BMP information in Spanish and English. On April 23, 2006, the Police Department sponsored a dog licensing and rabies clinic event to help educate residents about responsible pet ownership. During the event pet waste BMPs and “Bags on Board” dispensers were distributed to Carlsbad residents. Promotional Items In March 2006, the Storm Water Protection Program purchased approximately 1,000 pollution prevention message pens. The pens were distributed to municipal employees and the Carlsbad community. Items such as water bottles, notepads, mouse pads, and cups with the storm water hotline and other pollution prevention messages continued to be distributed to residents. During FY 05-06, the City purchased and distributed recycling bags to residents at various events. The recycling bags include the Environmental Programs logo, phone number, and were designed to encourage residents to recycle aluminum, glass, paper, and other materials. Neighborhood Outreach Campaign As a result of the Dry Weather Program Monitoring, several neighborhoods were identified as contributing to storm water pollution through various residential activities. The 2006 Dry Weather Monitoring Program report included recommendations to educate residents in five specific neighborhoods. In response, the Storm Water Protection Program conducted a targeted outreach campaign to those identified neighborhoods. The identified neighborhoods were delineated using the City’s interactive GIS. Layers were turned on to show the streets, parcels, and storm drain system in the identified neighborhoods. In December 2006, the City sent an information letter and BMPs to residential areas that were identified as potential contributors to storm water pollution (e.g., pet waste, car washing, and landscaping activities). Table 5.4 includes a summary of the number of homes targeted and the information they received. Table 5.4 Targeted Neighborhood Education. Neighborhood Site Number of Homes Brochures Distributed AH-24 81 Over-watering BA-06 75 Over-watering BA-13 100 Landscape waste and over-watering AH46 107 Over-watering and pet waste BA-40 200 Over-watering Total 563 City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 47 5.4 Enforcement of Residential Areas and Activities The public can report illegal discharges or any activities that may impact water quality to the Storm Water Protection Program through the storm water hotline, email address, or to other City departments. All reports and referrals were promptly investigated and resolved to the fullest extent. When a storm water complaint was received about a residential site or source, or an illegal discharge was observed or suspected, the City conducted a complete storm water investigation. 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. 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 residents 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, City inspectors 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 Enforcement Response Plan continued to be used by inspectors to identify, document, and respond to storm water violations. 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 as required. Escalating enforcement procedures provided flexibility in establishing appropriate compliance time frames. In judging the degree of severity, City inspectors also took into account any history of similar incidents or discharges and the impact to the environment. 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 warning to monetary fines. During FY 05-06, the Storm Water Protection Program received 107 complaints of potential illegal discharges. Most were residential with only 10 of these involving commercial or industrial facilities located in Carlsbad. However, many of the residential complaints did involve commercial contractors or mobile businesses. Of the residential complaints, there were 14 where no violation was found (either because it was an exempt discharge or a source was not found as reported). The City issued 16 verbal warnings and sent 13 informational letters. When verbal warnings or informational letters were not sufficient to achieve compliance, or additional documentation or enforcement was warranted, the City issued written warnings or a NOV. The City issued 5 written warnings and 3 NOVs to achieve compliance. A summary of all residential enforcement actions is found in Table 5.5. Table 5.5 – Summary of Residential Enforcement Actions in FY 05-06. Action Total Verbal Warning 16 Informational letter 13 Written Warning 5 Notice of Violation 3 Notice to Clean 0 Cease and Desist Order 0 Administrative Citation 0 TOTAL 37 City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 48 During FY 05-06, a new Notice to Clean form and streamlined NOV form were created to help facilitate prompt and proactive response from businesses. In addition to completing 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), Environmental Specialists are continually trained on code enforcement, inspection procedures, laws and regulations, and investigation techniques. Staff attended the following training during FY 05-06: • July 2005 Clean Water Summit, San Diego Ca • July 2005 Communicating Between the Lines, San Diego, Ca • August 2005 Dealing With Difficult People, Carlsbad, Ca • November 2005 High Impact Communications, Carlsbad, Ca. • March 2006 Hazardous Waste Operations and Emergency Response, San Diego, Ca • May 2006 Introduction to the Incident Command System, Carlsbad Ca. These training courses, in addition to the Enforcement Response Plan, helped the Storm Water Protection Program to appropriately identify and respond to storm water violations. 5.5 Self-Assessment Program Strengths In February 2006, the Carlsbad City Council approved the implementation of a new HHW pick up program. The program provides a means for Carlsbad residents to have HHW picked up from their homes and hauled away for a nominal fee. In addition, residents can also dispose of HHW for free at three permanent facilities in Vista, Oceanside, and Poway. The Environmental Programs Division sponsored a composting bin sale event in an effort to get more residents to compost trash instead of throwing it away. During FY 05-06 over 320 composting bins were sold to Carlsbad residents. In April 2006, the City sponsored a free HHW disposal day where 232 Carlsbad residents disposed of 18,298 pounds of HHW. The City plans to make this an annual event. In March 2006, the City developed a new brochure for mobile service providers. During FY 05-06, the “Best Management Practices for Mobile Service Providers” brochure was provided to residents during investigations. In March 2006, the City developed a new street sweeping notification door hanger. The door hanger was developed to help notify residents of street sweeping schedules so that they can move their cars and allow the street sweeper better access to clean the curb face and gutter. In June 2006, the City’s Public Works Department revised the “Public Works At Your Service” to include information about the Environmental Programs Division covering storm water, water conservation, and trash management. The Storm Water Protection Program depends on other City departments to assist with investigations and remediation during field reviews. The City’s Street Department, specifically the Storm Drain Maintenance Crew, was 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. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 49 The City continued to utilize university students as part of the 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, business reviews, outreach, data entry, monitoring and investigations increased productivity. The Storm Water Protection Program once again met the goal of responding to complaints “happening right now” within 30 minutes. This goal was met over 90% of the time during FY 05-06. Non- compliance by mobile businesses decreased significantly over the past year. Program Improvement Areas The Storm Water Protection Program staff began working with the City Attorney’s office to revise the storm water ordinance to reflect current enforcement levels and mechanisms. Revision and Council approval should be complete by the end of FY 06-07. In late FY 05-06, the Storm Water Protection Program began drafting a “Best Management Practices Manual” that includes the minimum and required BMPs for activities and pollutant types. The manual will be continually worked on during FY 06-07 and should be completed by early FY 07-08. The City will provide an update on the progress of the manual in the next annual report. In FY 03-04, the City worked with Waste Management to develop an Environmental Programs booklet that included storm water residential BMPs, as well as detailed information on available solid waste services, including oil recycling and HHW disposal sites. The booklet needs to be revised to reflect the most current HHW, trash, recycling, storm water, and water conservation information. The revision should be completed in late FY 06-07 and will be reported in the next annual report. During FY 04-05, staff begin revising brochures and fact sheets and updating them to reflect changes in the program. A complete revision of all brochures will take time to complete. However it is expected that this project will be completed by late FY 07-08. Runoff from residential irrigation continues to be an issue based on complaints received and the results of the Dry Weather Program. The Environmental Programs Division will continue to investigate the best ways to promote water conservation and to reduce irrigation runoff. The City will be working with the Olivenhain Water District to develop a new door hanger to educate residents about water conservation and storm water. The door hanger will be left at residences where over irrigation has been observed. The door hanger not only includes BMP information, but also the Environmental Programs web address and hotline number. The City will continue to advertise Environmental Programs and to seek the most cost-effective way to educate the public. In additional, the City will continue to work with the watershed stakeholders to address the residential community and outreach programs on a watershed basis. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 50 Section 6 Land-Use Planning Component 6.0 Overview The City continues to evaluate land use planning policies and principles, revise the environmental review procedures, and develop approval processes that minimize the impacts of development activities on receiving water quality. This section outlines Land-Use Planning actions implemented since the Permit was issued and during FY 05-06. It also 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 adopted a Comprehensive Update of its General Plan. The General Plan includes goals that balance environmental protection with smart, long-term economic growth. By laying out a clear vision for environmentally sensitive development within this coastal community, development projects are required to be consistent with various City ordinances (i.e.; Grading and Erosion Control, Storm Water Management, Hillside Development, Coastal Resource Protection) and other regulatory requirements. In July 1986, the City adopted a Growth Management Plan into its General Plan to guide development and anticipate the types and numbers of facilities needed to accommodate the Carlsbad community at build out. Those facilities include sewer plant capacity, sewage pipelines, reclaimed water system, and storm drain system with flood and pollution control basins. The General Plan is reviewed annually and revised as necessary to ensure that the public interest is considered and City goals are met. On February 19, 2002 the City Council adopted General Plan Amendment GPA 01-15. This General Plan Amendment revised/supplemented various policies regarding water quality protection in the Open Space and Conservation Element. The new policies reflect water quality and watershed protection principles found in the Permit pertaining to water pollution, and were all implemented in FY 05-06. The General Plan was reviewed in FY 05-06 and no revisions were necessary. The revised policies and programs from 2002 are listed below: a) Develop and implement a JURMP consistent with the Permit and any amendments thereof. b) Adopt and implement a Master Drainage Plan and Standard Urban Storm Water Mitigation Plan (SUSMP) consistent with the Permit and any amendments thereof. c) Prior to making land use decisions, utilize methods available to estimate increases in pollutant loads and flows resulting from projected future development. The City requires developments to incorporate structural and non-structural BMPs to mitigate any increases in pollutant loads. d) Implement storm water pollution prevention methods to the maximum extent practicable, supplemented by pollutant source controls and treatment. Use small collection strategies located at, or as close as possible to, the source (i.e., the point where water initially meets the ground) to minimize the transport of urban runoff and pollutants offsite and into the MS4. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 51 e) Post-development runoff from a site shall not contain pollutant loads which cause or contribute to an exceedance of receiving water quality objectives or which have not been reduced to the maximum extent practicable. f) Developments shall implement appropriate recommendations to protect water quality found in the San Diego Association of Government’s (SANDAG’s) Water Quality Element of its Regional Growth Management Strategy. g) Development projects should be designed to comply with the following site design principles: • Protect slopes and channels to decrease the potential for slopes and/or channels from eroding and impacting storm water runoff. • To the extent practicable, cluster development on the least environmentally sensitive portions of a site while leaving the remaining land in a natural undisturbed condition. • Preserve, and where possible, create or restore areas that provide important water quality benefits, such as riparian corridors, wetlands and buffer zones. Encourage land acquisition of such areas. • Provide buffer zones for natural water bodies. • Minimize the amount of impervious surfaces and directly connected impervious surfaces in areas of new development and redevelopment. • Where feasible implement site design/landscape features to slow runoff and maximize on-site infiltration of runoff. • Properly design outdoor material storage areas (including the use of roof or awning covers) to minimize the opportunity for toxic compounds, oil and grease, heavy metals, nutrients, suspended solids and other pollutants from entering the storm water conveyance system. • Incorporate roof or awning covers over trash storage areas to prevent off-site transport of trash and other pollutants from entering the storm water conveyance system. • Limit disturbances of natural water bodies and natural drainage systems caused by development including roads, highways and bridges. • Design streets and circulation systems to reduce pollutants associated with vehicles and traffic resulting from development. 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 and six other cities in north 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 has prepared a subarea plan, called the Carlsbad Habitat Management Plan (HMP) that was adopted in November 2004. The Carlsbad HMP contains the specific conservation, management, facility planning, land use, and other actions the City will take to implement the goals, guidelines, and standards of the MHCP plan. This HMP prohibits development in or near natural habitat areas including creeks and lagoons. Those areas act as a buffer between urban development pollutants and receiving waters. They also protect a significant percentage of pervious surface necessary to absorb run off. The Carlsbad City Council adopted a Zone Code Amendment (ZCA 01-08), Local Coastal Program Amendment (LCPA 01-15) and Municipal Code Amendments (MCA 01-05, 01-06, and 02-01) to revise/add new policies, standards, procedures and requirements regarding water quality and watershed protection to the Local Coastal Program Land Use Plans, Chapters 21.203 (Coastal Resource Protection Overlay Zone) and 21.205 (Coastal Resource Overlay Zone Mello I LCP Segment Local Coastal Program) of the Zoning Ordinance and Chapters 15.12 (Storm Water Management and Discharge City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 52 Control) and 15-16 (Grading and Erosion Control) of Carlsbad's Municipal Code. On November 1, 2002, the revised Zoning Ordinance, Municipal Code, and Local Coastal Plan Amendments were submitted to the California Coastal Commission. In August, 2006, the California Coastal Commission approved these municipal code amendments. All requirements of these documents were implemented in FY 05-06 and previous years while the City waited for Coastal Commission approval. Carlsbad is one of the first coastal cities in San Diego County to have amended NPDES /storm-water regulations approved by the Coastal Commission. 6.2 Modification of Development Project Approval Process Actions The City requires proposed development projects to implement measures to ensure that pollution and runoff from the development will be reduced to the maximum extent practicable and will not cause or contribute to an exceedance of receiving water quality objectives. All project applicants are required to submit a Storm Water Requirements Applicability Checklist (Checklist) concurrent with submittal of an application for a discretionary or administrative approval in accordance with the requirements of the City’s SUSMP (approved by the Regional Board on June 12, 2002). The Checklist is used by City staff to determine those projects which meet the priority development project category and are subject to the SUSMP requirements. Developments that are determined to be “priority development projects” are subjected to both the “Priority Permanent Storm Water BMP Requirements” and the “Standard Permanent Storm Water BMP Requirements” consistent with the SUSMP. Priority development projects are required to submit a Water Quality Technical Report consistent with the SUSMP standards before the project application is deemed complete. Additionally, applicants for priority development projects must incorporate the standard site design and source control BMPs as well as the BMPs for “Individual Priority Project Categories and Treatment Control BMPs” consistent with the SUSMP requirements. All non-exempt development projects are required to incorporate standard site design and source control BMPs consistent with the SUSMP prior to project approval. The City includes several standard conditions of approval to each discretionary and administrative approval including conditions requiring the developer to: 1. Comply with the City's Permit. 2. Submit a SWPPP prior to construction permit issuance (for projects that are subject to the General NPDES Permit for Storm Water Discharges Associated with Construction Activities). 3. Submit a “Storm Water Management Plan” (SWMP) prior to issuance of construction permits for the project (for projects that require permanent BMPs). 4. Exercise special care during the construction phase of the project to prevent offsite siltation and to comply with City planting and erosion control standards. 5. Provide proof of NOI submittal to the State Water Resources Control Board prior to start of grading work, if applicable. Additionally, special conditions are applied to projects requiring developer construction of all project related and master-planned drainage improvements in accordance with City Standards and the requirements of the Permit. There are no standard project conditions of approval applied to ministerial permits; however, each ministerial permit is required to comply with the referenced standard conditions prior to issuance of the respective ministerial permits. In FY 05-06, the City approved 53 development applications that were determined to be projects subject to the Priority Permanent Storm Water BMP Requirements as defined in the City SUSMP. A list of the 53 “priority development projects” can be found in Appendix 6-1. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 53 6.3 Revisions to Environmental Review Process Actions Consistent with the Permit, the City’s Initial Study Environmental Review Checklist Form was updated in March 2001 to incorporate additional focused hydrology and water quality questions to be considered by Community Development staff during the Initial Study process under CEQA. The review of all discretionary projects is consistent with CEQA requirements. Project proposals are reviewed to ensure that all development will be in compliance with the new/revised Grading, Storm Water, and Coastal ordinances, the Permit, local permits, and all other applicable ordinances and requirements. In FY 05-06, prior to project approval and issuance of local permits, the City required 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 Weekly staff meetings include a review of new discretional permits, discussions about specific/general topics about pollution control, new projects and of proper source and/or treatment control BMPs, past experiences, design alternatives, effectiveness, long-term maintenance, and other issues related to water quality. A list of all training and topics can be found in Appendix 6-2. On May 18 and June 1, 2006, the City co-sponsored two “Post-Construction Best Management Practices” seminars. The seminars were designed to assist the development community in understanding the post construction BMP requirements and provide information about expectations and specific jurisdictional requirements. The Storm Water Protection Program mailed 112 invitations to the seminars, which also included BMP information. On June 15, 2006, the Storm Water Protection Program presented a training program to City Planning staff on storm water and pollution prevention. Approximately 22 planning employees were in attendance. The City also continued to distribute the “Pollution Prevention Guide for the Construction Industry.” This brochure was developed to provide BMP and pollution prevention information related to materials storage, perimeter controls, building and staging areas, dumpsters and port-a-potty services, concrete trucks and pumpers, washout areas, and storm drain protection. 6.5 Self Assessment Program Strengths City personnel continue to build upon the storm water BMP database. Procedures have been put into place to link the BMP database to the City GIS maps. The database will assist the City in monitoring locations and types of permanent BMP measures and to track maintenance inspections. Program Improvement Areas The City will be conducting a business process review of the development project approval process in FY 06-07. In addition to other things, the business process review will address improvements in record keeping for compliance with the Permit and SUSMP requirements. This will help to ensure compliance with storm water regulations and to assist staff in preparing additional useful numeric data for the JURMP annual reports. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 54 The City also intends to adopt new storm water BMP maintenance agreements in FY 06-07 and incorporate as standard operating procedure. The current method of ensuring compliance with storm water BMP maintenance requirements is through provisions included within project CC&Rs. The new BMP maintenance agreements will provide increased control over property owner compliance with storm water BMP requirements. These new agreements will also provide the City with legal authority to access, inspect, and if necessary maintain onsite BMPs. In addition, the agreements will allow the City to place a lien on a property if BMPs are not maintained as required by the agreements. The City will reassign an Associate Engineer in the Development Services Division to work on storm water compliance issues related to the development review and permit approval process in FY 06-07. The intent of the reassignment is to advance compliance with the proposed NPDES Permit Order No. R- 9-2006-0011 and to enhance implementation of BMP strategies into new and development plans. The reassignment will also assist in the provision of more targeted and extensive training and education of Development Services staff, private land developers, and their professional consultants with specific emphasis on incorporating source control BMPs into land development projects. The City will also be reviewing and updating the Storm Water Requirements Applicability Checklist in FY 06-07. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 55 Section 7 Construction Component 7.0 Overview The City has implemented activities that address and minimize 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 05-06, the City updated the construction inventory, inspected all high priority sites, conducted outreach and education 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 during the grading permit process to develop and update a watershed based inventory of all construction sites that require grading permits regardless of site size or ownership. Construction sites with grading permits may include sites where activities such as grading, excavation, clearing, road construction, structure construction, or demolition results in the disturbance of soil. The City prioritized all sites with active grading permits for FY 05-06 as high priority for the purposes of conducting site inspections. This inventory is maintained throughout the year and updated weekly. A copy of the inventory can be found in Appendix 7-1. 7.2 Pollution Prevention Pollution prevention consists of procedures and practices that eliminate or reduce the pollutants at the source. The City has identified and required implementation of the following pollution prevention controls 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. • Engineering inspectors enforce implementation of BMPs described in approved erosion control plans and SWPPPs. The City has adopted the pollution prevention measures contained in the Storm Water Best Management Practice Handbooks, published by the California Storm Water Quality Association (CASQA), Caltrans Storm Water Quality Handbooks, and Standards for Design & Construction of Public Works Improvements in the City of Carlsbad. 7.3 Construction and Grading Approval Process During FY 05-06, the City began verifying NOI validity prior to issuance of a grading permit or Notice to Proceed for CIP projects. Prior to having a pre-construction meeting and issuing a grading permit, the CMI verifies a valid NOI is in place for projects required by the State. The Construction Manager reviews the State’s online database to ensure a NOI has been issued prior to assigning the project to an inspector for grading permit issuance. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 56 The City updated the Construction and Grading approval process during FY 03-04 and continued implementing this process in FY 05-06. The City ensures that all construction sites with a grading permit implement measures to reduce pollutants to the maximum extent practicable. Prior to approval of a grading permit, the project proponent is required to 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 grading 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). In previous years, the City modified its requirements to be consistent with the General Construction Permit, requiring projects one acre or larger to prepare a SWPPP, and continued implementing this requirement in FY 05-06. The City has also defined a process to outline how BMPs and other pollution prevention measures will be required and implemented. The process has been implemented for several years and is described as follows: Construction Permit Application A fact sheet (checklist used to define applicability of requirements) has been developed in accordance with the Permit that identifies and prioritizes construction activities. The fact sheet is completed by the construction permit applicant and reviewed by CMI staff who also assist the applicant in determining the appropriate BMPs and documentation required (SWPPP, SWMP, erosion plan, minimum BMPs, etc.) 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 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 captures construction sites 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 reviews applications to determine the adequacy and accuracy of the information. During the permitting process, the appropriate BMPs, pollution prevention methods, 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 Permit into local construction and grading permits. A grading permits checklist was developed to ensure construction and grading requirements are incorporated into the construction/building permits and the City continued to use this checklist in FY 05-06. The following construction and grading requirements are incorporated into the construction and building permits through the use of a checklist: City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 57 The project proponent must: • Develop and implement a plan to manage storm water and non-storm water discharges from the site; • 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, the project proponent is required to implement additional rainy season BMPs, 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. 7.4 Best Management Practice Implementation CMI continues to train all inspectors on the appropriate application of construction site BMPs. In addition to using the previously adopted and modified CASQA and Caltrans BMPs, the City also implemented new and improved BMPs during FY 05-06. The City continues to review new and varying site BMPs proposed for use on private development sites. This year, CMI reviewed and accepted Streamhawk® inlet protection devices (http://www.stream-hawk.com/) for installation in a project specific application. The devices were found to be an effective alternative to gravel bags and other forms of inlet protection when used on specific sites for temporary erosion control purposes. During the rainy season, little to no maintenance was required and they are anticipated to last for several seasons until building construction activities begin. The cost of installation is more than offset with the need for on- going maintenance, re-grading the pad or repair slope damage. During FY 05-06, the City‘s standard for stabilizing rough graded residential lots was clarified to include the CASQA and Caltrans standard drawing numbers as reference materials (Appendix 7-2). SWPPPs and erosion control plans are reviewed prior to commencement of construction activities to ensure that the required minimum BMPs are implemented. The seven required minimum BMPs, as identified in the JURMP, are: 1. Erosion control methods for graded slopes: 2. Erosion control method 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; and 7. Non-storm water management control. To address each of the required BMPs, the City ensures the SWPPPs and/or erosion control plans include implementation of the following types of BMPs as applicable, depending on site-specific requirements. The list below corresponds to the numbered BMPs above: City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 58 1. Hydroseed applications, bonded fiber matrix application, Geotextiles and Mats, straw waddles, silt fences, and fiber rolls are incorporated into the City approved erosion control plans and project SWPPP’s as applicable. 2. Irrigated and non-irrigated hydro-seed mixes’, gravel bag and/or sandbag barriers, silt fence, and fiber rolls are incorporated into approved erosion control plans and SWPPPs as applicable. 3. Silt fences, earthen berms, velocity dissipaters, gravel bag and/or sandbag barriers, and drainage swales are incorporated into approved erosion control plans and project SWPPPs as applicable. 4. Construction entrances and tire washing stations are incorporated into approved erosion control plans and project SWPPP’s as applicable. 5. Vehicle and equipment maintenance, fueling and cleaning stations, material storage and delivery yards are protected and concrete washout basins are incorporated into approved erosion control plans and project SWPPPs as applicable. 6. Covered receptacles are incorporated into all projects at strategic locations, litter removal programs are incorporated into the project schedules, ensuring material storage is isolated from drainage facilities and watercourses, and other source control BMPs are incorporated into City approved erosion control plans and project SWPPPs as applicable. 7. Non-storm water management generally includes source control BMPs such as paving and grinding operations, dewatering operations, water practices, etc. These BMPs are incorporated into City approved erosion control plans and project SWPPPs as applicable. 7.5 Inspection of Construction Sites The City continues to prioritize all construction sites with active grading permits as high priority. These sites are inspected on a weekly basis to ensure proper installation and maintenance of pollution prevention BMPs. For the purposes of this report, a report was generated which illustrates the active grading permits and priority of each for FY 05-06. Appendix 7-1 is an inventory of active grading permit construction sites and CIP projects. The City performed 3,385 construction site inspections during FY 05-06. The inventory in Appendix 7-1 shows 202 sites with active grading permits and 36 CIP sites. Inspectors are out on CIP projects daily covering a number of issues including storm water issues. It is important to note that not all sites on the inventory were active during the entire rainy season. The City currently has a system of tracking required inspections, which is monitored on a weekly basis to ensure compliance. Information from completed inspections is entered into a database and annual reports are processed from this database for reporting purposes. 7.6 Enforcement of Construction Sites There have been no changes in the enforcement process during this fiscal year as described in the City’s JURMP. Table 7-1 is a summary of enforcement actions taken by the City during FY 05-06. A detailed report is available upon request. Table 7.1. Summary of Enforcement Actions at Construction Sites in FY 05-06 Actions Taken Number of Actions Field Memo (written warning) 15 Correction Notice 1 Stop Work Notice 14 Total Actions 30 City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 59 7.7 Reporting of Noncompliant Sites There were no changes to the reporting procedures as described in the JURMP. The Public Works Director or designated representative provides verbal notification, within 24 hours, to the Regional 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. The Carlsbad Municipal Code is also used to appropriately respond 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 that are determined to pose a threat to water quality will continue to be reported to the Regional Board. No sites required notification to the Regional Board during FY 05-06. 7.8 Education on Construction Activities The City continues to conduct and participate in workshops to educate external parties, which includes project applicants, developers, contractors, and property owners on the implementation of the storm water program and requirements for construction sites. The City has developed a BMP training program for Engineering Inspectors that is conducted throughout the year. Staff is trained on the installation of specific BMPs. A list of these internal training topics is in Appendix 7-3 and a list of external training is located in Appendix 7-4. On May 18 and June 1, 2006, the City co-sponsored two “Post-Construction Best Management Practices” seminars. The seminars were designed to assist the development community in understanding the post construction BMP requirements and provide information about expectations and specific jurisdictional requirements. 7.9 Self Assessments Program Strengths Incorporating storm water training into regular staff meeting has been highly effective. There are several mandatory topics, with the ability to select a few topics of interest, such as tire washing. Each inspector is required to pick a topic and provide the training. This helps engage the inspector in the topic and take ownership. Repeating the mandatory topics each season is a good refresher course and an opportunity to share ideas for improvement. 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 implemented the inspection of BMP requirements on all grading permit projects. This inspection is scheduled to take place each week between October and April. Each inspection is documented and a copy of the field inspection report is filed in the project file. Program Improvement Areas The City will continue to research and observe various types of BMPs and evaluate their performance. The City will update the Rough Pad Stabilization example to improve developers’ and applicants’ knowledge of the City’s expectations. This activity is expected to be completed in FY 06-07. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 60 The CMI will distribute the ‘Pollution Prevention Guide to the Construction Industry’ brochure with each construction-related permit application. The City will consider posting minimum BMPs on the City’s website for access by the public, permit applicants, developers, and property owners. The City will review inventory management, prioritization practices, inspection and enforcement procedures, training programs, record-keeping, and reporting procedures related to construction activities within the City’s jurisdiction in FY 06-07. Expected improvements include formalizing procedures, documenting common practices, and training employees on existing, improved, and new procedures city- wide. Annual review of written SOPs will be considered for updating procedures and conducting refresher training. Implementation of improvements may include activities occurring in FY 07-08. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 61 Section 8 Illicit Discharges Detection and Elimination Component 8.0 Overview The City continued to conduct a proactive program for detecting and eliminating illegal discharges and illicit connections to the storm drain system. The City’s program actively seeks to identify and eliminate 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. 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 05-06, this monitoring was performed at 60 sites. The City continues to contract out the Dry Weather Monitoring Program to D-Max. Follow-up investigations were conducted by D-Max and City staff, in combination with the action levels and confidence intervals established by the Monitoring Workgroup. The Dry Weather Monitoring Program report for FY 05-06 is under separate cover and a summary of follow-up activities is found in Appendix 8-1. Coastal Outfall Monitoring As required, the City continues to conduct a Coastal Outfall Monitoring Program to detect and mitigate urban runoff discharges to coastal storm drain outfalls. This program monitors ocean and lagoon outfalls and receiving waters for Total Coliform, Fecal Coliform and Enterococci. 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 is 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 Annual Unified Report covering the receiving waters monitoring program. 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. Sources for illegal discharge reports to the City included 40% from the public, 40% from City employees, and 20% from outside agencies. The Storm Water Protection Program also tracked the origins of all received reports and found that during FY 05-06, 38.5% of the reports came through the hotline, 40.5% though other phone numbers and email addresses, in addition to 21% which were observed in the field by City employees. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 62 During regular office hours, Storm Water Protection Program staff answered the hotline, checked emails, and forwarded reported information to the appropriate personnel. When calls were received after office hours, the hotline provided a voice mail message (in English and Spanish) directing complainants to leave a message for follow-up or be directed to police dispatch for emergency response (i.e., dumping of hazardous materials into the storm water system). When an illegal discharge was reported during regular office hours as “happening right now”, an inspector was immediately dispatched to the site. The City tracked this response as a way to measure customer service and because an immediate response minimized the potential for harmful discharges to enter waterways. Being able to respond rapidly also provided a better opportunity for proactive education or prompt enforcement. During FY 05-06, there were 15 reports of washing or dumping to the storm drain system that met the high priority complaint criteria. Inspectors were dispatched to all but one of these incidents within 30-minutes, thus achieving the benchmark of 90%. The public continued to use the Environmental Programs hotline and e-mail address to request information about the HHW, trash, and recycling programs. In addition, the City tracked calls, comments, and questions about Environmental Programs. During FY 05-06, Environmental Programs responded to 59 complaints related to HHW, recycling, and solid waste (Table 8.1). Table 8.1: Numbers and Types of Environmental Program Complaints/Issues in for FY 05-06 Issue Type/SubType Total # HHW: Comment or Suggestion 1 HHW: Complaint 1 Recycling: Comment or Suggestion 1 Recycling: General Information 9 Recycling: Complaint 8 Solid Waste: Comment or Suggestion 1 Solid Waste: Complaint 25 Solid Waste: General Information 5 Solid Waste: Missed Collection 8 TOTAL 59 8.3 Illicit Connection/Illegal Discharge (IC/ID) Investigation and Follow-up During FY 05-06, the Storm Water Protection Program responded to 107 storm water related complaints. In addition, 420 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, and the Streets Department. Table 8.2 includes an issue summary by complaint type. Table 8.2. Total Numbers of Issues in RFA for FY 05-06 by Department Responding (107+420) Issue Type/SubType Department Total # Pet Waste - Private Property Code Enforcement 2 Dirt/Debris-Piles Storm Water Protection Program 16 Erosion from Existing Development Storm Water Protection Program 2 Storm Drain-Dumping to Storm Drain Storm Water Protection Program 28 Storm Drain-Washing to Storm Drain Storm Water Protection Program 57 Storm Water-General Information/Questions Storm Water Protection Program 19 Vehicles-Leaking Oil or Fluids Storm Water Protection Program 7 Water Conservation Environmental Programs 316 City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 63 Issue Type/SubType Department Total # Drainage-Runoff from Street Streets Maintenance 3 Drainage-Water Ponding/pooling Streets Maintenance 4 Litter/Debris-Clean up Request Streets Maintenance 11 Storm Drain-Damaged/Needs Repair Streets Maintenance 3 Storm Drain-Needs Cleaning Streets Maintenance 21 Street Sweeping-Request for Sweeping Streets Maintenance 4 Lift Station-Spill/Leak M & O - Utility Operations 1 Sewer System-Leak M & O - Utility Operations 1 Sewer System-Sewer Stoppage at Cleanout M & O - Utility Operations 12 Sewer System-Sewer Stoppage M & O - Utility Operations 11 Sewer System-Sewer Stoppage Private M & O - Utility Operations 9 Grand Total 527 A complete summary of the above Storm Water Protection Program investigations and responses is found in Appendix 8-2. The City conducted four high priority illicit discharge investigations during FY 05-06. High priority illicit discharge investigations include those that involve hazardous and/or toxic substances and those investigations resulting from complaints to or from the Regional Board. Syntron Bioresearch Spill On November 9, 2005, a City Construction Inspector received a call from the construction site stating that during the normal dewatering activities, a large amount of foam was observed at the discharge point. The site crew stopped pumping and contained the area. The Storm Water Protection Program responded and found a large plume of foam in a pit of murky water. Storm water inspectors determined that the product could not be identified and called Carlsbad Fire Department (CFD) to respond. Storm water personnel located the source at Syntron Bioresearch and found that a 50 gallon drum containing a concentrated industrial soap product had leaked and discharged to the storm drain system. CFD determined that the product had the probability to be hazardous and that the area would need to be protected. CFD notified the County of San Diego Department of Environmental Health Hazardous (DEH) Materials personnel. County DEH staff also found that the material had the potential to be hazardous. They worked with Syntron Bioresearch to have the impacted storm drain system cleaned and materials properly disposed of offsite. County DEH also notified the Office of Emergency Services (OES) about the release. City personnel monitored the cleanup efforts and followed up with a NOV to Syntron Bioresearch. Leo Carrillo Historical Park Investigation In late December of 2005, two discharges from a wetland in the Leo Carrillo Ranch Historical Park were reported to the Storm Water Protection Program. Upon site investigation, it appeared that the materials were the same two materials analyzed and found to be non-hazardous in 2003. The first discharge was a brown rusty liquid with an oily sheen and no discernible odor that covered a larger area than previously observed. The second discharge was a white substance prevalent throughout the wetland area which appeared to originate within the wetland vegetation. The white substance formed in thick sedimentary layers and was collecting as a powdery foam in the peripheral zones of the wetland. In early 2006, it was determined that, due to the recurrence of the substance, an investigation should be undertaken to determine the extent of the discharge, its composition, any hazardous characteristics and possible remedial actions. Samples of water and sediment were collected and analyzed for: metals, total petroleum hydrocarbon, fish bioassay (to determine toxicity) and pesticides. Findings from the County of City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 64 San Diego, Department of Environmental Health, State of CA Fish and Game, and U.S. Fish and Wildlife Service are that the materials are non-hazardous. The results of the investigation are as follows: • Brown rusty water: Site investigations and sampling determined that the brown liquid was non- toxic with low or non-detectable concentrations of heavy metals, total petroleum hydrocarbon, or pesticides. The discharge is most likely the result of naturally occurring swamp liquid consisting of tannins (which cause the rust coloration) and naturally occurring bacteria (which produce foam and an oily sheen to the water). • White discharge: Sampling showed that the water and sediments containing the white substance were non-toxic with low or non-detectible concentrations of metals, total petroleum hydrocarbon, or pesticides. Analysis did suggest that the white discharge could be a calcium deposit. Calcium levels in the water samples were extremely elevated and microscopic analysis suggests the presence of coagulated minerals rather than biological accumulations. McClellan Palomar Airport Plane Crash On January 24, 2006, the City responded to a plane crash adjacent to the McClellan Palomar Airport. As reported a small commuter plan overshot the runway and crashed into directional equipment on the airport, eventually came to stop on City property at the end of Palomar Oaks Way. The Storm Water Protection Program provided information to support emergency response such as storm drain maps, clean up contractors, and BMP recommendations. The County of San Diego took the lead on cleaning up the site and the City required BMPs including erosion control, spill containment, hazardous materials removal and manifest, and storm drain protection. The Storm Water Protection Program conducted follow up site visits and investigations to ensure that the area was properly cleaned up and that there were no adverse impacts to water quality. Vigilucci Cucina Grease Spill On June 30, 2006, the Storm Water Protection Program responded to a complaint that a restaurant grease bin had been knocked over and grease had spilled to the storm drain. City inspectors immediately responded and found that the Vigilucci’s Cucina grease bin had been knocked over and approximately 75- 100 gallons of used cooking oil had spilled to the parking lot and storm drain. The area and storm drain were immediately protected and Vigilucci’s Cucina management was notified of the incident. City inspectors worked with Vigilucci’s Cucina management to secure a contractor who could manage such a large scale clean up effort. The City worked with the contractor to ensure the entire storm drain line, storm water catch-basins, and drainage conduits downstream were cleaned. The spill did not reach the Buena Vista Lagoon or any tributary thereof. 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 used one or any combination of these efforts as necessary to achieve compliance. The ultimate goal is to eliminate the discharge or connection and to prevent future occurrences. Enforcement actions are further discussed in subsection 8.5. During FY 05-06, the Storm Water Protection Program received 107 complaints of potential illegal discharges. Three of these complaints were referred to other agencies (San Diego County HazMat) for follow-up and remediation. All complaints were investigated, however 31 resulted in either a source not being found as described or the source was not an illegal discharge (i.e. groundwater seepage). Table 8.3 lists the total number of illegal discharges and connections identified. During this reporting period, one illicit connection was identified and eliminated. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 65 Table 8.3. Total Numbers of Illegal Discharges and Illicit Connections Identified from Residential, Commercial and Industrial Sources 8.5 HHW and Oil Recycling Programs The City continued to promote a used oil-recycling program where the public can recycle up to 10 quarts of used motor oil and/or 15 quarts of diesel fuel at five locations. Used motor oil was only accepted if it was not mixed with other liquids including water, antifreeze, gasoline, or parts cleaners. Table 8.4 shows the five locations that accept used motor oil for recycling. Table 8.4: Locations in the Carlsbad that Accept Used Motor Oil For Recycling Location Address Phone Number Firestone Store #2252 2545 El Camino Real, Carlsbad, 92008 760-434-8392 Jiffy Lube # 1621 6021 Paseo Del Norte, Carlsbad, 92009 760-431-9875 Big O Tires 2615 State Street, Carlsbad, 92008 760-720-5212 Vista HHW Collection Facility 1165 East Taylor Street Vista, 92084 800-444-4244 Oceanside Permanent Facility 2880 Industry Street, Oceanside, 92056 760-929-9400 The City also promoted the used oil collection program through various outreach and education efforts. The Environmental Programs web page offered residents information on how and where to properly dispose of used oil. There were over 12,860 hits on this web page during this reporting year. The used oil recycling program was also promoted at various public events such as the Public Works Fair, Earth Day, Barrio Festival, and the Citizen’s Academy. The City provided information about disposal locations as well as specific phone numbers to request general information about HHW disposal. Household Hazardous Waste Program The HHW program promoted responsible HHW disposal for the protection of Carlsbad’s environment and community through various outreach and education efforts, which are further detailed in Section 9 of this report. The same outreach methods and tools used for the oil program were employed for the HHW program. The City contracted with Clean Harbors and Waste Management to allow residents to dispose of HHW at the Vista HHW Collection Facility and the Oceanside Permanent Facility. Approximately 2,000 residents used these facilities (602 at Oceanside and 1,398 at Vista) to collect and dispose of 430.55 tons of HHW. This represents a substantial increase of waste collected due to the end of the Universal Waste exemption and subsequent public education of the new law, as well as an increase in advertising by the City to publicize HHW disposal programs. Residents can also use the Environmental Programs hotline or web site to request additional information about HHW collection and disposal. During FY 05-06, Carlsbad residents disposed of the following types of HHW (Table 8.5): 1 Most of the industrial illegal discharges were identified during site inspections. Discharge Eliminated Residential Commercial Industrial1 Illegal discharge 81 20 6 Illicit connection 0 0 0 City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 66 Table 8.5. HHW Amounts Collected at Permanent Facilities in FY 05-06 Activity Quantity (in tons) Flammable solid/liquid 82.16 Oil-base Paint 50.80 Poison (non-Aerosol) 17.70 Radioactive and Explosive 0.01 Organic/Inorganic Acid 4.01 Organic/Inorganic Base 2.90 PCB Waste/Mercury 0.07 Oxidizing Base 0.89 Antifreeze 5.50 Car Batteries 22.20 Latex Paint 126.30 Motor Oil 36.06 Oil Filters 0.88 Household Batteries 2.79 Electronic Waste 42.55 Aerosol Containers 12.53 Other Universal Waste 1.15 Other HHW 20.63 Asbestos 1.45 Total 430.55 In February 2006, the Carlsbad City Council approved a new HHW pick up program that provides a means for residents to have HHW (up to 15 gallons or 125 pounds) picked up from their homes and hauled away. Approximately 34.08 tons of HHW was collected and disposed using the door-to-door program. Table 8.6 shows the number and types of HHW collected by the door-door program. Table 8.6. HHW Amounts Collected by the Door-to-Door Program in FY 05-06 Activity Quantity (in tons) Flammable solid/liquid 2.95 Poison (non-Aerosol) 2.65 Organic/Inorganic Acid 0.29 Organic/Inorganic Base 0.29 Flammable Aerosols 1.40 Latex Paint 23.20 Class9/Non-RCRA 3.30 Total 34.08 The process for door-to-door collection is: • Residents collect HHW material at home. • Call for an appointment using the toll-free number (1-800-444-4244). • On the day of the appointment, place HHW material on the porch or in front of the garage in a safe location and in a sealed container. • Clean Harbors comes by and collects the materials. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 67 In April 2006, the City sponsored a free HHW disposal day where Carlsbad residents could dispose of up to 15 gallons or 125 pounds of HHW materials. During FY 05-06, 232 residents took advantage of the special HHW collection event and were offered the Environmental Programs and Door-to-Door HHW brochures. The City collected and disposed of 18,298 pounds of HHW during this event. 8.6 Ordinance Enforcement An intensive information and education effort was the first step the City took to eliminate discharges, prevent repeat occurrences, and ensure corrective actions were adequately and promptly implemented. Voluntary elimination of illegal discharges is strongly encouraged. However, when compliance was not achieved, the City initiated enforcement actions. Enforcement was based on the intensity, frequency, duration, and intent of the violation. Enforcement actions can range from a verbal warning to administrative fines. Over the last three years the program has become more enforcement oriented, as considerable time and resources have already been expended to educate the public. Table 8.7 lists the types and numbers of enforcement actions taken during this reporting period. Table 8.7. Total Number of Enforcement Actions Taken for Residential, Commercial and Industrial Sources for FY 05-06 Verbal Warning: In most cases, a verbal warning was sufficient to stop the discharge or correct the violation. Whenever appropriate, these verbal warnings were combined with distribution of educational information. Violations noted at an industrial or commercial site were written in the inspection report. There were a total of 21 verbal warnings given in FY 05-06, compared to 29 the previous year. Information Letter: Informational letters were typically used to provide educational materials for violations reported at residential locations, especially when the violation was not considered a serious threat to water quality. Any potential or illegal discharges observed during an industrial or commercial inspection were addressed on-site, noted in the inspection report, and followed up with enforcement actions as appropriate. There were 13 information letters sent in FY 05-06, compared with 36 sent in FY 04-05. Written Warning: Written warnings provide documentation of an incident, compliance requirements, and constitute the initiation of escalating enforcement actions. There were 31 written warnings issued in FY 05-06, compared with 40 issued in the previous year. Notice of Violation, Administrative Citation and Cease and Desist Orders: A NOV is a formal enforcement action that details specific code violations, corrective actions, and a compliance schedule. If the responsible party does not comply as required, the City could follow up with an administrative citation, starting at $100 per violation. During FY 05-06, a new Notice to Clean form and streamlined NOV form were created to help facilitate prompt response from businesses. There were 31 NOVs issued in FY 05-06, compared with 48 the previous year. There were 10 administrative citations issued in FY 05-06 compared to 11 during FY 04-05. Type of Action Residential Commercial Industrial Total Verbal warning 16 3 2 21 Information letter 13 0 0 13 Written Warning 5 19 7 31 Notice of Violation 3 21 7 31 Cease and Desist 0 0 0 0 Notice to Clean 0 3 2 5 Admin. Citation 0 10 0 10 TOTAL 37 56 18 111 City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 68 8.7 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 public education and outreach, inspections, preventive maintenance, complaint response, and spill response (containment and remediation). The City operates and maintains 18 sewer pump stations. The following inspection and preventive maintenance activities were conducted during this reporting period. Inspection From Monday through Friday, all sewer pump stations were inspected daily. The ten largest pump stations were also inspected 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 were inspected 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 were issued to the Duty Person, Lead Worker, and Supervisor. In the case of power failures, ten of the stations have onsite generators and three stations can be powered by the City’s two trailer mounted generators. Preventive Maintenance During FY 05-06, 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 1,700 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 117 miles of sewer lines were cleaned last year. The maintenance 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. Tables 8.8 and 8.9 detail the percentage of maintenance and cleaning achieved since 2003. Table 8.8. Station Facility Maintenance Since FY 2003 % Maintenance Achieved 2. Activity FY 2003 FY 2004 FY 2005 FY 2006 Station Facility Maintenance Benchmark Pump Station 90% 104% 100% 102% 95% Pump Station Electrical 90% 102% 51% 94% 77% Pump Station Wet Well 90% 63% 41% 49% 103% Pump Station Generator 90% 104% 113% 98% 101% Pump Valves & Check Valves 90% 8% 61% 91% 103% Pump Station Pump 90% 86% 17% 30% 71% Overall 77.8% 64% 77% 92% . 2 Achievement levels as reported in the “Maintenance Assessment Program” Report City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 69 Table 8.9. Sewer Main Cleaning Since FY 2003 % Maintenance Achieved 3. Activity FY 2003 FY 2004 FY 2005 FY 2006 Sewer Main Cleaning Benchmark Priority Sewer Every 3 Months 90% Data not available 103% 86% 98% Priority Sewer Every 6 Months 90% Data not available 86% 108% 104% Priority Sewer Every 12 Months 90% Data not available 93% 80% 92% VCP Sewer Lines Every 24 Months 90% Data not available. 100% 100% 100% PVC Sewer Lines Every 36 Months 90% Data not available 100% 100% 100% Overall N/A 96% 95% 99% Spill Response M&O continued to respond and coordinate sewage spill response with the Leucadia Waste Water District (LWWD) and Vallecitos Water District for spills that occur outside the M&O jurisdiction. During normal business hours, calls were dispatched by M&O to field units for immediate response and evaluation. After working hours, phone numbers were routed through police dispatch to CMI standby personnel. City employees are trained to follow the City’s Sewer Overflow Prevention Plan/Response Plan. Staff training was conducted semi-annually, and tailgate meetings were held quarterly. All spill response incidents were tracked in the Hanson system or spill reports. Sanitary sewage overflow responses were documented as required on the Sanitary Sewer Overflow Report Form, which was sent via fax to the Regional Board, County Health Department, and the Storm Water Protection Program. During FY 05-06, the City responded to 19 sewage overflow or spills. A total of 98 gallons were recovered with approximately 1,509 gallons entering the environment. The overflow reports are found in Appendix 8-3. A portion of the LWWD collection system is located within the City limits. They are responsible for operating and maintaining their system, including responding to overflows and spills. However, M&O responds or provides assistance when requested. During FY 05-06, the LWWD responded to two sewage overflows in Carlsbad. Response details are found in Appendix 8-4. The following tables show the reportable gallons spilled, recaptured, and percentage recaptured by fiscal year. This information is published in the City’s annual State of Effectiveness report. Table 8.10. Volume of Spills and Spills Recaptured Fiscal Year No. of Reportable Spills4 Reportable Gallons Spilled . Total Miles of Sewer Mains Reportable Gallons Spilled per Mile Benchmark 0.0 2001 9 1,125 212 5.3 2002 14 7,835 212 36.9 2003 7 7,550 232 32.5 2004 6 209 235 .89 2005 11 3,030 254 11.9 2006 7 1,509 255 5.4 3 Achievement levels as reported in the “Maintenance Assessment Program” Report. 4 Includes all spills caused by a failure in the sewer system (excludes recycled water spills and/or spills from sewer laterals). City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 70 Table 8.11. Volume of Spills Recaptured Fiscal Year Reportable Gallons Spilled 1. Reportable Gallons Recaptured 2. Percentage of Gallons Recaptured Benchmark 100% 2001 1,125 3. 2,640 4. 235% 2002 7,835 6,845 87% 2003 7,550 2,200 29% 2004 209 164 76% 2005 3,030 1,025 34% 2006 1,509 98 6.5% 1. This column includes all spills that were caused by a failure in the City’s sewer system (excludes recycled water spills and/or spills from sewer laterals). Figures are adjusted from previous years’ reports. 2. Data is based on total reportable gallons recaptured from the City’s public sewer system. 3. Of note, two significant spills occurred to the recycled water system and are not included above. 4. Residual and/ or any other water from other areas during recapture was reported. Volume of Spills: This component of the sewer system delivery measure includes reportable spills due specifically to system failure. In past reports, the volume measure included only those spills of 50 gallons or more per incident. All spills are now used in this measure, because M&O reports spills regardless of the volume. Also, because our benchmark partners do not have responsibility for sewer laterals and in order to maintain comparability of data, this measure does not include spills from sewer laterals even though the City reports those types of spills when they occur. The number of gallons spilled per mile of sewer main as a result of system failure was 5.4. This is a decrease from the previous year and represents the results of our ongoing proactive sewer main cleaning preventative maintenance program. M&O gave particular attention to the sewer main system in the older downtown area of Carlsbad which historically has experienced blockages caused by grease and/or root intrusion. Sewer mains in these older areas are categorized as “high priority.” These areas were inspected and cleaned every three months as a proactive measure to mitigate possibility of blockages and/or spills. When staff identifies areas that have continued blockage problems, these areas are included on the high priority maintenance list. Compared to benchmark agencies, the City was second only to the City of Chula Vista with the lowest reportable gallons spilled due to sewer system failure. It should be noted that this is a measure of sewage spills only. Recycled water spills were included in prior years’ reports because the City is required by the Regional Board to report that information. Because the focus of this measure is based primarily on the integrity of the sewage conveyance system, recycled water spills were not included in the measure. Volume of Spills Recaptured: This measure is included to represent the effectiveness of the City’s “Sewer Response Plan.” The number of gallons recaptured in FY 05-06 was 6.5% of total reportable gallons spilled due to system failure. Unfortunately, this did not meet the benchmark of 100%. Staff responds to all spills upon notification; however, in some cases notification did not come in time to allow for the total recapture or contain the spill. Six of the seven spills reported occurred in isolated areas not normally or regularly patrolled. As a result, by the time staff discovered the spills, the sewage had already escaped into the environment and staff was unable to fully recapture the spill. The number and volume of spills was down from last year; however, the volume of spills reaching the environment was approximately the same as last year (1,487 in 2006 as compared to 1,500 gallons in 2005). City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 71 Complaint Response M&O personnel responded to 65 sewer stoppage incidents, one sewer leak, and 30 sewer repair requests. These requests and the City’s response were tracked electronically in the RFA and Hansen systems. Education Educating the public on the proper disposal of fats, oils and grease is one of the BMPs used to prevent sewage spills. The City continued to distribute the Water Environment Federation brochure entitled “Fat- Free Sewers.” These brochures were distributed at various public events and during field visits. In June 2006, the Public Works Department revised the “Public Works At Your Service,” brochure. The revised brochure includes information about the Environmental Programs covering storm water, water conservations, M&O, and trash management. The brochure was sent to all Carlsbad residents. The Storm Water Protection Program depends on other City departments to assist with investigations and remediation during field reviews. M&O and the Storm Drain Maintenance Crew were key to prompt, effective responses to investigations involving spills and clean ups. Regular meetings and discussions about compliance issues facilitated this interdepartmental coordination effort. In June 2006, the City held a successful restaurant workshop which attracted 40 participants representing several industrial and commercial businesses throughout Carlsbad. The participants received training in storm water pollution prevention, trash and grease management, and the requirements of the Carlsbad Municipal Code. Featured speakers from the City, Waste Management, and the San Diego County Green Business Program were also on hand to provide information about storm water requirements, pollution prevention strategies, and BMPs. Other Spills The City’s Emergency Services (Fire/Police Departments) responded to reports of hazardous materials spills and discharges in Carlsbad. Fire Department personnel were trained in hazardous material emergency response and identification of hazardous materials and other City departments relied on the Fire Department to assume command during hazardous materials incidents. Emergency services may request assistance from the Streets Department to contain discharges that have the potential to endanger life, property, and/or the City right-of-way, control traffic, and provide secondary perimeter boundaries as directed Emergency Services’ staff. During FY 05-06, the Spill Response Plan continued to be used to detail the roles and responsibilities of Emergency Services, Streets Department, M&O, and the Storm Water Protection Program. If Emergency Services was first on the scene of an unidentified spill, the incident commander decided whether to provide emergency containment measures or wait until the emergency response agency identified the substance. If the incident commander suspected the substance to be of a hazardous nature, emergency response procedures were implemented. All incident commanders retained 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 HIRT, through a Joint Powers Agreement, was involved in any significant spills of a hazardous nature. The County maintains these records, as does the State OES. Minor petroleum or other small spills on City streets were handled by the Streets Department using absorbents, sweeping, and proper waste disposal. These cleanup requests were documented in the City’s RFA or work order systems. During FY 05-06, there were 12 other spills (non-sewage related) in Carlsbad as referenced in Appendix 8-5. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 72 8.8 Self-Assessment Program Strengths In February 2006, the Carlsbad City Council approved a new HHW pick up program that provides a means for Carlsbad residents to have HHW picked up from their homes and hauled away. In addition, residents can also dispose of HHW for free at three permanent facilities in Vista, Oceanside, and Poway. In April 2006, the City sponsored a free HHW disposal day where Carlsbad residents could dispose of up to 15 gallons or 125 pounds of HHW materials. The event attracted 232 residents. The City plans to make this an annual event. The City’s goal was to respond to complaints “happening right now” within 30 minutes for 90% of incidents. This goal was met over 90% of the time during FY 05-06. In June 2006, the City held a successful restaurant workshop which attracted 40 participants representing several industrial and commercial businesses throughout Carlsbad. The participants received training in storm water pollution prevention, trash and grease management, and the requirements of the Carlsbad Municipal Code. The City, Waste Management, and the San Diego County Green Business Program provided information about storm water, pollution prevention strategies, and BMPs. The Public Works Department revised the “Public Works At Your Service” brochure. The revised brochure includes information about the Environmental Programs Division covering storm water, water conservations, M&O, and trash management. The brochure was sent to all Carlsbad residents. The City continues to use the Performance Measurement System 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. The City also has a Maintenance Assessment Program to evaluate the condition of public facilities. This program establishes and documents the frequency of recommended preventive maintenance and/or responsiveness to repair needs, then measures the level of accomplishment each year by comparing percent of completed work to scheduled maintenance. The City continues to recruit interns from local universities to work with storm water staff. During FY 05-06, the Storm Water Protection Program had four interns working on various projects, including commercial and industrial inspections, data management, and outreach and education. The City continues to use the Spill Response and Cost Recovery Plan procedure to define the process for protecting the storm drain system from potentially hazardous releases. This procedure applies to the City personnel who may be involved in spill prevention, containment and response activities. Program Improvement Areas In late FY 05-06, the Storm Water Protection Program began drafting a Best Management Practices Manual that includes the minimum and required BMPs for activities and pollutants types. The manual will be continually worked on during FY 06-07 and should be completed by early FY 07-08. The City will provide an update on the progress of the manual in the next annual report. During FY 05-06, staff continued to revise brochures and fact sheets to reflect changes in the program. A complete revision of all brochures will take time to complete. However it is expected that this project will be completed by late FY 07-08. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 73 In an effort to discover sewer blockages before they become a spill, M&O staff will be implementing a pilot program using radio-wave signal technology called “SmartCover™.” The SmartCover™ system will provide continuous real-time monitoring of five access hole locations that staff has determined as critical. Using wireless communications to designated cell phones and/or pagers, the system will alert staff upon intrusion or surcharge in any of the monitored locations. This will allow staff to respond in time to clear any blockages, etc., prior to a spill occurring. If this system proves to be successful, staff will add additional monitored sites in subsequent years. In FY 03-04, the City worked with Waste Management to develop an Environmental Programs booklet that included storm water residential BMPs, as well as detailed information on available solid waste services, including oil recycling and HHW disposal sites. The booklet needs to be revised and updated to reflect the most current HHW, trash, recycling, storm water, and water conservation information. The revision should be completed in late FY 06-07 and will be reported in the next annual report. Although the Storm Water Program has developed outreach materials that address oil and grease, it continues to be a pollutant source, especially at restaurants. The Storm Water Protection Program will continue to work closely with the Public Works – M&O Water Division to develop a program to address grease trap maintenance, outdoor tallow bin storage, and proper clean up and disposal of spilled grease. In relation to sewer spill volume and spills recaptured M&O staff will continue: • Preventive maintenance sewer line inspections and monitoring in a proactive attempt to eliminate the volume of spills. • Inspection of new construction to ensure that any debris ending up in the sewer system is held to a minimum and does not result in a spill or blockage. • Investigation and implementation of mitigation efforts and enhancements to the Sewer Response Plan to increase the percentage of spills recaptured. The measure will include any sewage spill that occurs, whether or not it’s the result of system integrity failure or caused by other occurrences (e.g., line damage due to construction and blockages caused by grease disposal into sewer system). Station Facility Maintenance: Alternative work methods will be evaluated to improve the balance of planned versus corrective maintenance. Examples include the use of contract services, temporary help, and/or consolidation of services with other Public Works divisions. Sewer Main Cleaning: • With sewer main cleaning meeting the established benchmark, staff will evaluate alternative work methods to further improve work productivity in this activity. This will include the use of contract services, temporary help, and/or consolidation of services with other Public Works divisions. • In order to meet the sewer main cleaning standards, staff uses two Jet/Vac trucks on a regularly scheduled basis. However, only one Jet/Vac is part of the Sanitation Operations vehicle replacement schedule. In FY 06-07, staff will review and evaluate adding one Jet/Vac to the Sanitation Operations vehicle replacement schedule. • In FY 06-07, staff will implement a new work management system (Hansen) that will automate scheduling and record maintenance of work activities, and tie maintenance and/or repair work to a specific asset in the sewer system. • Staff will compare sewer main cleaning procedures and standards with benchmark agencies. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 74 Section 9 Outreach and Education 9.0 Overview Public education is integral to the success of the City’s urban runoff management program. The City continues to increase public awareness about pollution prevention and promote behavioral changes and environmental stewardship. The Storm Water Protection Program collaborated locally and regionally to ensure outreach efforts and messages for storm water pollution prevention were consistent. The City continued to be 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 further discussed in the following subsections by target audience. 9.1 Municipal Departments and Personnel Storm water training for municipal employees included general training and job specific training for designated departments and personnel. The objectives of the employee training programs are as follows: • Promote a clear understanding of the urban runoff and water quality issues, including activities that can potentially pollute receiving water bodies. • Identify and implement strategies for BMPs. • Promote employee ownership of the problems and their ability to apply solutions. • Integrate employee feedback into training and BMP implementation. General Employee Training During this reporting period, City employees received storm water training covering issues such as 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 the Permit. During FY 05-06, City staff received information and general storm water training through various communication methods including: 1. Storm Water Webpage: Employees were able to download BMPs and the JURMP directly from the City’s website. 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. Public Works Newsletters: During FY 05-06 every edition of Public Works newsletter featured updates on the Storm Water Protection Program and Environmental Programs. Employees were notified by e-mail when these newsletters were published and posted on the City’s intranet, and hard copies were given to maintenance personnel. 4. Workshops: All new employees were invited to attend a three-day orientation workshop entitled Experience Carlsbad. At this workshop, employees were given a Power Point presentation introducing them to the Storm Water Protection Program. 5. Promotional Items: Items such as water bottles, notepads, mouse pads, cups, and pens with the hotline numbers and other pollution prevention messages continued to be distributed to employees. 6. Hotline Decals and Notepads: Car window decals and notepads with the storm water hotline were distributed for employee use in the field. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 75 Job Specific Training Several job positions have been identified that require activity or job specific storm water training. A summary of municipal employee training is in Appendix 9-1. Table 9.1 identifies the departments with personnel that should receive job specific training. Table 9.1. Department and Positions for Job Specific Storm Water Training MSA Department Positions PW Engineering, Construction Inspections Construction Inspectors PW Engineering, Engineering Development Services Associate Engineer, Assistant Engineer PW Environmental Programs, Storm Water Environmental Specialists Interns PW Environmental Programs, Water Conservation Water Conservation Specialist PW General Services, Streets Division Street Maintenance Workers 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, Planners, Code Enforcement, Safety Fire Department Fire Fighters Storm Water Committee The Storm Water Committee continued to meet monthly to discuss and develop a calendar of storm water training activities for staff, coordinate compliance activities and documentation, create and distribute job specific storm water training information, and standardize documentation of training activities. A summary of Storm Water Committee meeting topics during FY 05-06 can be found in Appendix 2-3. Other Training In July 2005, the Environmental Specialist attended the Clean Water Summit held in the City of San Diego. The workshop covered topics such as site prioritization, complaint response, enforcement, the San Diego Green Business program, BMPs, and data management. During the spring of 2006, the Environmental Specialist II, Water Conservation Specialist, and Storm Drain Maintenance Crew leader completed the eight hour “Hazardous Waste Operations and Emergency Response Training” in San Diego. This course is required for anyone who is expected to identify emergency situations involving hazardous materials. Staff was trained to recognize, report, and assist in emergency response. This course fulfills the requirements under OSHA 29 CFR 1910.120. In May of 2006, the Fire Department Training Coordinator presented an “Introduction to the Incident Command System” training for the Storm Water Protection Program. In May and June of 2006, the Public Works Director participated in several commercial and industrial storm water inspections with the Storm Water Protection Program. During the inspections, the Public Works Director received information about inspection procedures, compliance issues, enforcement actions, and problem areas in the City. In addition, the Public Works Director also accompanied staff during the storm drain maintenance, compliance inspection, and water quality monitoring activities. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 76 In early FY 05-06, the City purchased a new storm water and pollution prevention video entitled, “The River Returns.” The video was used to educate City employees about watershed protection, pollution prevention, sustainable growth, and the natural water cycle. On March 13 and 14, 2006, the Acting Environmental Programs Manager and the Deputy City Engineer attended training on storm water quality and treatment alternatives. The two day course focused on storm water quality, water quality and monitoring, treatment process, and treatment decision making. On June 15, 2006, the Storm Water Protection Program presented a training program to City Planning staff on storm water and pollution prevention. There were 22 Planning employees in attendance. 9.2 Construction Site Owners and Developers 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. They also provided sample SWPPPs and SWMPs for engineers, developers, and applicants to use as guides 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. On May 18 and June 1, 2006, the City co-sponsored two “Post-Construction Best Management Practices” seminars in Oceanside and Escondido. The seminars were designed to assist the development community in understanding the post construction BMP requirements and provide information about expectations and specific jurisdictional requirements. The Storm Water Protection Program mailed 112 invitations to general contractors, which also included BMP information. The Storm Water Protection Program also continued to distribute the “Pollution Prevention Guide for the Construction Industry.” This brochure was developed to provide BMP and pollution prevention information related to materials storage, perimeter controls, building and staging areas, dumpsters and port-a-potty services, tracking controls, concrete trucks and pumpers, washout areas, dirt and grading, earthmoving equipment, and storm drain protection. The brochure was distributed to commercial businesses that conduct small remodeling or home improvement projects. The City continues to conduct and participate in workshops to educate external parties, which include project applicants, developers, contractors, and property owners on the implementation of the storm water program and requirements for construction sites. 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 distribution of printed materials, participation at workshops, presentations to business community groups, direct mailings, inspections and site visits. Accomplishments are detailed below. Printed Materials The City developed new brochures and fact sheets during FY 05-06 and continued to distribute existing brochures developed in previous years. These materials were distributed by direct mail, during inspections and complaint investigations, and were available at public events and presentations. These brochures are also available on the City’s storm water web page, accessed at www.carlsbadconserves.org. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 77 The City actively participated in the North County Storm Water Program (NCSWP), which is a collaboration of the Carlsbad Watershed Copermittees and the Project Cleanwater Copermittee Outreach Workgroup. The City distributed the printed materials previously developed with these groups. During FY 05-06, the City continued to distribute the “Best Management Practices for Businesses – Commercial and Industrial” brochure containing the list and description of minimum BMPs. This brochure was distributed to businesses during inspections and by direct mail. In March 2006, the City developed a new brochure for mobile service providers, including carpet cleaners, plumbers, pressure washers, mechanics, porta-potty services, and any other mobile business that provides services at various off-site locations. During FY 05-06, the “Best Management Practices for Mobile Service Providers” brochure was mailed to applicable businesses on the storm water inventory. Direct Mailings In May 2006, the City sent two mailers to all landscape and pest control professionals in Carlsbad. The mailer included BMP information and an invitation to the May 9, 2005, “Integrated Pest Management Training for Landscape Professionals”, sponsored by the Unified Port of San Diego and the June 7, 2006, “Exotic Invasive Plant Workshop.” Community and Professional Groups On March 9, 2006, the Acting Environmental Programs Manager and Environmental Specialist II attended the Industrial Environmental Association – Water Subgroup meeting and made a presentation about the City’s storm water compliance program. The presentation also included an update on industrial compliance, information about fire sprinkler discharges, and distribution of BMP information. Website and Hotline The storm water hotline was listed on all printed material. Industries and commercial businesses can call the hotline to request BMP information. All brochures were also available through the City website. During FY 05-06, there were 12,860 visits to the Environmental Programs web page. . Inspections and Site Visits City storm water inspectors worked with businesses during inspections and complaint investigations to identify storm water compliance issues, detail corrective actions, and assess the appropriateness of BMPs. Workshops and Outreach Events On June 13, 2006, the City hosted a free pollution prevention workshop for area businesses that prepare and/or sell food and beverages. Approximately 300 businesses were invited to attend and all invitations included information about storm water and BMPs. The workshop provided food service owners, managers, and staff with information about the City’s pollution prevention requirements. Participants received training in storm water pollution prevention, trash and grease management, and the requirements of the Carlsbad Municipal Code. Featured speakers from the City, Waste Management, and the San Diego County Green Business Program provided businesses with the current information about storm water requirements, pollution prevention strategies, and BMPs. The City sponsored a “Composting for the Health of Your Soil” workshop held on February 11, 2006. City representatives were on hand to provide information about the Storm Water Protection Program and distribute information on BMPs for lawn and garden care. A flyer, information letter, and BMPs was sent to all landscape and garden care businesses in Carlsbad. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 78 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 05-06. 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. Carlsbad actively pursued a comprehensive environmental education and outreach program, combining the activities of storm water, solid waste and water conservation under the umbrella of Environmental Programs. The purpose was to create a unified message, better educate the public, and allow easy access for the public. These accomplishments are described below. Bill Stuffers The Environmental Programs brochure was mailed to residents in October and November 2005 with approximately 33,000 solid waste bills. This brochure included storm water residential BMPs as well as pollution prevention messages for HHW, solid waste, and water conservation. Environmental Programs included information on storm water pollution prevention and BMPs in the City’s Annual Drinking Water Quality Report, which was sent with water bills to approximately 36,000 customers in June 2006 (Appendix 9-2). In the spring of 2006, the “Pet Waste” BMP brochure was revised to include the Environmental Programs logo, phone number, and email address. The brochure was designed to educate residents on the proper disposal of pet waste. The revised brochure was mailed to residents with the trash and water utility bills. Printed Material In June 2006, the Public Works Department revised the “Public Works At Your Service” brochure. The revised brochure includes information about Environmental Programs covering storm water, water conservations, and trash management. The brochure was mailed to all Carlsbad residents. During FY 05-06, the Environmental Programs Division updated the “Put Toxic Waste in its Place” fact sheet to include the new HHW collection sites, phone numbers, addresses, logo, web address, and map of disposal locations. The fact sheet was distributed to residents by mail and at outreach events. The City worked with the North County Outreach Group to develop a new informative pledge card to provide information on pollution prevention and collect data about local residents. A copy of the pledge card can be found in Appendix 9-3. During FY 05-06, the new “Best Management Practices for Mobile Service Providers” brochure was provided to residents during complaint investigations related to mobile service provider discharges. Direct Mailings The Carlsbad Community Services Guide (City Scene) is mailed three times a year to all Carlsbad households (approx. 40,000). The Fall 2005 and Summer 2006 editions of the guide included residential storm water BMPs and Environmental Programs information. The “TGIF Jazz in the Parks 2006” guide included an Environmental Programs advertisement, and information about recycling. The guide was mailed to all Carlsbad households in April 2006. Water Bill Messages Environmental Programs continued to take advantage of this tool by including short messages on the bottom of the water bills. Messages included information on the storm water hotline, bulky item pickups, water conservation audits, and other related program information. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 79 Figure 9-1: Solana Center educator Natalie Kopytko with students & the Enviroscape© Classroom Education During FY 05-06, the Solana Center for Environmental Innovation (Solana Center) continued to conduct the “Classroom Watershed Program” for the City. The Solana Center used the EnviroScape interactive model to teach students about watershed stewardship and pollution prevention. Outreach materials and workbooks were provided to the students and teachers. During FY 05-06, 403 storm water fliers were distributed to teachers. A copy of the flyer can be found in Appendix 9-4. Each classroom was given a watershed poster, handouts for ten simple ways to help protect the ocean, guides to HHW alternatives and disposal (English and Spanish), and a recycling guide for students to take home. Students were also given pledge cards to sign and take home. The pledge cards read as follows: 1. I pledge not to dump anything down the storm drain. 2. I pledge to remind my family to properly dispose of toxic materials such as paint, cleaners, and pesticides. 3. I pledge to pick up after my dog (given only to those with dogs). Table 9.2 lists all of the schools and the number of classrooms and students that attended the watershed classroom presentation during FY 05-06. Table 9.2. Carlsbad Elementary Schools Watershed Awareness Programs Date Elementary School # of teachers # of students 10/04/05 Boys and Girls Club 2 50 10/05/05 Olivenhain Elementary 3 50 10/05/05 Carlsbad Boys and Girls Club 2 20 10/06/05 Olivenhain Elementary 2 50 10/11/05 Carlsbad Boys and Girls Club 2 50 11/03/05 Aviara Oaks Elementary 2 60 11/04/05 Hope Elementary 2 40 11/07/05 El Camino Creek Elementary 3 90 11/16/05 Calavera Hills Elementary 2 60 11/18/05 Hope Elementary 2 40 12/01/05 Jefferson Elementary 2 40 01/09/06 Buena Vista Elementary 2 60 01/17/06 Hope Elementary 2 61 01/24/06 Jefferson Elementary 2 40 01/25/06 Jefferson Elementary 2 40 01/26/06 Aviara Oaks Middle School 3 72 01/26/06 Carlsbad Seaside Academy 1 10 02/02/06 Aviara Oaks Middle School 1 24 02/10/06 Valley Middle School 4 132 02/21/06 Valley Middle School 5 165 02/22/06 Valley Middle School 5 165 03/01/06 Magnolia Elementary 4 80 03/09/06 Hope Elementary 4 40 03/13/06 Aviara Oaks Middle School 4 40 04/10/06 Boys and Girls Club 2 30 04/25/06 Magnolia Elementary 2 64 City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 80 Date Elementary School # of teachers # of students 04/28/06 Magnolia Elementary 3 32 05/08/06 La Costa Meadows Elementary 3 60 05/19/06 La Costa Meadows Elementary 3 60 05/26/06 Jefferson Elementary 1 32 Total 77 1,757 Advertisements During FY 05-06, advertisements were published in the North County Times and the Community Services Guide. Copies of the Environmental Programs advertisements can be found in Appendices 9.5- 9.8. Table 9.3 lists the published ad and the estimated circulation. Table 9.3. Dates of Publication of the Environmental Programs Advertisements Website and Hotline Most of the printed materials were available for download from the City’s website and Environmental Programs website. There were 12,860 hits to the Environmental Programs web pages during FY 05-06. Information Line/On-hold Messages A continuous on-hold message provides residents with information about events in the City. During FY 05-06, staff used the information line to inform residents of the Environmental Programs web page, telephone number, upcoming outreach events, City services, Public Works Fair, Bulky Item Collection Day, and HHW collection facilities. Kiosks/Display Racks Various Storm Water Protection Program brochures are kept stocked at City kiosks and display racks. Publications An article entitled “Carlsbad Offering Waste Removal,” was featured in the Today’s Local News publication on February 9, 2006. The article highlighted the new HHW pick up program and also included the Environmental Programs phone number. Neighborhood Outreach Campaign The City’s Dry Weather Program monitoring results found that several neighborhoods were contributing to storm water pollution through various residential activities. The Dry Weather Program monitoring report included recommendations to educate residents in four specific neighborhoods. In response, the Storm Water Protection Program conducted a targeted outreach campaign to those identified neighborhoods. The identified neighborhoods were delineated using the City’s interactive GIS. In December 2005, the City sent an information letter and BMPs to the residential areas identified as potential contributors to storm water pollution (e.g., pet waste, car washing, and landscaping activities). Staff mailed the “Only Rain in the Storm Drain” brochure and information letter to each residence in four identified areas in the City. Ad Month Publication Circulation Environmental Programs Ad Fall Carlsbad Community Services Guide 80,000 Environmental Programs Ad March North County Times 44,000 Environmental Programs Ad April North County Times 44,000 Environmental Programs Ad May North County Times 44,000 Environmental Programs Ad June North County Times 44,000 Environmental Programs Ad Summer Carlsbad Community Services Guide 80,000 City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 81 Presentations On October 22, 2005, the City conducted a presentation for the Agua Hedionda Foundation about the Carlsbad Watershed and storm water program. Twenty Carlsbad residents were in attendance and received information about BMPs and storm water protection. The participants were most interested in information about illegal discharges, pesticide application, and detention basin maintenance. On May 9, 2006, the City conducted a presentation for the Carlsbad Beach Preservation Committee. Ten participants received information about the storm water, pollution prevention, water quality, and BMPs. 2006 Calendar and Community Guide This 122-page bound calendar is mailed once a year to all Carlsbad residents. Several articles related to water quality were included during FY 05-06. Approximately 47,000 were printed for distribution. Direct Interactions Residents were educated about pollution prevention and BMPs during complaint investigations. City inspectors met with residents to explain storm water regulations and pollution prevention. When a resident was not available, a door hanger and other outreach materials were left to provide information about the reported discharge. Typically, follow-up informational letters were sent to homeowners and/or contractors after an investigation. These correspondences included brochures and fact sheets about storm water. Additional information on complaint investigations is provided in Section 5.4. Prompts and Promotional items Environmental Programs created and distributed recycling bags to residents at various events. The recycling bags displayed the Environmental Programs logo and phone number. The bags were also designed to encourage residents to recycle aluminum, glass, paper, and other materials. In March 2006, the Storm Water Protection Program purchased approximately 1,000 pollution prevention message pens. The pens were distributed to Carlsbad residents and City employees. Several existing storm water, solid waste, and water conservation materials were also distributed, including oil funnels and rags, key chains, buttons, notepads, cups, Frisbees, magnets, and a variety of other products. Workshops The City hired the Solana Center to conduct two workshops entitled, “Learn How To Maintain a Smart Lawn” workshop held on August 20, 2006, and “Composting for the Health of Your Soil” held on February 11, 2006. Carlsbad residents received information on a variety of topics, including water conservation, mulching, plant selection, proper irrigation practices, home composting, and fertilizer and pesticide alternatives. This educational workshop clearly demonstrated the relationship between water conservation, solid waste, and storm water. Residents were provided with information on alternative chemical products, including integrated pest management, and were given information on the City’s HHW collection facilities. Most residents took with them several of the City’s brochures and Environmental Program promotional items publicizing the new phone number and website 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. During most of these events, a staffed booth was 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. Table 9.4 includes a summary of these public events for FY 05-06. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 82 Table 9.4. Outreach Events for Residents, General Public, and School Children Event Date Type Target Audience Attendance Fiesta del Barrio 9/11/05 Booth Residential, General Public >1,000 Buena Vista Creek Cleanup 9/17/05 Event Residential 92 Citizen’s Academy 9/22/05 Presentation Residential 33 Carlsbad Village Street Faire 11/06/05 Event Residential, General Public 100,000 Fall Festival at the Leo Carrillo Ranch 11/12/05 Event Residential, General Public 820 Composting Workshop 02/11/06 Workshop Residential, General Public 8 Citizen’s Academy 03/23/06 Presentation Residential 27 Kids Day at the Flower Fields 04/01/06 Booth School Children, General Public 3,000 Police Department Dog Licensing and Rabies Clinic 04/23/06 Event Residential 100 City Stuff 05/25/06 Presentation School Children 40 City Stuff 05/30/06 Presentation School Children 40 Water Conservation Poster Contest May 2006 Presentation School Children 5,000 Public Works Fair 05/24/06 Booth School Children, General Public 1,000 9.5 Quasi-Government Agencies/Districts (i.e. Educational Institutions, Water Districts, Sanitation Districts, etc.). Quasi-government agencies and districts 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 compliance inspections. During FY 05-06, the City inspected seven water and sanitation facilities as part of the industrial inspection program. Educational information was provided during the inspections, as well as in written inspection reports. Most of the water and sewer districts and educational institutions were covered under permits issued by the Regional Board. Therefore, many of these facilities already have knowledge of the storm water requirements and participate in education activities. In August 2005, the City provided the County Animal Shelter located in Carlsbad with 280 “Bags on Board” dispensers to be distributed to residents that use shelter services. The shelter has about 4,000 customers per months (from all over North County) and could potentially distribute up to 300 “Bags on Board” per month. The City will be working with the North County Outreach Group to determine if a larger distribution program can be developed. 9.6 Self-Assessment Program Strengths In June 2006, the City held a successful restaurant workshop which attracted 40 participants representing several businesses throughout Carlsbad. The participants received training in pollution prevention, trash and grease management, and the requirements of the Carlsbad Municipal Code. Featured speakers from the City, Waste Management, and the San Diego County Green Business Program provided information about storm water requirements, pollution prevention strategies, and BMPs. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 83 In March 2006, the City developed a new brochure for the mobile service providers. The brochure was designed for mobile service providers, their employees and anyone that hires a mobile service provider. The new brochure was mailed to every applicable business on the storm water inventory. The Environmental Programs Division sponsored a composting bin sale event on June 17, 2006, in an effort to get more residents to compost organic waste instead of throwing it away. During FY 05-06 over 320 composting bins were sold to Carlsbad residents. The composting bins will be on sale continuously. The 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 newspaper advertisements. The City continued to actively promote and advertise the Storm Water Protection Program as part of Environmental Programs. This merger of programs allowed the Storm Water Protection Program to work in conjunction with the “Used Oil Block Grant Funds” program to conduct related education and outreach. The merger also created a unified City Environmental Programs message to help foster a better understanding of the relationship between residential activities and sources of pollution. The City conducted the annual (telephone) Public Opinion Survey in FY 05-06, which included questions on storm water pollution prevention. The results from this survey 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. This survey information is also used on a Performance Measure to gauge the effectiveness of the outreach and education program. Program Improvement Areas In late FY 05-06, the Storm Water Protection Program began drafting a Best Management Practices Manual that includes minimum and required BMPs for activities and pollutants types. The manual will be continually worked on during FY 06-07 and should be completed by early FY 07-08. This City will provide an update on the progress of the manual in the next annual report. Storm Water Protection Program and Environmental Programs will be working with the Information Technology Department to revise the web pages and provide updated information about pollution prevention. The webpage updates should be completed by the end of FY 06-07. In FY 03-04, the City worked with Waste Management to develop an Environmental Programs booklet that included storm water residential BMPs, as well as detailed information on solid waste services, including oil recycling and HHW disposal sites. The booklet will be revised and updated to reflect the most current HHW, trash, recycling, storm water, and water conservation information. The revision should be completed in late FY 06-07 and will be reported in the next annual report. Although the Storm Water Program has developed outreach materials that address oil and grease, it continues to be a major pollutants source, especially at restaurants. The Storm Water Protection Program will continue to work closely with the Carlsbad Municipal Water District to develop a program to address grease trap maintenance, outdoor tallow bin storage, and proper clean up and disposal of spilled grease. During FY 05-06, staff begin revising brochures and fact sheets and updating them to reflect changes in the program. A complete revision of all brochures is expected to be completed by early FY 07-08. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 84 Section 10 Public Participation Component 10.0 Overview Public participation is crucial to ensuring the effectiveness of the Storm Water Protection Program. Public participation allows the residents, interested parties, and stakeholders to express their concerns and provide creative solutions before final decisions are made. The City led and/or contributed to several public participation opportunities this reporting period including the development, implementation, and review of storm water management programs, BMPs, and other JURMP and related issues. The goal has been to ensure that the Carlsbad community has a vested interest in solving storm water problems and has a general understanding of watershed protection. Citizens, the business community, and other interested parties were invited to attend public meetings, outreach events, workshops, City Council meetings, and other events during this reporting year. 10.1 Public Meetings and Hearings The public had numerous opportunities to attend meetings, at the watershed and regional levels, to learn about the City’s implementation of the Permit and have their concerns addressed. Table 10.1 contains a list of some of the public meetings and dates held during this reporting period. Table 10.1. Public Meetings Held During the Reporting Period City of Carlsbad Municipal Storm Water Copermittees Regular Council Meetings Planning Commission Management Committee Outreach Workgroup Monitoring Workgroup 07/05/05 07/12/05 07/19/05 07/26/05 08/02/05 08/09/05 08/16/05 08/23/05 08/30/05 09/06/05 09/13/05 09/20/05 09/27/05 10/04/05 10/11/05 10/18/05 10/25/05 11/01/05 11/08/05 11/15/05 11/22/05 11/29/05 12/06/05 12/13/05 12/20/05 12/27/05 01/03/06 01/10/06 01/17/06 01/24/06 01/31/06 02/07/06 02/14/06 02/21/06 02/28/06 03/07/06 03/14/06 03/21/06 03/28/06 04/04/06 04/11/06 04/18/06 04/25/06 05/02/06 05/09/06 05/16/06 05/23/06 05/30/06 06/06/06 06/13/06 06/20/06 06/27/06 07/13/05 07/27/05 08/10/05 08/24/05 09/07/05 09/21/05 10/05/05 10/19/05 11/02/05 11/16/05 11/30/05 12/14/05 12/28/05 01/11/06 01/25/06 02/08/06 02/22/06 03/08/06 03/22/06 04/05/06 04/19/06 05/03/06 05/17/06 05/31/06 06/14/06 06/28/06 09/15/05 09/27/05 02/07/06 03/16/06 03/22/06 04/11/06 04/18/06 05/17/06 07/12/05 09/13/05 01/10/06 03/14/06 05/09/06 08/02/05 10/25/05 02/21/06 02/28/06 03/06/06 03/15/06 03/21/06 03/27/06 04/05/06 04/18/06 05/02/06 05/09/06 05/16/06 05/23/06 City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 85 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 and are open to the public. The Council meetings are also televised live on Tuesday night on Cablevision Channel 3 and replayed Wednesdays at 8 AM and 2 PM. Videotaped copies of the Council meetings are available at the Carlsbad Library. City Council Agendas are prepared by the City Clerk's office and are available on the Friday prior to the City Council Meeting or through a subscription email service. Agendas are available at the meeting, posted outside Council Chambers, or the public can pick up a copy from the Clerk's office. 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 agenda and public hearing notices are available on the City’s web site at www.carlsbadca.gov. Council Agenda Packets are available for review at the City Clerk's office and at the Carlsbad Library on the Friday prior to the City Council Meeting. City Council Minutes are prepared by the City Clerk's office 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. Residents can also become representatives on various City committees. The City Clerk's office maintains a current list of City Boards, Commissions, and Committees, current vacancies, meeting dates and times, and coordinates all appointments to these positions. The Planning Commission is comprised of seven members appointed by the City Council. This commission makes recommendations to the City Council regarding implementation and updating of the General Plan. When needed, they also provide recommendations to the Council regarding policy issues that affect long-range planning. They review development projects, provide recommendations to the City Council, provide reports to the City Council on the Local Facilities Management Plans, review the annual CIP for consistency with Growth Management Program, identify potential problems and opportunities facing the City, and suggest special studies when appropriate. 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. Hotline and E-mail Address The public is encouraged to provide input and feedback on the Storm Water Protection Program implementation. In addition to the public meeting opportunities detailed above, the public can call the storm water hotline to request information, provide comments, or make illegal discharge reports. 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 available for public use. Other City departments forward comments and questions to the Storm Water Protection Program as needed. The public can also access a Storm Water Protection Program web page through the City’s website which provides information about the storm water requirements and BMPs. The public continued to use the Environmental Programs hotline and e-mail address to obtain information about HHW, trash, and recycling programs. The City’s RFA system was used to track calls about Environmental Programs comments and questions from residents. During FY 05-06, the Environmental Programs Division responded to 59 complaints related to HHW, recycling, and solid waste. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 86 Direct interaction The City continues to rely on the interactions between City staff and the public to convey messages about storm water and pollution prevention. City staff received targeted training to increase their understanding of urban runoff issues. Staff interaction with the public also provided additional opportunities for the City to obtain direct feedback about BMPs, ordinances, and pollution prevention efforts. On March 9, 2006, the Acting Environmental Programs Manager and Environmental Specialist II attended an Industrial Environmental Association – Water Subgroup meeting and made a presentation about the City’s storm water compliance program. The presentation also included an update on industrial compliance, information about fire sprinkler discharge, distribution of BMP information, and an opportunity for IEA members to provide feedback about the storm water program. Public Surveys The Social and Behavioral Research Institute at California State University, San Marcos, on behalf of the City, conducts an annual Public Opinion Survey of Carlsbad residents. The survey entails a random-Digit dial methodology of over 1,000 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 two questions related to storm water quality on the 2006 survey. The results of these questions are in Section 11 of this report. The entire report is available for download from the City’s website. Surveys helped the City understand how the public perceives storm water which can help foster better planning and management programs. The City publishes the results of the Public Opinion Survey in the annual State of Effectiveness Report. General Outreach Efforts through printed ads, newspapers, press releases, media interviews, PSA’s, the Community Calendar, City guides, brochures, water bill stuffers, and other publications were used to keep the public informed of storm water requirements, updates, and public participation opportunities. 10.3 Community Events and Volunteer Efforts The City’s Community Volunteer Coordinator administers outreach and involvement programs for Carlsbad residents. This position has continued to find volunteers to assist the Storm Water Protection Program with various activities, including cleanup events. During FY 05-06, volunteers contributed 258 hours towards improving storm water quality. The City participated in several community events held in Carlsbad and other locations across the County. These events are summarized in the following table. Table 10.2. Community Events FY 05-06 Date Event Location # of Participants 9/11/05 Fiesta del Barrio Carlsbad >2,000 9/17/05 Buena Vista Creek Cleanup Carlsbad 230 11/06/05 Carlsbad Village Street Faire Carlsbad 100,000 11/12/05 Fall Festival at the Leo Carrillo Ranch Carlsbad 820 02/11/06 Composting Workshop Carlsbad 8 04/01/06 Kids Day at the Flower Fields Carlsbad 3,000 04/23/06 Police Department Dog Licensing and Rabies Clinic Carlsbad 100 05/24/06 Public Works Fair Carlsbad 1,000 City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 87 Clean Up Events In September 2005, the City sponsored the annual “Buena Vista Creek Clean up” event. Over 230 volunteers, several of them Carlsbad residents, came out to help pick up over 3 tons of trash and recyclables along Buena Vista Creek. This was the second time the City had over 100 volunteers for this annual clean up event. Common items found included fast food containers, recyclable glass and plastic beverage containers, and cigarette butts. Larger items included tires, bed frames, carpets, and pallets. In celebration of Public Lands Day, the Parks Department sponsored a clean up event at Lake Calavera. The event attracted 25 volunteers who assisted with trash and debris removal. Citizen’s Academy Twice a year, the City hosts an event called “Citizen’s Academy.” This seven-week course (one night per week) teaches residents about City government 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 requirements, program activities, and residential BMPs was presented at both events this reporting year. Approximately 60 residents attended the two academy sessions held on September 22, 2005 and March 23, 2006. This has been a highly successful and popular event, which typically has a waiting list for new participants. Storm Drain Stenciling Stenciling storm drain inlets with “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. Public inlets are marked by the Streets Department. Composting Event The Environmental Programs Division sponsored a composting bin sale event on June 17, 2006, in an effort to get more residents to compost trash instead of throwing it away. During FY 05-06 over 320 composting bins were sold to Carlsbad residents. The composting bins will be on sale continuously. 10.4 Other Public Participation Opportunities The City continues to recruit interns from local universities to work with storm water staff. During FY 05-06, the Storm Water Protection Program had four interns working on various projects, including commercial and industrial inspections, data management, and outreach and education. Their assistance with inspections, water quality studies and monitoring, data entry, and investigations increased productivity and helped the program achieve inspection and investigation goals. 10.5 Self-Assessment Program Strengths Information about water conservation, trash management, and storm water has been combined to one centralized web page accessed at www.carlsbadconserves.org. The Environmental Programs hotline provides information about storm water, trash, and water conservation for the public. The hotline is primarily answered by the Storm Water Protection Program during business hours and provides a detailed voice message after hours. In addition, outreach materials continue to be revised to include the Environmental Program’s web page address, hotline number, and storm water hotline number. Residents can call the hotline to request BMP information or download the information from the Environmental City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 88 Programs and the Storm Water Protection Program web page. During FY 05-06, there were over 2,750 visits to the storm water web page and 12,860 visits to the Environmental Programs web page. 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 welcomes participation from the public and will continue to actively educate the community. The City will also continue to improve its website to provide more information to the public and to publicize hotline numbers, email addresses, public meetings and other events where the public can get involved. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 89 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 their 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.” During FY 05-06, the City continued to participate in a Copermittee workgroup to draft common elements for this assessment. Previously, the Copermittee workgroup submitted “A Framework for Assessing the Effectiveness of Jurisdictional Urban Runoff Management Programs” (Framework) to the Regional Board on October 16, 2003. The City continues to use this document as a guideline for refining the assessment strategy and for developing assessment measures. 11.1 Targeted Outcomes The Framework document established six 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 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 the Copermittee efforts is the establishment of specific programs and activities, which are assumed but not proven, to be beneficial to water quality. While many of the assumptions 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. Table 11.1 tracks some of the City’s program activity measures, which are discussed in detail in the previous report sections. Tracking of many of these activities was useful in assessing compliance with the program, but is not yet tied to long-term assessment or improved water quality. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 90 Table 11.1: FY 05-06 Program Activity Measures JURMP Section Targeted Activities Measure of success (% completed) MUNICIPAL Inventory # inspected/cleaned Qty. removed % inspected/ cleaned MS4 – catch basins 3,671 1200 24 tons 33% Brow ditches - public 23,500 feet - 6.5 tons Channels – public (6) 6 channels 6 channels 600 pounds 100% Desilting Basins 3 3 200 pounds 100% Street sweeping (annual)* 13,000 miles 13,000 miles 1,100 tons 100% Roadside litter - - 1150 cu.yds. High Priority Facilities 13 13 N/A 100% INDUSTRIAL Inventory # inspected High Priority 41 41 100% Medium Priority 177 121 68% Low Priority 245 179 73% COMMERCIAL Inventory # inspected High Priority 573 443 77% RESIDENTIAL Tons collected FY 02-03 Tons collected FY 03-04 Tons collected FY 04-05 Tons collected FY 05-06 Hazardous waste 67.81 53.67 64.87 430.55 LAND USE Discretionary permits rev. # required SWPPP/SWMP 53 53 100% CONSTRUCTION # high priority sites ID’d # high priority sites inspected All active grading permits are rated high and inspected accordingly. 100% IC/ID # complaints received # responded to Complaints 428 428 100% Identified Eliminated Illegal Discharges 107 107 100% Illicit Connections 0 N/A N/A Dry weather sites 60 targeted sites 60 monitored sites 100% EDUCATION # events (workshops, etc) # attendance School Presentations 30 1,757 N/A Public Events 13 109,034 N/A Municipal job specific 75 778 N/A Printed estimates Website Hits Materials distributed >600,000 2,750 N/A PUBLIC PARTIC. >100 opportunities provided *does not include public parking areas which were also swept monthly at a minimum City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 91 Performance Measurement Program In addition to these on-going program activities and measures, the City conducts a citywide Performance Measurement Program that results in an annual “State of Effectiveness Report.” This effort was initiated in 1999 and the first annual report was published in February 2001. The program is a systematic approach designed to continuously assess service and program effectiveness and efficiency. While performance measurement is a fairly common practice in the private sector, there currently is no standard model for the public sector. The City’s goal has been to create and improve a measurement system that identifies key outcomes that quantify success. 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 annual cycle begins each January when the results of the citywide public opinion survey and “State-of-Effectiveness Report” are presented to the Carlsbad City Council. The City Council uses these reports to set priorities and strategic goals. The results are then communicated to staff who use them to develop management goals and department budgets for the next fiscal year. For FY 05-06, the City Council identified ten strategic goals that address: • Top Quality Service • Transportation, Balanced Community Development • Parks/Open Space/Trails • Water Quality • Environmental Management • Financial Health • Communication • Learning and Education • Citizen Connection Individual performance measures were developed by departments to address the strategic goals. The City departments annually collect data about each goal and compare results to benchmark values. The benchmark levels were set high, since they target the level of performance each department strives to achieve. The related performance measure goal defined under the Environmental Management Strategic Goal for FY 05-06 is as follows: “Be an environmentally sensitive community by focusing on: conservation, storm water, sewage collection and treatment, solid waste, and cost effective and efficient use of energy including alternative energy sources.” Sanitary Sewer Performance Measure A number of items were tracked in the sewer related performance measures. They were designed to measure the integrity of the sewer system, the ability of staff to respond quickly and efficiently to spills, and the effectiveness of preventive maintenance operations. These efforts are summarized below with additional detail found in Section 8.7 of this report. Volume of Spills: Volume of reportable sewage spills per mile of sewer mains. For the purposes of this report, a “spill” is defined as any untreated sewage flow that escapes from the sewer collection system and has the potential for entering surface waters and/or the MS4. • Benchmark: Annual volume of reported sewage spills due to system failure will be zero. This benchmark is consistent with the requirements of the Regional Board. • Results: 5.4 City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 92 Volume of Spills Recaptured: This component looks at spills caused by a failure in the City’s sewer system. This does not include spills from sewer laterals within the City. • Benchmark: Recapture 100% of all spills from the maintained sewer system so that sewage never enters surface waters and/or the MS4. • Results: 6.5% Station Facility Maintenance: Percentage of work activities completed during the fiscal year (based on the standards established in the Maintenance Assessment Program). • Benchmark: At least 90% of all pump station electrical moving parts, wet wells, generators, valves and pumps are tested and repaired annually. This program includes station maintenance, electrical maintenance, wet well maintenance, generator maintenance, station surveillance operations, valve maintenance and pump maintenance/repair. • Results: 92% overall Sewer Main Cleaning: Percentage of work activities completed during the fiscal year (based on standards established in the Maintenance Assessment Program). • Benchmark: At least 90% of all priority sewer main lines will receive high velocity cleaning to ensure proper conveyance of sewage and to prevent sanitary sewer overflows and backups. Priority sewer lines are scheduled for cleaning depending on the location of the lines, flow rates, historical information on the frequency of blockages, and pipe material. • Results: 99% overall Level 2: Changes in Knowledge/Awareness The most immediate, basic outcome of urban runoff programs 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 often targeted through outreach programs and once knowledge changes, it presumably forms the basis of behavioral change and the proactive use of BMPs. The City was involved in a number of surveys and programs to assess knowledge and awareness of various target communities. These are highlighted below. City of Carlsbad Public Opinion Survey An annual public telephone survey is conducted by the Social and Behavioral Research Institute at California State University, San Marcos as part of the Performance Measurement Program and “State-of- Effectiveness Report.” Carlsbad households were selected using Random-Digit-Dial methodology with a minimum sample size of 1,000. This survey had a margin of error of +/- 3% at the 95% confidence level. Storm water pollution was addressed briefly in this survey. The City survey asked, “Have you seen or heard any information about how residents can prevent the pollution of creeks, lagoons, and the ocean?” This question was used to gage the public’s perception of ocean water pollution and was asked previously in 2003. The results are presented in Table 11.2 below. Table 11.2: Results of Environmental Question 1 Answer: 2006 (%) 2003 (%) 1. Yes 64.6 58.1 2. No 35.4 41.9 This question illustrates an increase in general awareness of storm water and urban runoff pollution from 2003 to 2006. When extrapolated to current City population of 98,607, this equates to an increase of 6,409 residents with an awareness of these environmental issues. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 93 Industrial/Commercial Assessment In FY 04-05, a BMP and Knowledge Assessment tool was developed to measure an individual operator’s knowledge of storm water issues and assess the implementation of BMPs onsite. The assessment tool is used by inspectors during site visits. Please refer to Section 3 for the Knowledge and BMP Assessment rating scale criteria. Table 11.3 shows the number of instances in percentage that Industrial High and Medium businesses rated for each score for FY 04-05 and FY 05-06, with 5 being the highest score possible. Table 11.3: Industrial Knowledge Assessment Scores from Inspections Knowledge Rating FY 2004-05 Percentage in Each Rating FY 2005-06 Percentage in Each Rating 1 6 3 2 8 12 3 10 26 4 27 21 5 49 38 The number of industries with average or above average knowledge of storm water issues remained constant with 86% reported in FY 04-05 and 85% in FY 05-06. The distribution of knowledge is more uniform in the recent year, whereas in FY 04-05, the majority of businesses ranked in higher categories. Complaints The Storm Water Protection Program responded to 107 reports of potential illegal discharges. Approximately 76 were found to be valid complaints (i.e., others were either not located or not violations, permitted discharges, etc.). The number of reports has continued to decrease from FY 03-04 and FY 04- 05, although the number of valid complaints is only slightly less than in previous years. Classroom Education Elementary school students were given an Eco-quiz prior to presentations to gauge their knowledge of the subject. Following each presentation, students were given the same Eco-quiz to identify the effectiveness of the presentation. This year, the quizzes reflect that 34% of students had knowledge of watersheds and storm drains before the presentations. After the presentations, approximately 80% of the students had a clear awareness. This is a 46% increase in knowledge before and after the Eco-quiz. Although last year’s quizzes were administered to a smaller group of children, the base awareness was only 15%, whereas this year, with a more representative data set, the base awareness was at 34%. Level 3: Behavioral Change/BMP Implementation A key goal of jurisdictional programs is to affect significant and lasting changes in the knowledge and behavior of municipal employees, residents, businesses, and other target audiences. Outcomes may range from compliance with discharge prohibitions, to implementation of BMPs, to active stewardship of watershed resources. Therefore, quantifying BMP implementation through surveys or other means provides an important step toward establishing pollutant reductions. Surveys The City asked a behavioral question during the 2006 survey to those who answered affirmatively to the question, “Have you seen or heard any information about how residents can prevent the pollution of creeks, lagoons, and the ocean?” The 64.6% who answered question one affirmatively were asked the follow-up question, “What things are you doing to reduce water pollution?” Results for this question are presented in Table 11.4. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 94 Table 11.4: Top Responses to “What things are you doing to reduce water pollution?” Answer: Percent 1. Properly disposing of hazardous waste. 22.4 2. Cleaned up trash at Beach, Roadside, Etc. 21.8 3. Using environmentally friendly soaps, pesticides, etc. 13.9 4. Used a commercial carwash. 13.8 5. Recycling. 11.5 6. Reduce water runoff/reduce fertilizer and pesticide use. 11.2 7. Cleaned up animal waste. 6.4 8. Did nothing. 24.7 9. Other. 15.2 10. Don’t know. 2.6 While these responses can not be guaranteed to be accurate, continued survey data should help to show if long-term behavior change has occurred. Seventy percent of residents who answered question one affirmatively consciously chose an environmentally friendly method over others in certain instances. Industrial/Commercial Assessment The Storm Water Protection Program also implemented a BMP Assessment tool. The inspector assigns a rating of overall BMP implementation based on the criteria outlined in Section 3 of this report. Table 11.5 shows the number of instances in percentage that industrial high and medium businesses combined rated for each score during FY 04-05 and FY 05-06, with 5 being the highest score possible. Table 11.5: Industrial BMP Assessment Scores from Inspections BMP Implementation Rating FY 04-05 Percentage in Each Rating FY 05-06 Percentage in Each Rating 1 3 7 2 8 7 3 13 18 4 32 37 5 43 31 In FY 04-05, over 40% had effective BMP implementation with only 3% failing overall; while in FY 05- 06 the number of industries ranking highest declined to 31%. Overall, the percentages of industries ranking average or above were similar from year to year, 88% in FY 04-05 and 86% in FY 05-06. Enforcement When the Permit was issued, the Storm Water Protection Program focused efforts on educating the public and informing residents and businesses how to comply. In most instances, a verbal notice was sufficient for compliance. If repeat violations occurred, enforcement actions were escalated to obtain compliance. As anticipated, the Storm Water Protection Program has moved toward escalated enforcement when necessary to achieve compliance. Table 11.6 summarizes types and rates of enforcement actions taken from FY 01-02 through FY 05-06. Table 11.6: Comparison of Enforcement Mechanisms by Year and Percentage Type of Action FY 01-02 FY 02-03 FY 03-04 FY 04-05 FY 05-06 Verbal Warning 44% 27% 6% 17% 19% Informational letter or warning 24% 57% 51% 46% 40% Notice of Violation 2% 16% 40% 29% 28% Notice to Clean - - - - 4% Cease and Desist order <1% <1% - - - Administrative Citation - - 3% 6% 9% City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 95 Identifying the types of illegal discharges most commonly reported may help indicate problem activities and focus outreach efforts to those areas. Most complaints originated from residential sources. During FY 05-06, illegal dumping was the most frequently reported illegal discharge at 23%, followed by illegal washing at 18%, and home improvement discharges at 17%. Previously, mobile businesses were the most common discharge complaints; however, these have decreased because these businesses have been actively educated on storm water requirements. Chart 11.1 illustrates the percentage of complaints received for each type of discharge in FY 05-06. Irrigation complaints were not included in the chart because they were not deemed an illegal discharge by the Permit or Carlsbad Municipal Code. Chart 11.1: Types of Illegal Discharges FY 05-06 Level 4: Load Reductions The primary goal of BMP implementation is to reduce pollutant loads in storm water discharges. An important emphasis of annual program assessments is to estimate the 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. The Regional Board wrote the following in October 2004: Program effectiveness can be assessed by quantifying the pollutant load reductions attributable to various program activities. An effective program will compare pollutant load reductions of various program activities and implement those activities which result in the largest pollutant load reductions. It is expected that by implementing program activities which maximize pollutant load reductions, Copermittees will be implementing effective programs which will improve receiving water quality. The City used the Watershed Treatment Model (WTM) as a simple tool for rapid assessment of effectiveness of the storm water programs. The WTM (version 3.1) was prepared by Deb Caraco of the Center for Watershed Protection for the U.S. EPA Region V - Office of Wetlands, Oceans and Watersheds. Last year’s report identified bacteria, sediment, and nutrients as constituents of concern. In response, specific program activities were undertaken to address these constituents. The WTM estimates the pollutant loading reductions for sediment, bacteria and nutrients for various program activities, such as residential education, erosion and sediment control programs, and street sweeping among others. The results of some of these storm water management programs are discussed below. Complete explanations and assumptions are found in the WTM book. Washing, 18% Home Improvement, 17% Dumping, 23% Spills or Leaks, 11% Miscellaneous, 17% Allowable or Not Found, 14% Types of Illegal Discharges City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 96 Public Education A variety of public education programs may help to reduce the concentration of nutrients, sediment and bacteria in urban streams. The model currently focuses only on a few of these, including programs to address lawn care, septic system maintenance, and pet waste. Several other residential pollution prevention programs improve water quality, but have little effect on nutrients, suspended solids, and bacteria. For example, HHW programs are effective at reducing toxics but do not have a quantifiable impact on pollutants such as suspended solids, nutrients, or bacteria. Lawn Care: The ideal pollutant removal associated with lawn care would be achieved if all of the additional fertilizer applied to turf were eliminated. The model uses equations to estimate optimal nutrient load reduction from a lawn care program combined with a calculation of the residential lawn area. Table 11.7 shows the spreadsheet information from the WTM. The model calculates the residential lawn area based on the City’s input of residential acres taken from GIS. The user inputs the information on how the education campaign was conducted (the green cells). Default values (blue cells) were given for the fraction of the audience willing to change behavior based on nationwide data. The City conducted lawn care education through brochure distribution, workshops and newspaper ads. Table 11.7: Lawn Care Education Model Input Lawn Care Education Program? (Y/N) Y Lawn Area (acres) 4,117 Program Discounts Fertilizers (Fraction) 0.78 “Over Fertilizers” (fraction of fertilizers) 0.65 Awareness of Message (fraction of population) 0.15 Fraction willing to change behavior 0.7 The model allows the user to input the media type, which determines the portion of the population that remember the message (“Awareness of Message”). This number is largest with television (0.4), followed by newspaper (0.3), radio (0.25), billboard (0.13), brochures (0.08) and workshops (0.07). Because three of these mechanisms were used in FY 05-06, the input value entered was an average for brochures, workshops and newspaper (0.15). This results in an annual nutrient load reduction of 4,110 pounds of nitrogen and 82 pounds of phosphorus (Table 11.8). Table 11.8: Loading Reduction from Existing Lawn Care Education Loading Reduction N (lbs/year) P (lbs/year) Lawn Care Education 4110 82 Pet Waste: The Storm Water Protection Program also conducted a Pet Waste Education Program during FY 05-06. In the urban watershed, dogs are a significant contributor of bacteria and nutrients. Ideally, a Pet Waste Education Program would reduce this source to zero, with all homeowners properly disposing of waste. The model provides estimated values for the fraction of households with a dog, the fraction of owners who walk their dog, the fraction of owners who cleanup after their dog, and the fraction willing to change their behavior. As with the lawn care education, the portion of the population that remembers the message is based on the media used for the education. This past year, the City delivered this message through brochures and the newspaper. In addition, the City distributed free pet waste bag dispensers at local events and provided animal care facilities with these dispensers. These activities were considered similar to a workshop, so an averaged value of 0.15 was used for this calculation (see Table 11.9). City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 97 Table 11.9: Pet Waste Education Program Model Input Pet Waste Education Program? (Y/N) Y Program Discounts Fraction of Households with a Dog 0.4 Owners who walk their dogs (fraction) 0.5 Owners who Clean Up (fraction) 0.6 Fraction willing to change behavior 0.6 Awareness of Message (fraction of population) 0.15 This results in an annual pollutant loading removal of 2,086 pounds of nitrogen, 272 pounds of phosphorus, and 18,137 billion bacteria per year (Table 11.10). Table 11.10: Loading Reduction from Existing Pet Waste Education Program Loading Reduction N (lbs/year) P (lbs/year) Bacteria (billion/year) Pet Waste Education 2,086 272 18,137 The overall assessments of these education programs show that the media significantly affected the associated pollutant removal due to the increased audience that remembers the message. For instance, if the City had the ability to use mass media (television and radio), the estimated pollutant reduction would be increased significantly. The City’s annual phone survey confirms that most people recall hearing these messages through mass media. However, mass media is significantly more expensive than brochures and workshops. The City has a storm water performance measure that calculates the cost per capita for education activities. Proposed cost changes to the education campaigns can be calculated and compared in order to select the most efficient options. With these loading reduction estimations, costs can also be calculated on a per pound basis in order to justify the use of one option over another. Such calculations may show that it is not cost efficient to conduct a mass media campaign due to these costs and the associated reductions achieved. Large campaigns for mass media may be best conducted on a regional basis with Copermittees sharing the expense or pursuing grant funds for these expensive activities. Erosion and Sediment Control Program The WTM default efficiency for erosion and sediment control is 70%. This efficiency is based on a best case scenario: a sediment control program that emphasizes erosion control measures, including practices that limit clearing and grading or use of phased construction methods (Brown and Caraco, 1997), and requires advanced sediment control measures to reduce sediment runoff from leaving the site. The user assigns the discount factors related to the fraction of the erosion practices installed and the fraction installed/maintained properly. There is a range of discount factors based on the level of program implementation and oversight. For example, if there were few inspectors, with no pre-construction meetings and poor practices allowed by codes and regulations, the input value would be 0.4. If inspectors visit sites weekly and if there are education programs for inspectors and contractors, the input value is 0.9 (the highest discount value in the WTM). Inspectors treat each grading site as high priority with weekly inspections and education. This allows for high discount input values. Improvements are continually made to the program. With these considerations, a discount value of 0.8 was used. A discount factor is also calculated based on the fraction of practices installed and maintained properly. Based on input from CMI with weekly inspections, education programs, and guidance on BMP selection, a high discount value of 0.8 was used (Table 11.11). City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 98 Table 11.11: Erosion and Sediment Control Model Input Erosion and Sediment Control Program Efficiency 70% Fraction of Building Permits Regulated 75% Compliance Discount 0.8 Installation/Maintenance Discount 0.8 Based on the estimated acres under construction (from SWRCB NOI database) and the discount factors applied, this results in an annual loading reduction of 36,992 pounds of nitrogen, 110,977 pounds of phosphorus, and 36,992,374 pounds of Total Suspended Solids per year (Table 11.12). Table 11.12: Loading Reduction from Existing Erosion and Sediment Control Programs Loading Reduction N (lbs/year) P (lbs/year) TSS (lbs/year) Erosion and Sediment Control 36,992 110,977 36,992,374 Street Sweeping The WTM accounts for street sweeping by reducing the concentration value of TSS, nitrogen, and phosphorus from road runoff. The user inputs the acres of roadway swept for four types of streets: roadways, residential streets, commercial streets, and industrial streets. For each street type, the load reduction is calculated by multiplying the load by the efficiency of street sweeping. The “best case” estimate of street sweeping efficiencies assumes weekly sweeping. Sediment removals are derived from a modeling study conducted in Portland, Oregon (Claytor, 1999a). Other research suggests that the performance of street sweeping for phosphorus is roughly 80% of the performance for suspended solids (Kurahashi and Associates, 1997). The WTM assumes that the removal for nitrogen is the same as for phosphorus. These are only simplifications, the performance for different constituents will vary depending on the sweeper performance when picking up various sized particulate (mechanical vs. regenerative air vs. vacuum assisted). Table 11.13 shows the potential pollutant removal efficiencies for different types of sweepers and streets (from the WTM). Table 11.13: Washoff Reductions for Weekly Street Sweeping Percentages1 Street Type/Sweeper Type TSS Removal N/P Removal Residential Street • Mechanical • Regenerative Air • Vacuum Assisted 30% 64% 78% 24% 51% 62% Major Road (not residential) • Mechanical • Regenerative Air • Vacuum Assisted 5% 22% 79% 4% 18% 63% Discount factors for street sweeping reflect the frequency of sweeping and “technique” (i.e., the amount of the street surface that is swept). The “frequency factor” reduces effectiveness if sweeping is less frequent than once per week. Reducing sweeping frequency to monthly can reduce the efficiency to approximately 60% of the efficiency for weekly sweeping (Claytor, 1999a). The “technique factor” accounts for reductions in efficiency caused when sweeper operators do not sweep the entire road surface. 1 Claytor, 1999a; Sutherland and Jelen, 1997; Kurahashi and Associates, 1997. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 99 This typically happens when cars are parked on the streets, or when operators are improperly trained. Table 11.14 shows some rough estimates (acreage) for the existing street sweeping program. Table 11.14: Street Sweeping Model Input Streets Swept (Acres) Sweeper Type Residential Other Streets Parking Lots Mechanical 0 957 100 Regenerative Air 0 0 0 Vacuum Assisted 1,324 0 0 Sweeping Frequency (M=monthly, W = Weekly) 0.8 0.6 0.6 Total Street Area (acres) 516 2,225 1,340 Technique Discount 0.5 This existing program resulted in the pollutant loading reductions shown in Table 11.15. Table 11.15: Loading Reductions from Existing Street Sweeping Activities Loading Reduction N (lbs/year) P (lbs/year) TSS (lbs/year) Street Sweeping 2,431 280 211,664 Parking restrictions are in effect in 12 locations throughout the City and have not been modified recently. There is no City-specific training for the contracted sweeper operator. The City improved and amended the street sweeping contract in FY 05-06 to provide for vacuum assisted sweeping in all residential areas, which are swept a minimum of twice per month. This improvement accounts for the increased volume of pollutants removed from street sweeping efforts. Illicit Connection Removal Optimistically, an illicit connection removal program would remove the entire illicit connection load as calculated in the WTM. This reduction is then multiplied by two discount factors: a survey factor which represents the fraction of the sewer system where the illicit connection survey is conducted, and an implementation factor which represents the fraction of illicit connections found that will be removed. Since 1995, the City has conducted a Dry Weather Screening Program designed to identify illicit connections to the storm drain system. When an illicit connection is found, the City requires the owner/responsible party to immediately disconnect. Table 11.16 shows the model input using conservative figures of the number of illicit connections and Table 11.17 shows the loading reductions if 75% of the MS4 is surveyed in a year and all identified illicit connections are eliminated. Table 11.16: Illicit Connection Model Input Illicit Connections Fraction of WS Population Illicitly Connected 0.0001 # of Illicit Connections 4.3133 Number of Businesses 3,493 Fraction of Businesses with Illicit Connections 0.05 Fraction of Business Connections that are Wash Water Only 0.9 Wash Water Flow (gpd) 50 Total Flow/Business (gpd) 150 Table 11.17: Loading Reductions from Illicit Connection Removal N (lbs/year) P (lbs/year) TSS (lbs/year) Bacteria (bil./yr) ICID removal 559 257 4773 173,804 City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 100 Illicit connections can be a huge contributor of pollutants to the MS4. Because the City has had an active identification and elimination program for almost a decade, this potential source has been successfully reduced. As new businesses and homes continue to be built, it is important that inspection programs continue to ensure no new illicit connections are added. Sanitary Sewer Overflow Repair/Abatement Reduction of sanitary sewer overflow (SSO) loads is difficult to predict and may include practices such as repairing existing blockages, increasing the volume of the sanitary sewer, or lining pipes to prevent infiltration from adjacent soils. In the WTM, the user must input a target reduction as a percentage of the existing SSO load. This load reduction is multiplied by an implementation factor, which represents the fraction of the repairs implemented. Storm loading estimated at 21% of SSOs based on previous year’s overflows within 72 hours of rainfall. Table 11.18 shows the calculated loading reductions if the City inputs a value of 75% as the target reduction and can complete 75% of the necessary repairs. Table 11.18: Loading Reductions from SSO Repair/Abatement at 75% Target N (lbs/year) P (lbs/year) TSS (lbs/year) Bacteria (bil./yr) SSO Repair/Abatement 1.14 0.19 8 861 The City has an active SSO response program and maintenance program to prevent overflows. The actual annual number and volume of SSO’s was entered into the model to calculate secondary loadings (based on performance measure results). The City’s numbers were significantly lower than the national average default values. 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 MS4. Improving the quality of discharges into and from the MS4 is an important and targeted outcome. 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 eliminate illicit connections and illegal discharges to the storm drain system. For the past seven years, the City has contracted this work out to D-Max Engineering, Inc. The Dry Weather Monitoring Program report for FY 05-06 and follow- up activities are provided under separate cover with this report. The following charts and discussions summarize current and past dry weather results in order to assess changes in MS4 water quality. Chart 11.2 reviews the geometric mean for total coliform, fecal coliform and enterococcus over the past four years. There were 20 dry weather samples collected each year, across various points covering the MS4. Fecal coliform concentrations are generally lower over the past three years than in 2003, while total coliform and enterococcus concentrations are slightly higher in recent years. In comparison to dry weather action levels, fecal coliform and enterococcus are well below the established action levels across all years of data. With only 4 years of data and many variable factors unaccounted for, it is unclear if the recent results are due to improvements and BMP implementation or to the extremely variable nature of bacteria concentrations. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 101 The City has conducted field testing of detergents since 1995. Chart 11.3 appears to show a downward trend in detergent levels found in the MS4 with results less than established action levels for MBAS. Currently, detergents are rarely detected in the dry weather program (at current lab MDLs). This is likely due to the efforts of the City’s Storm Water Protection Program to educate the public and to prevent illegal washing into the MS4. Chart 11.2 Bacteria Geometric Mean per Year 1 10 100 1,000 10,000 100,000 1,000,000 2003 2004 2005 2006 Year cfu/100 ml Total Coliform Fecal Coliform Enterococcus Chart 11.3 Average Detergent Concentrations 0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 Year mg/l City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 102 The average pH levels, as shown in Chart 11.4, have also shown a downward trend since 1995. This may be a result of the decreased detergents in the MS4, which are typically basic having pH values >7. Dry weather samples are analyzed in the field for many parameters including nutrients such as ammonia- nitrogen, nitrate-nitrogen, and ortho-phosphate. Ammonia concentrations, as illustrated in Chart 11.5, show that concentrations have been decreasing since the inception of the Permit. With the exception of 2002, all recent years have averaged well below the established action level for ammonia-nitrogen. Chart 11.4 pH by Year 6.8 7 7.2 7.4 7.6 7.8 8 8.2 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 Year pH units Chart 11.5 Ammonia by Year 0 0.2 0.4 0.6 0.8 1 1.2 1.4 1.6 1.8 2002 2003 2004 2005 2006 Year mg/l City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 103 Chart 11.6 illustrates average nitrate-nitrogen concentrations over the past five years. Although slightly higher in recent years, all averages are below established action levels. Much of the nitrate-nitrogen is attributable to groundwater in the region. Data for ortho-phoshate is presented in Chart 11.7. Lower in recent years than in 2002, all averages are well below established dry weather action levels. Over the course of the five year dry weather program, water quality parameters have been repeatedly analyzed at the same sites allowing for a comparison of data. In general, water quality within the MS4 is good, with evidence of decreasing concentrations of fecal coliform, MBAS, pH, ammonia, and ortho- phosphates. Efforts continue to focus on bacteria concentrations in the MS4 and their sources. In the future, increased efforts to understand bacteria concentrations and sources will be made through various TMDL activities. With an enhanced understanding of bacteria, the City will be better prepared to address and abate sources within the watershed. Chart 11.6 Nitrate by Year 0 1 2 3 4 5 6 7 8 9 10 2002 2003 2004 2005 2006 Year mg/l Chart 11.7 Ortho-phosphate by Year 0 0.1 0.2 0.3 0.4 0.5 2002 2003 2004 2005 2006 Year mg/l City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 104 Coastal Outfall Monitoring Program As mentioned in Subsection 8.1, the City collects samples of various storm drain outfalls as part of the Coastal Outfall Monitoring Program. If water is flowing from an outfall, samples were collected and analyzed for total coliform, fecal coliform and enterococci. Storm drain sample results were compared to the 95th percentile criteria established in the Adaptive Monitoring Plan. Where possible, a paired receiving water sample was collected to assess the impacts of the storm drains on the receiving waters. The receiving water samples were compared to Rec-1 standards to determine exceedances. Where storm drain bacteria concentrations exceeded 95th percentile criteria or receiving water samples exceeded Rec-1 objectives, follow-up sampling and/or investigations were performed. The monitoring and follow-up protocols are detailed in the Adaptive Monitoring Plan. Chart 11.8 shows the number of outfall samples that had an exceedance of the 95th percentile criteria for the bacterial indicators. Recent years indicate a decrease in storm drain exceedances for all three bacterial indicators, showing improvements in water quality. Exceedances of the 95th percentile did not correlate with any corresponding exceedances in the receiving water. In all cases, the flow from outfalls was intermittent and low volume. In many cases, the flow did not actually reach the receiving waters, but dissipated into 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. Level 6: Changes in Receiving Water Quality The ultimate objective of the Permit is to protect and improve water bodies from receiving polluted 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, it is important that receiving water quality reflects considerably more than the quality of the City’s MS4 discharges. 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, wildlife (impacting bacteria levels), atmospheric deposition, and other events and activities. During FY 05-06, the City continued the Performance Monitoring Program in Agua Hedionda Creek and Lagoon. This has been an ongoing study of three sites on Agua Hedionda Lagoon and one on Agua Hedionda Creek. An explanation and complete discussion of this study is found in Section 13 of this report. Chart 11.8 Coastal Storm Drain Outfall 95th Percentile Exceedances 0 5 10 15 20 25 30 Total Coliform Fecal Coliform Enterococcus Indicator Exceedances FY02-03 FY03-04 FY04-05 FY05-06 City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 105 At the end of FY 04-05, the City purchased a continuous water quality monitoring probe (Datasonde) to be installed in Agua Hedionda Creek near the Mass Loading Station. The Datasonde was installed during FY 05-06. The probe is tied into a continuous stream flow gauge that was installed during the year as part of a State Proposition 13 Grant for the removal of invasive plant species in the Carlsbad Watershed. Stream flow gauges were installed on Buena Vista Creek, San Marcos Creek, and Agua Hedionda Creek. It is anticipated that this multi-parameter probe will provide useful data in the future development of TMDLs, specifically to be used to implement the Lagoon Investigative Order, 2006-0076. Although the probe is gathering data, the data has not been compiled, quality controlled, or assessed at this time. Expansion of Dry Weather Program The Dry Weather Field Screening Program is aimed at identifying illegal discharges to the MS4. The City continued to have samples collected in order to provide additional baseline data of surface water quality. This included 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 part of the four separate Carlsbad sub-watersheds. The results for FY 05-06 are found in Chapter 7 (Table 7-1) of the Dry Weather Report (under separate cover). As a quick comparison with the results from 2003, 2004, and 2005, Diazinon and Chlorpyrifos were not detected at any creek site once again (compared with one during 2003). Other non-detects included oil and grease, surfactants, cadmium, copper, and lead. These sites will continue to be monitored during FY 06-07 as part of the Dry Weather Field Screening Program. Coastal Monitoring Data The City collected one sample of the ocean water during FY 05-06. There were no exceedances of the REC-1 standards in the Ocean for total coliform, fecal coliform or enterococci during the last four reporting periods. There were 50 routine paired samples collected from outfalls to lagoons during FY 05- 06. Chart 11.9 shows the number of samples that exceeded a bacterial indicator during the last four reporting periods. A decline in receiving water exceedances in the lagoons is evident across all bacterial indicators, showing improvements in water quality. Of the 50 receiving water samples collected in lagoons, there were only a few exceedances of benchmarks: zero for total coliform, 4 for fecal coliform, and 2 enterococci. There was wide variability between outfalls, monitoring events, and dry and wet seasons, and there was no correlation between a high receiving water result and a high storm drain result. For the paired receiving water samples exceeding the REC-1 standards, all of the corresponding storm drain results were below the 95th percentile indicating that the storm drain discharge did not negatively impact the receiving water. The City will continue to implement this program and to conduct follow-up investigations in accordance with the Adaptive Plan. Chart 11.9 Lagoon Receiving Water Exceedances 0 2 4 6 8 10 12 14 Total Coliform Fecal Coliform Enterococcus Indicator Exceedances FY02-03 FY03-04 FY04-05 FY05-06 City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 106 11.2 Self Assessment Program Strengths The City has made progress with effectiveness assessment measures during FY 05-06. This included the continued use of surveys, pollutant loading estimations, and MS4 and water quality monitoring. As more data is collected, assessments will be more representative of actual conditions. Compliance based (Level 1) assessment is effective in showing that the City is meeting or exceeding Permit requirements. Dedicated crews for litter abatement and MS4 cleaning contribute to better overall water quality. Industrial and commercial inspections were completed as required and have been effective in reducing pollution from these sources. The amount of HHW collected through various programs increased in FY 05-06 due to the addition of methods, locations, and advertising. Construction sites with grading permits were all prioritized as high threats to water quality and are inspected frequently. Because the performance measure system has been incorporated into the storm water programs, Permit requirements were often exceeded. Changes in knowledge and awareness in storm water issues (Level 2) is addressed through education and outreach programs and in the industrial and commercial inspection programs. A public phone survey is completed annually and includes questions designed to assess changes in awareness from year to year. An “Eco-quiz” is also given to children in the City through in class school programs. This quiz assesses knowledge before and after the presentations. The City also includes an assessment question on the industrial and commercial inspection forms. This question is designed to assess knowledge and awareness on-site and changes can be tracked year to year. Changes in awareness are evident in the public survey results from 2003 to 2006 and in the results of the “eco-quiz”. Behavioral changes (Level 3) are assessed in the same manner as described above. Questions on the public surveys and on the inspection forms allow for changes in behavior to be tracked and assessed year to year. These questions are slightly different from Level 2 questions in that they are designed to assess what actions the target audience is actually taking to improve water quality. Public surveys help the program to determine which BMPs are implemented in the residential sector. Although this question has not been tracked year to year, the overview of common environmentally conscious behavior is evidence of positive impacts of the program. Estimated load reductions necessary for the Level 4 assessment are calculated using EPA modeling software. Reductions are calculated for nitrogen and phosphorus associated with improved lawn care, pet waste disposal, erosion and sediment control, street sweeping, removal of illicit connections, and reduction in sanitary sewer overflows. TSS reductions are calculated for improvements in erosion and sediment control, street sweeping, removal of illicit connections, and reductions in sanitary sewer overflows. Bacteria loading reductions are calculated for improvements in pet waste disposal, removal of illicit connections, and reductions in sanitary sewer overflows. Land use information collected from GIS analyses is necessary for generating these estimations. Significant loading reductions to the storm drain system are evident for total nitrogen, phosphorous, bacteria, and total suspended solids through BMP implementation as prescribed by the program. The ultimate goal of the program is to demonstrate improvements of water quality in receiving waters, Level 6 assessment. Receiving water quality is monitored via several programs including: in-house Performance Monitoring, dry weather monitoring, deployment of a dataSonde at Agua Hedionda Creek, coastal storm drain monitoring, and mass loading station monitoring. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 107 Tracking changes in MS4 water quality (Level 5) assessment is possible via the Dry Weather Monitoring Program. With five years of dry weather data, ranging from nutrient and physical measurements to bio- available metals and pesticides, collected at 60 sites covering the entire MS4, a picture of water quality within the system is becoming clear. While data is only collected once annually, improvements can be seen for nutrient concentrations, pH, and surfactants within the MS4. Exceedances of bacteria 95th percentile criteria in the Coastal Storm Drain Monitoring Program have declined in recent years of monitoring. FY05-06 had the fewest number of outfall samples exceeding criteria of any previous years. The Performance Monitoring Program provides the City with a baseline of water quality data in Agua Hedionda Creek and Lagoon during dry weather. This monitoring yields positive results regarding impairment listings in the lagoon and will provide a basis for future monitoring under TMDL development for Agua Hedionda Lagoon. Overall conditions in the lagoon were good for dissolved oxygen and turbidity, while ranking only fair for fecal coliform during FY 05-06 monitoring. The Dry Weather Monitoring Program expanded to include four sample locations to assess receiving water quality downstream of the MS4. In 2006 monitoring, nearly all constituents were not detected in the water samples including: MBAS, oil and grease, dissolved cadmium, dissolved copper, dissolved lead, diazinon, and chlorpyrifos. Water quality at the four locations was relatively good. The Coastal Monitoring Program requires bacteria sampling of the receiving waters, ocean and lagoon, where storm drains are flowing into the water bodies during dry weather. This program attempts to assess the impacts of the storm drain flows on water quality in the receiving water. FY 05-06 data indicates no water quality exceedances for bacteria in the ocean and only a few in the enclosed lagoons. The exceedances in the lagoons have been declining in recent monitoring seasons as water quality appears to be improving. Samples where objectives were exceeded in the lagoon did not positively correlate with high bacteria in the storm drains and were likely influenced by other bacteria sources. The Regional Monitoring Program includes a monitoring station at Agua Hedionda Creek and monitors a number of water quality constituents during storm events. During three storm events in FY 05-06, no water quality objectives were exceeded for metals (total or dissolved), nutrients, diazinon, or chlorpyrifos. In the future, this data may be used for long term water quality assessments and for TMDL monitoring information. Program Improvements Level 1, compliance based assessment, will be more effective as the City is able to better track activities and performance measures. In most cases activities are being conducted but documentation is inconsistent. Level 2, assessment of change in knowledge and awareness, is working well. In the past, assessments of changes in awareness of municipal employees were also performed and should continue to be implemented. Changes in awareness in the industrial and commercial sector are not evident through the inspection questions as awareness remains consistently high for both. With only two years of data collected, future data collection will be helpful in assessing change in industrial and commercial businesses. This question should be included on the municipal inspection forms as well. Level 3, assessing changes in behaviors, in the industrial and commercial sector are not evident through the inspection question. The implementation of BMPs remains consistently high for both. With only two years of data collected, future data collection will be helpful in assessing change in industrial and commercial businesses. This question should be included on the municipal inspection forms as well. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 108 Level 4, assessments of load reductions, should be compared to loading estimates from other jurisdictions to determine the quality of the data. For example, total loads per land use have been estimated in studies in the Los Angeles Region. These loads should be compared to the reductions calculated by the EPA model to determine the usefulness of either method. Estimates and load reductions will be calculated for future TMDL development as well. Level 5 and 6, improvements in MS4 discharge and receiving water quality, will involve inclusion of monitoring not currently performed and in-depth assessments of historical monitoring at locations where data is available. Table 11.19 is a matrix showing current monitoring programs implemented in the City and regionally. These programs cover a variety of conditions and constituents in the MS4 and receiving waters. Table 11.19 Matrix of Current Monitoring Within City of Carlsbad Watersheds Parameter Location Condition Physical Sediment Bacteria Nutrients Metals Pesticides Toxicity DRY PM, DW PM, DW PM, DW, CM DW DW DW MS4 WET DRY PM, DS, DW PM, DS, DW PM, DW, CM DS, DW DW DW RW WET DS DS, ML ML DS, ML ML ML ML PM=performance monitoring, DS=dataSonde, DW=dry weather, CM=coastal monitoring, ML=mass loading station The following improvements are anticipated to provide a better overall monitoring program, allowing for more accurate assessments of changes in water quality in the MS4 and in receiving waters. It is anticipated that several changes to the monitoring program will be implemented under the new municipal storm water permit. These changes include several new or modified monitoring programs. There will be temporary watershed assessment stations strategically located upstream of the mass loading stations. In conjunction with the outfall monitoring program, to be developed, the MS4 will be covered during wet weather events. With the full implementation of the dataSonde and data collection, additional data will be gathered for the receiving waters during wet and dry weather. Furthermore, with the implementation of Order 2006-0076, the Lagoon Investigative Order, additional water quality data will be collected in the lagoons. A dataSonde was deployed at Agua Hedionda Creek to collect continuous water quality data. The Sonde is currently in a testing phase in which all data collected is not accessible for inclusion in this report. In the future, the Sonde is expected to provide real time data for dry weather and for storm events at the creek mouth. This data will be useful in assessing conditions and changes in the Creek water quality and in future TMDL development monitoring. With the additions and changes to the existing programs anticipated in the coming years, the data collected will provide for comprehensive water quality assessments in the MS4 and in receiving waters during wet and dry weather conditions. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 109 Section 12 Fiscal Analysis Component 12.0 Overview The Permit requires the City to secure the resources necessary to meet the requirements of the Permit and the JURMP, and to conduct an annual fiscal analysis. The analysis must evaluate the expenditures necessary to accomplish the activities identified in the JURMP and describe the sources of the funds used to meet the expenditures. The Storm Water Protection Program is comprised of numerous program activities funded from a variety of sources. Table 12.1 summarizes the storm water protection program activities and identifies the current funding source: Table 12.1. Summary of Program Activities and Current Funding Sources 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 In FY 02-03 and 03-04, the City conducted a fee study to evaluate possible financing mechanisms for the Storm Water Protection Program. The new financing mechanism was detailed in the “City of Carlsbad Storm Water Pollution Protection Program Regulatory Fee Study Report”, dated September 12, 2003. The report recommended funding the storm water program through an increase in the City’s Solid Waste Service fees and new development processing fees. Nearly all of the pollutants discharged into the MS4 are classified as solid waste under state and local codes. Based on this information and other findings, the City implemented 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 is calculated based upon the apportioned costs to the business and residential service users and their contribution to the pollutant loading. The Solid Waste Service fee increase is expected to generate over $1.55 million annually in new revenues to fund the Storm Water Protection Program activities. The total operating costs to fund the storm water program activities for FY 05-06 were $1,258,562. This does not include the Storm Water Capital Improvement Program costs discussed in Section 12.1. It does, however, include actual expenditures for personnel, operating costs and capital outlay from the Storm Water Protection Program budget, including costs for street sweeping. Since the 2003 fee study and new Storm Water Fees, most of the activities related to Storm Water Protection Program and storm drain maintenance have been funded out of the “Storm Water” account. A few other items, such as the citywide litter removal and a portion of street sweeping not directly involving the City’s right-of-ways are paid for from other sources. A spreadsheet detailing the FY 05-06 expenditures for storm water activities along with the planned FY 06-07 budget is in Appendix 12-1. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 110 The September 2003 study and proposal also recommended the establishment of development processing fees to pay for costs to review and inspect construction related SWPPPs. At the current rate of development, the SWPPP review and inspection fees are expected to generate over $155,000 annually in revenues. 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 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 adopted CIP budget includes funding for $23.8 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 included within the funding of other projects is not identified in the CIP budget. Through the end of FY 05-06, the City had active drainage facility projects totaling $7.93 million in the adopted CIP budget. New projects initiated in FY 05-06 appropriated an additional $654,000. To date, approximately $3.3 million has been spent on active drainage projects. The City is committed to funding the construction of new and upgraded storm water facilities from its Development Impact Fee Program, the General Fund, and/or other revenue sources. The City will continue to investigate 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 formal Storm Drain Maintenance Program includes cleaning and minor repairs to the MS4, street sweeping, litter removal, storm event preparations, and patrolling. Historically, the cost to provide these services was funded by the General Fund. However, the adoption of the solid waste funding mechanism has provided a funding source for many of the Storm Drain Maintenance Program costs that had previously been funded in the General Fund. Street sweeping expenses totaled $198,996 during FY 05-06, additionally $101,710 was spent for litter removal. When all Storm Water Protection Program expenditures were combined, it was estimated that the total costs for storm drain maintenance activities was approximately $551,050. 12.3 Storm Water Protection Program Administration The administrative cost of the Storm Water Protection 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 for FY 05-06 was estimated at $707,512. Prior to approval of the new storm water funding mechanisms, the full cost for administration of the program was funded from the General Fund. With the approval of the new funding mechanisms, the full cost for administration of the Storm Water Protection Program is 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 include activities to detect and investigate the discharge of non-permitted pollutants into the MS4. This also includes any activities required to eliminate discharges and/or otherwise enforce compliance with the storm water regulations. The primary expenditures for the Illicit Detection and Illegal Discharge Enforcement Program for FY 05- City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 111 06 is included in the administrative costs listed above. 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. 12.5 Commercial/Industrial SWPPP Inspection Program The City’s Commercial/Industrial SWPPP Inspection Program includes the review of business related SWPPPs together with periodic site inspections to ensure compliance with requirements of the JURMP and the Carlsbad Municipal Code. The total budget allocated for the Commercial/Industrial SWPPP Inspection Program for FY 05-06 was estimated at $110,000. These costs were partially paid for out of the Storm Water Protection Program and the General Fund. Prior to approval of the new storm water funding mechanisms, the full cost for administration of the program was funded from the General Fund. 12.6 Construction Related SWPPP Review and Inspection Program The Construction Related SWPPP Review and Inspection Program also includes regular site inspections during project construction to ensure project proponents comply with the requirements of the Permit, JURMP, and Carlsbad Municipal Code. The annual cost for the Construction Related SWPPP Review and Inspection Program varies from year to year depending upon the level of development within the City. The developer processing fees will ensure that adequate revenues are generated to fund all construction related SWPPP reviews and inspections. Based upon current development activity levels, the City anticipates the annual program costs in the range of $180,000. Prior to the approval of the new storm water funding mechanisms, the full cost for the Construction Related SWPPP Review and Inspection Program was funded from the General Fund. With the approval of the new funding mechanisms, the full cost for the program will be paid from the revenues generated from the collection of development processing fees. 12.7 Self-Assessment Program Strengths The City has had a steady revenue source to fund the Storm Water Protection Program over the past year. The City also has a performance measure that compares costs for program activities such as inspection and maintenance and compares these to other cities in order to evaluate cost efficiency. Program Improvements It is difficult to accurately compare costs with other jurisdictions due to a lack of consistency for tracking costs. The City will work with the other Copermittees to pursue a more unified approach to fiscal tracking and reporting for better comparison purposes. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 112 Section 13 Special Investigations 13.0 Overview This section contains water quality data related to two Special Investigations conducted in FY 05-06. The first is described in Section 13.1 and reflects samples collected monthly at Agua Hedionda Creek (at the Mass Loading Station site) and three lagoon sites, referred to as Performance Monitoring. The second is described in Section 13.2 and was conducted as a result of a complaint and is also referenced in Section 8. 13.1 Performance Monitoring This monitoring program was first initiated in Fall of 2003 as part of the City’s Performance Measure program described in Section 11. This measure and the results are given below. The Outcome Water quality that maintains the beneficial uses of Carlsbad’s creeks and lagoons. The Measurement The City monitors storm water discharges and water quality of various creeks, lagoons and the ocean (receiving waters) in Carlsbad as part of the Coastal Lagoon and Outfall Monitoring program and the annual Dry Weather Program. In addition, the City participates in regional monitoring programs that collect data on local creeks and lagoons. The receiving water results are compared to Water Quality Objectives (WQO) listed in the 1994 Water Quality Control Plan for the San Diego Basin (Basin Plan), which are set by the State to be protective of beneficial uses. Fecal coliform bacteria, dissolved oxygen, and transparency/turbidity results will be routinely monitored in Agua Hedionda Lagoon and Creek to determine if beneficial uses are being met. Results may also show if water quality is improving or declining over time. Figure 13.1 shows the monitoring locations for this project. Figure 13.1: Performance Monitoring Site Map What Does the Data Mean? Beneficial Uses are the uses of water necessary for the survival or well being of humans, plants, and wildlife. Examples include recreation, industrial, and agricultural water supplies and the support of aquatic habitats. Beneficial uses for all surface and ground waters in the San Diego region are designated by the State in the Basin Plan. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 113 Water quality objectives are defined as “the limits or levels of water quality constituents or characteristics which are established for the reasonable protection of beneficial uses of water or the prevention of nuisance within a specific area.” If water quality objectives or other conditions are not met, the State may designate a waterbody as being “impaired”, indicating that beneficial uses may not be adequately protected, thus requiring additional costly monitoring and pollution control programs. Agua Hedionda Lagoon is a highly used waterbody that the State has identified as being impaired by sedimentation and bacteria. This lagoon has many designated beneficial uses including recreational, commercial, industrial, and as habitat for aquatic organisms. This measure is currently focused on Agua Hedionda Lagoon and Agua Hedionda Creek as a pilot program, and may be expanded in the future to other lagoons and creeks in Carlsbad. This measure determines if the numerical water quality objectives for fecal coliform bacteria, dissolved oxygen and transparency/turbidity are being met in the Lagoon and Creek. Fecal coliform bacteria concentrations are measured as human-health related indicators of sewage pollution. Fecal coliform levels must be met in order to protect the recreational beneficial uses. Dissolved oxygen in the water column is critical for respiration of most aquatic organisms. It is one of the most universal indicators of overall water quality. High dissolved oxygen concentrations represent good conditions, while low concentrations can indicate organic pollution. A transparency tube or turbidity measurement can be used to estimate the clarity of surface waters. High transparency is indicative of clean water. Low transparency is typically associated with degraded waters, indicating light limiting conditions which in turn affect plant growth and the aquatic habitat. The turbidity standard applies to the creek and the transparency standard applies to the lagoon. Meeting water quality objectives for dissolved oxygen and transparency/turbidity helps demonstrate protection of aquatic life and habitat beneficial uses. Benchmark Each sampling measure is to achieve a “good” rating 100% of the time. The following table details the sampling benchmarks. Table 13.1 Water Quality Sampling Benchmarks MEASURE GOOD FAIR POOR Dissolved Oxygen ≥ 5.0 mg/L < 5.0 less than half the time < 5.0 more than half the time Fecal Coliform ≤ 400/100 ml > 400/100 ml less than half the time > 400/100 ml more than half the time Transparency ≥ 50% of depth < 50% of depth less than half the time < 50% of depth more than half the time Turbidity (Creek) ≤ 20 NTU > 20 NTU less than half the time > 20 NTU more than half the time Results Samples were collected from October 2005 through February 2006, therefore this year’s data set represents five sampling events. Results from monthly sampling events during the sampling year are shown in Table 13.2 . Table 13.2 Water Quality Measure Results Site Dissolved Oxygen Fecal Coliform Turbidity A3 Good Good Good A6 Fair Fair Good A17 Good Fair Good Creek Good Fair Fair City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 114 Analysis The water quality results represent monthly sampling from October 2005 through February 2006. Samples from the creek and lagoon sites rated good or fair for all three measures. Agua Hedionda Creek At the Agua Hedionda (AH) Creek site, bacteria concentrations were generally low. None of the five total coliform samples were above REC-1 standards (10,000 cfu/100 ml is the Basin Plan WQO for the Estuary; no objective exists for the creek itself). Two of the five samples exceeded the WQO for fecal coliform in the creek. Enterococcus concentrations were also generally low, however studies have shown that E. coli is a better indicator of fecal contamination for fresh water systems. The action plan developed at the end of 04-05 performance monitoring recommended sampling for E. coli at the AH creek location. Monitoring for E. coli was initiated in November 2005 and the four subsequent samples were below single sample standards in the creek. Total suspended solids (TSS) and turbidity values were also low at the AH creek site. All samples for TSS were below the WQO of 100 mg/l. Two of the five samples collected were above the turbidity WQO of 20 NTU in the creek. All other physical parameters (pH, dissolved oxygen, temperature, and conductivity) were within appropriate standards. Of particular note are the dissolved oxygen levels, averaging 9.0 mg/l over the five sampling events. These concentrations are indicative of healthy conditions related to oxygen availability in the water column. Lagoon Sites Bacteria concentrations in the lagoon samples were also generally low. With three sites, 15 samples were collected over the monitoring period. Of the 15, no samples exceeded the total coliform standard, two samples (13%) exceeded the fecal coliform standard, and three samples (20%) exceeded the enterococcus standard. Rec-1 standards are used in the lagoon as designated in the Basin Plan. Two samples in the lagoon were above the TSS WQO. However, seven of the turbidity samples collected were above the WQO. Other physical parameters were within applicable standards. Dissolved oxygen levels were above 5.0 mg/l on all but one sample, indicating good oxygen availability in the water column the majority of the time. Samples for pH, temperature, and conductivity were consistently good as well. Chart 13.1: Fecal Coliform Results for All Four Sites by Month. Chart 13.1 Fecal Coliform by Site and Month 0 500 1000 1500 2000 2500 3000 3500 Oct-05 Nov-05 Dec-05 Jan-06 Feb-06 Monthcfu/100 mlA3 A6 A17 AH Creek City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 115 Chart 13.2: Total Coliform Results for All Four Sites by Month Chart 13.2 Total Coliform by Site and Month 0 500 1000 1500 2000 2500 3000 3500 4000 Oct-05 Nov-05 Dec-05 Jan-06 Feb-06 Monthcfu/100 mlA3 A6 A17 AH Creek Chart 13.3: Enterococcus Results for All Four Sites by Month Chart 13.3 Enterococcus by Site and Month 0 100 200 300 400 500 600 700 Oct-05 Nov-05 Dec-05 Jan-06 Feb-06 Monthcfu/100 mlA3 A6 A17 AH Creek City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 116 Chart 13.4: TSS Results for All Four Sites by Month Chart 13.4 Total Suspended Solids by Site and Month 0 50 100 150 200 250 Oct-05 Nov-05 Dec-05 Jan-06 Feb-06 Monthcfu/100 mlA3 A6 A17 AH Creek Chart 13.5: Results of Turbidity Monitoring at All Four Sites by Month Chart 13.5 Turbidity by Site and Month 0 50 100 150 200 250 300 Oct-05 Nov-05 Dec-05 Jan-06 Feb-06 Monthcfu/100 mlA3 A6 A17 AH Creek City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 117 Chart 13.6: Results of Dissolved Oxygen Monitoring at All Four Sites by Month Chart 13.6 Dissolved Oxygen by Site and Month 0 2 4 6 8 10 12 Oct-05 Nov-05 Dec-05 Jan-06 Feb-06 Monthcfu/100 mlA3 A6 A17 AH Creek Summary From the graphs, it appears that the water quality in the lagoon is not driven by conditions in Agua Hedionda Creek during dry weather periods. For example, Chart 13.4 illustrates the TSS concentrations at the four locations. In all five sampling events, TSS concentrations in the creek are 10 mg/l or less, while the TSS concentrations are higher in the lagoon samples, especially in October and November. Including data collected in this reporting period, 29 monthly samples have been collected at Agua Hedionda Creek and at three locations in Agua Hedionda Lagoon. Table 13.3 shows the results of all data collected since 2003. Table 13.3 Water Quality Measure Results, 2003-2006 Site Dissolved Oxygen Fecal Coliform Turbidity A3 Good Good Good A6 Fair Fair Good A17 Fair Fair Good AH Creek Good Poor Fair With the exception of fecal coliform concentration in the creek, other water quality parameters were good or fair. The Storm Water Protection Program has continued to address potential urban sources of fecal contamination (pet waste, sewage leaks, septic systems, animal facilities, etc) through inspections, enforcement, and education. Recent monitoring of fecal contamination using E. coli, the preferred freshwater fecal indicator, has shown concentrations within Basin Plan standards. Recommended Action Plan Two projects to be fully implemented in upcoming years are expected to greatly supplement the existing data collected in this program. With the commencement of required monitoring under the Lagoon Investigative Order No. 2006-0076, a comprehensive monitoring program will be implemented in several of the lagoons in the region, including Agua Hedionda. In preparation for this monitoring, the City has installed a datasonde at Agua Hedionda Creek, designed to gather and transmit continuous sets of data for many water quality parameters. This datasonde is expected to augment future data collection when fully operational. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 118 With the onset of these projects in the near future, the Performance Monitoring has been suspended and samples were not collected during or after the dredging of the Creek in the spring of 2006. The recommended action plan is to integrate the data collected as part of this program with data collected in the future programs to provide a better picture of water quality in Agua Hedionda Lagoon. 13.2 Leo Carrillo Historical Park Investigation In late December of 2005, two discharges from a wetland in the Leo Carrillo Ranch Historical Park were reported to the Storm Water Protection Program. Upon site investigation, it appeared that the materials were the same two materials analyzed and found to be non-hazardous in 2003. The first discharge was a brown rusty liquid with an oily sheen and no discernible odor that covered a larger area than previously observed. The second discharge was a white substance prevalent throughout the wetland area which appeared to originate from the hillside or from within the wetland vegetation. The white substance formed in thick sedimentary layers and collected as a powdery foam in the peripheral zones of the wetland. In early 2006 it was determined that, due to the recurrence of the substance, an investigation should be undertaken to determine the extent of the discharge, its composition, any hazardous characteristics and possible remedial actions. Samples of water and sediment were collected and analyzed for: metals, total petroleum hydrocarbon, fish bioassay (to determine toxicity) and pesticides. The results of the investigation are as follows: • Brown rusty water: The results of the site investigations and sample testing determined that the brown liquid was non-toxic with low or non-detectable concentrations of heavy metals, total petroleum hydrocarbon and pesticides. The discharge is most likely to be the result of naturally occurring swamp liquid consisting of tannins (which cause the rust coloration) and naturally occurring bacteria (which produce foam and an oily sheen to the water). • White discharge: The results of the sample testing showed that the water and sediments containing the white substance were non-toxic with low or non-detectible concentrations of metals, total petroleum hydrocarbon and pesticides. Analysis did suggest that the white discharge could be a calcium deposit. Calcium levels in the water samples were extremely elevated and microscopic analysis suggests the presence of coagulated minerals rather than biological accumulations. Findings from the County of San Diego, Department of Environmental Health, State of California Fish and Game, and U.S. Fish and Wildlife Service show that the materials are non-hazardous. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 119 Section 14 Conclusions and Recommendations 14.0 Overview During FY 05-06, the City implemented the Permit requirements and the program components of the JURMP. This report described the activities that the City undertook to reduce discharges of pollutants and urban runoff flow to the MS4 to the maximum extent practicable. This Annual Report also provided an overall account of the activities conducted and the programs implemented to address the inspection, monitoring, investigation, education, and enforcement requirements. Identified program strengths as well as improvement areas for FY 06-07 are outlined in each report section. Several highlights are listed below, including specific discussion of activities conducted related to meeting Permit requirements, internal program goals that that met or exceeded Permit requirements, and recommended improvements. Note that these are highlights only and do not represent all activities conducted by the City to maintain and exceed compliance. Comprehensive details are reported in the applicable preceding sections. This section concludes with a discussion of water quality improvements or degradation related to the MS4 and receiving waters. 14.1 Highlighted Activities Performed to Meet Permit Requirements The City continued activities to maintain compliance with the Permit. For comprehensive details, please refer to the applicable preceding sections of the report. Highlights for FY 05-06 are listed below. The City: • Updated and mapped the municipal inventory and inspected all high priority municipal facilities. • Conducted cleaning and maintenance activities to reduce pollutant discharges from the MS4. • Updated and mapped the industrial inventory, inspected 351 industries (including all high priority industries), conducted outreach, and issued 18 enforcement actions to obtain compliance. • Updated and mapped the commercial inventory, provided outreach on BMPs, inspected 443 commercial sites, and issued 56 enforcement actions to obtain compliance. • Continued using the Knowledge and BMP Assessments at commercial and industrial facilities. • Collaborated with other internal departments to assist with investigations and remediation during field incidents. The Storm Drain Maintenance Crew was key to prompt, effective responses to complaints involving clean ups of incidents on public streets. Regular meetings and discussions about compliance issues and consistent contacts facilitates this inter-departmental coordination. • Distributed educational information for residential activities, continued an advertising campaign, hosted or participated in 13 community outreach events, collaborated in offering four oil recycling and HHW drop-off sites for residential use, responded to 107 reports of illegal discharges, and issued 37 enforcement actions to obtain compliance. • Inspected all high priority construction sites at required frequencies, conducted outreach to project proponents and City staff, and issued 30 enforcement actions to obtain compliance. • Continued implementation of the Dry Weather Field Screening and Analytical Program, analyzing conditions and samples from 60 sites in the MS4. • Continued implementation of the Coastal Outfall Program by routinely monitoring 23 “active” outfall sites on a regular basis, and 28 “inactive” sites semi-annually. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 120 • Conducted a proactive program to detect and eliminate illegal discharges to the MS4. The public continued to use the storm water hotline and e-mail address to report illegal discharges to the storm drain system. The Storm Water Protection Program responded to 107 reports of illegal discharges to the storm drain system. In addition, the City responded to 420 complaints or requests for action related to storm water quality, the sewer system, or MS4 maintenance. • Continued implementation of the Sewer Overflow Prevention Plan/Response Plan and responded to 19 sewage spills or overflow reports, with a total of 98 gallons recovered and approximately 1,509 gallons entering the environment. • Continued involvement in outreach and education at the local level, the watershed level with the NCSWP, and the regional level with the Project Clean Water Outreach Workgroup. • Created new storm water educational brochures and continued the Environmental Programs advertising campaign. • Distributed information through direct mail, during inspections and investigations, on the website, at workshops, during presentations, training seminars, and other public outreach events. • Conducted a Public Opinion Survey of 1,000 residents and included questions on storm water. • Distributed promotional items such as notepads, pens, Bags on Board, and key chains with pollution prevention messages. These new and existing media messages resulted in over 1,000,000 impressions. • Decreased illegal discharges from commercial mobile businesses. 14.2 Highlighted Activities In Addition to Permit Requirements The City implemented several initiatives in addition to the requirements of the Permit. Some of these highlights are internal program goals and should not be viewed as enforceable under the Permit. These internal program goals will be continued and enhanced as resources allow. For comprehensive details, please refer to the applicable preceding sections of this report. Highlights for FY 05-06 are as follows: The City: • Revised the streamlined inspection report so that businesses could promptly implement corrective actions. The revised streamlined inspection form now includes spaces to report previous enforcement actions, new storm water contacts, and a detailed list of necessary corrective actions. The revised form has proven to be successful in attaining compliance from regulated facilities. • Coordinated with the Public Works Director to participate in several commercial and industrial compliance inspections. During the inspections, the Public Works Director received additional and current information about inspection procedures, compliance issues, enforcement actions, and problem areas in the City. In addition, the Public Works Director also accompanied staff during the storm drain maintenance and inspection activities, and water quality monitoring activities. • Hosted a free pollution prevention workshop for area businesses that prepare and/or sell food and beverages. Approximately 300 businesses were invited to attend and all invitations included information about storm water and BMPs. The workshop provided food service owners, managers, and staff with important educational tools to help businesses comply with pollution prevention requirements. Participants received training in pollution prevention, trash and grease management, and the requirements of the Carlsbad Municipal Code. Featured speakers from the City, Waste Management, and the San Diego County Green Business Program provided information about storm water requirements, pollution prevention strategies, and BMPs. • Continued to maintain regular communications with the Industrial Compliance Unit of the Regional Board. In addition to copies of inspection reports and other correspondence with high and medium industries covered under the Permit, the City regularly coordinated compliance issues with Regional Board representatives over the phone and through emails. On several City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 121 occasions, the Regional Board expressed their appreciation of the City’s professionalism, responsiveness, and implementation of the storm water program. • Developed a new brochure for mobile service providers, including carpet cleaners, plumbers, pressure washers, mechanics, porta-potty services, and any other mobile businesses that provide services at various off-site locations. This brochure was designed for mobile service providers, their employees, and anyone that hires a mobile service provider. During FY 05-06, the “Best Management Practices for Mobile Service Providers” brochure was mailed to every applicable business on the storm water inventory. • Continued Storm Water Committee monthly meetings which included members from Public Works, Fire Department, and the Building Department. The meetings provided a forum for discussion of municipal storm water BMPs and pollution prevention issues. • Continued to use the new database to track private treatment BMPs implemented under SUSMP. • Recommended and City Council approved the implementation of a new HHW pick up program. The program provides a means for Carlsbad residents to have HHW picked up from their homes and hauled away for a nominal fee. In addition, residents can also dispose of HHW for free at three permanent facilities in Vista, Oceanside, and Poway. • Continued to track measures in the Performance Measurement System to monitor various environmental goals, including annual sewage overflow spills and responses, storm water complaint response time, and performance monitoring on Agua Hedionda Creek and Lagoon. • Continued to implement a Maintenance Assessment Program to measure the level of care being provided at various City facilities. • Continued to implement a computerized asset management/work order system that will allow the Storm Drain Maintenance Crew to keep track of the MS4 inventory, inspections, and maintenance activities conducted. 14.3 Highlighted Recommendations for Improvement As the City implemented the JURMP in FY 05-06, some areas for improvement were noted for FY 06-07. Comprehensive details are included in applicable preceding sections of the report, but highlights are listed below. Areas targeted for improvement in FY 06-07, including the following: The City will: • Continue to research, observe, and evaluate the performance of various types of BMPs. • Update the Rough Pad Stabilization example to improve project proponents’ knowledge of the City’s expectations. This activity is expected to be completed in FY 06-07. • Distribute a copy of the Pollution Prevention Guide to the Construction Industry brochure with each construction-related permit application. • Consider posting minimum BMPs on the City’s website for access by the public, permit applicants, developers, and property owners. • Review inventory management, prioritization practices, inspection and enforcement procedures, training programs, record-keeping, and reporting procedures related to construction activities. Expected improvements include formalizing procedures, documenting common practices, and training employees on existing, improved, and new procedures city-wide. Annual review of written SOPs will be considered for updating procedures and conducting refresher training. Implementation of improvements may include activities occurring in FY 07-08. • Improve the Carlsbad Municipal Code by working with the City Attorney’s office to revise the ordinance to reflect current enforcement levels and mechanisms. Revision should be complete by the end of FY 06-07. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 122 • Continue working on a “Best Management Practices Manual” that includes the minimum and required BMPs for activities and pollutant types. The manual will be continually worked on during FY 06-07 and should be completed by early FY 07-08. • Revise brochures and fact sheets to reflect changes in the program. A complete revision of all brochures it is expected to be completed by end of FY 07-08. • Work on developing a comprehensive database of existing and proposed permanent storm water BMPs and other pollution control devices to facilitate Permit compliance and reporting. • Adopt new storm water BMP maintenance agreements and incorporate into standard operating procedures. The current method of ensuring compliance with storm water BMP maintenance requirements is through provisions included within project CC&Rs. The new BMP maintenance agreements will provide increased control over property owner compliance with storm water BMP requirements. These new agreements will also provide the City with legal authority to access, inspect and if necessary maintain onsite BMPs. In addition, the agreements will allow the City to place a lien on a property if BMPs are not maintained as required. • Monitor Dry Weather Program results in the area of the Car Country Carlsbad, Carlsbad Premium Outlets, and Carlsbad Flower Fields. Past data continue to show elevated nitrate concentrations in these areas. High nitrate levels have also been discovered in groundwater beneath croplands due to excessive fertilizer use, especially in heavily irrigated areas with sandy soils. The City has conducted extensive inspections upstream of the reports. To date, the Storm Water Protection Program has not been able to identity a source of the nitrates, but will continue to monitor dry weather results, conduct frequent inspections, and require the implementation of BMPs that reduce or eliminate nitrates. • Continue using a new model to calculate uncontrolled loading of sediment, nutrients and bacteria from existing land uses and the pollutant load removal achieved from implementation of various storm water management programs and treatment options. • Improve the formal “Catch Basin Inspection Program” by reassigned resources to dedicate a work order system that tracks routine and scheduled catch basin inspections and cleaning activities. As a result of this formal program, the City expects that 100% of catch basins will be inspected and cleaned as needed during FY 06-07. This program is scheduled to begin in July 2006 and will be discussed during the next reporting period. • Coordinate Storm Water Protection Program and M&O activities to improve the Fats, Oils, and Grease Program. Although the Storm Water Protection Program has developed outreach materials that address oil and grease, it continues to be a pollutant source, especially at restaurants. The City will continue to improve this program and address grease trap maintenance, outdoor tallow bin storage, and proper clean up and disposal of spilled grease. • Collect data for Performance Measures and the Maintenance Assessment Program to analyze alternative work methods to improve the balance of scheduled versus unscheduled maintenance. • Conduct a thorough review of all internal NPDES programs to ensure compliance with the Permit prior to implementing the new Order expected to be formalized in January of 2007. • Consider adopting an environmental initiative to look at environmental resources from a City- wide perspective including storm water, energy, desalination, and open space. • Continue to work at the watershed level and help focus activities on high priority pollutants. 14.4 Water Quality Improvements or Degradation The complete 2006 Dry Weather report is contained in Appendix 8-1 of this report. Additional analyses of the MS4 water quality are found in Section 11 of this report. Special receiving water studies were also conducted with results listed in Section 13 of this report. Please refer to the Carlsbad Watershed FY 05- 06 Annual Report for data trends supporting the focus on High Priority Pollutants on a watershed basis. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 123 The following text highlights some of the observations on water quality. References to specific charts are given in parentheses. MS4 Water Quality With five years of data from the Dry Weather Program, ranging from nutrient and physical measurements to bio-available metals and pesticides, collected at 60 sites covering the entire MS4, a picture of water quality within the system is becoming clear. While data is only collected once annually, improvements can be seen for nutrient concentrations, pH, and surfactants within the MS4. Exceedances of bacteria 95th percentile criteria in the Coastal Storm Drain Monitoring Program have declined in recent years. FY 05-06 had the fewest number of outfall samples exceeding criteria of any previous years in the program. Specific water quality information from these programs is highlighted in Sections 8, 11, and 13 of this report. All these programs were conducted under dry weather conditions. Receiving Water Quality The City is beginning to conduct additional receiving water monitoring to assess receiving water quality in Carlsbad. Current programs include the Coastal and Lagoon Outfall Monitoring Program, the addition of four creek sites to the Dry Weather Program, deployment of a dataSonde at Agua Hedionda Creek, mass loading station monitoring, and the Performance Monitoring Program initiated in FY 03-04. Specific water quality information from these programs is highlighted in Sections 8, 11 and 13 of this report, and in the San Diego County Municipal Copermittees Urban Runoff Monitoring Annual Report. All of these programs were conducted under dry weather conditions, except for the mass loading station data collection, which was conducted during wet weather events. Coastal Monitoring Program data indicates no water quality exceedances for bacteria in the ocean and only a few in the enclosed lagoons. The exceedances in the lagoons have declined in recent monitoring seasons and water quality appears to be improving. Samples where objectives were exceeded did not positively correlate with high bacteria in the MS4 and were likely influenced by other bacteria sources. Dry Weather Program monitoring found that nearly all constituents were undetected in the four additional creek sites’ water samples including: MBAS, oil and grease, dissolved cadmium, dissolved copper, dissolved lead, diazinon, and chlorpyrifos. Water quality at the four locations was relatively good. A dataSonde was deployed at Agua Hedionda Creek to collect continuous water quality data. The Sonde is currently in a testing phase in which all data collected is not accessible for inclusion in this report. However, in the future, the Sonde is expected to provide real time data for dry weather and for storm events at the creek mouth. This data will be useful in assessing conditions and changes in the Creek water quality and in future TMDL development monitoring. The regional monitoring program includes a mass loading monitoring station at Agua Hedionda Creek that monitors a number of water quality parameters during storm events. During three storm events in FY 05-06, no water quality objectives were exceeded for metals (total or dissolved), nutrients, diazinon, or chlorpyrifos. In the future, this data may be used for long term water quality assessments and for TMDL monitoring information. Under the Performance Monitoring Program, overall conditions in the lagoon were good for dissolved oxygen and turbidity, while ranking only fair for fecal coliform during FY 05-06 monitoring. City of Carlsbad JURMP Annual Report for July 1, 2005 – June 30, 2006 124 14.5 Conclusion The Storm Water Protection Program continues to evolve over time in response to the iterative process of implementing BMPs, assessing effectiveness, and evaluating results. As more procedures, programs and activities are implemented, there is a clear need for better databases to track and report activities and BMPs being implemented. Tying 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 individually and with the Copermittees to further develop existing compliance programs and create new opportunities for improvement. This Annual Report demonstrates the City’s compliance with the Permit and success implementing the JURMP. Previous sections of this report show that knowledge has increased in target communities, improved BMP implementation and behavior changes are occurring, pollutant loadings are being reduced from storm water management programs, the MS4 quality is improving, and some pollutants in receiving waters are improving. These are encouraging signs that are worth noting. The City recognizes that changes are likely to happen slowly and that continued program improvements and effectiveness measures are needed for long-term success.