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HomeMy WebLinkAboutAgenda Bill 3.B 03/03/2003; a 1 CITY OF PETALUMA, CALIFORNIA AGENDA BILL MAP 0 2003 Agenda Title Resolution Approving the Storm Water Meeting Date: Management Program and Authorizing the City Manager to Execute March 3, 2003 and Submit the Notice of Intent and Storm Water Management Program to the San Francisco Bay Regional Water Quality Control Board for Coverage Under the State General Permit for Storm Water Discharge Pursuant to the National Pollutant Discharge Elimination System Phase II Storm Water Regulations. (Ban/Eckerson) Department Director Contact Person Phone Number Water Resources and Michael Ban, P.E. Dean Eckerson, 707 - 778 -4583 Conservation P.E. Cost. of Proposal Approximately $30,000 /year Account Number 602- 400 -6250 Amount Budgeted Will be budgeted in FY 03 -04 Name of Fund Storm Drain Attachments to Agenda Packet-Item • Agenda Report • Exhibit A — Storm Water Management Program • Exhibit B —Notice of intent • Exhibit C — Resolution Summary Statement The -Storm Water Phase H Rule is the U.S. Environmental. Protection Agency's (U.S. EPA's) second phase of the National Pollutant Discharge Elimination System ( NPDES) Program for storm water discharges. The Phase II Rule promulgated in 1999 requires operators of the municipal separate stormm sewer systems (MS4s) in urbanized areas and operators of small (one to five acres) construction sites, through the use of NPDES permits, to implement programs and practices to manage storm water runoff. NPDES Permits are, required because storm water discharges from these MS4s are considered sources of pollution. The California Regional Water Quality Control Board, San Francisco Bay Region is the regulatory agency with NPDES Permit oversight authority for Petaluma. The Storm Water Phase II Final Rule requires the City of Petaluma as an MS4 operator, to apply for coverage under the State General NPDES Permit. By March 10, 2003, the City is required to submit (1) a Notice of Intent, (2). a Storm Water Management Program, and (3) pay a permit fee of'$3,750 to the Regional Board. Council Priority THIS AGENDA ITEM IS CONSIDERED TO BE PART OF, OR NECESSARY TO, ONE OR MORE OF THE 2001 PRIORITIES ESTABLISHED By THE CITY COUNCIL ON JULY 21, 2001. Priority(s): N/A Recommended City Council' Action /SugLrested Motion City Management recommends the City Council consider the presentation on the Storm Water Management Program, receive public comments, provide direction to City Management on clarifications, if appropriate, and adopt the resolution approving the. Storm Water Management Program and authorizing the City Manager to execute and submit the Notice of Intent and Storm Water Management Program to the San Francisco Bay Regional Water. Quality :Control Board for coverage under the State General Permit for storm water discharge pursuant to the National Pollutant Discharge Elimination System Phase II Storm Water Regulations. Reviewed by Finance Director: Reviewed by City- Attorney Date: A rov�e(Id',b ana er: , U U 'f Date: f + ate: Y y � Today's Date i Revision_ # and Date Revised: File C de. Febr uary 14, 2003 4 S: /WR &C /Agenda/3 -3 -03 NPDES CITY OF PETALUMA, CALIFORNIA MARCH 3, 2003 AGENDA REPORT FOR RESOLUTION APPROVING THE STORM WATERMANAGEMENT PROGRAM AND AUTHORIZING THE CITY MANAGER TO' EXECUTE AND SUBMIT THE NOTICE OF INTENT AND STORM WATER MANAGEMENT PROGRAM TO THE SAN FRANCISCO BAY REGIONAL WATER QUALITY CONTROL BOARD FOR COVERAGE UNDER THE STATE GENERAL PERMIT FOR STORM WATER DISCHARGE PURSUANT'TO THE NATIONAL:, POLLUTANT DISCHARGE ELIMINATION SYSTEM PHASE II STORM WATER REGULATIONS 1. ExECUTIVE SUMMARY The Storm Water Phase IlRule is the U.S. Environmental Protection Agency's (EPA's) second phase of the National. Pollutant Discharge Elimination System ( NPDES) Program for storm water discharges. The Phase II Rule promulgated y in 1999 requires operators of the municipal separate storm sewer systems (MS4s) in. urbanized areas and operators of small (one to five acres) construction sites, through the use of.NPDES permits, to implement programs and practices to manage storm. water runoff. NPDES Permits are required_ because storm water discharges from these MS4s are considered sources of pollution. The California Regional Water Quality Control Board, San Francisco Bay Region is the regulatory agency with NPDES Permit ® oversight authority for Petaluma. The Storm Water Phase It Final Rule requires the City of Petaluma, as an MS4 operator to apply for coverage under the State General NPDES Permit. By March 10; 2003, the City is required to submif (1) Notice of Intent, (2) a Storm Water Management. Program, and (3) pay :a permit' fee of $3,750 to the Regional Board. City Management recommends City Council consid&lhe presentation on the Storm Water Management; Program, receive public comments, provide direction to City Management on clarifications, if appropriate, and adopt the resolution approving the Storm Water Management`Program and authorizing the City Manager to execute and submit the Notice of Intent and Storm Water Management Program to the San Francisco Bay Regional' Water Quality Control Board for coverage under the State General Permit for storm water discharge pursuant to the National Pollutant Discharge Elimination System Phase II Storm Water Regulations. 2. BACKGROUND In 199 -9, the U.S. Environmental !Protection Agency (EPA) promulgated Storm Water Phase :II regulations . for storm water discharges in cities between 10,000 and 100,000 population. The federal Storm Water Phase lI Final Rule requires operators of small municipal separate storm. sewer systems (MS4s), such as the City of Petaluma, to comply with the National Pollutant. Discharge Elimination System ( NPDES) requirements to reduce pollutants and protect water quality, by March 10, 2003. NPDES compliance is required =for the City because storm water discharges are considered sources of pollution. 1 The EPA designated the. State Water Resources. Control Board (SWRCB) as the statewide permitting authority in California. Specifically, the Phase TI regulations require the SWRCB to issue NPDES permits to all operators of MS4s. In compliance with.the Phase II regulations, the SWRCB issued a draft General Permit in October 2002. The draft General Permit sets forth.the NPDES requirements for all applicable permittees to promote consistency under the EPA Phase II rule. The Final Phase II General .Permit is expected to be -adopted by the SWRCB sometime in the first quarter of 2003. In order to comply with the Phase II NPDES requirements as set forth in the State General Permit, the Cit must submit.a Notice of:Intent OI a Storm Water Man _ (N ), ageinent "Program (SWMP), and pay 50 % of the annual permit fee: PRIORITY POLLUTANTS Enactment of the Federal Water Pollution Control Act of 1972 established federal laws to reduce or eliminate pollutants in waters of the. United States. As amended in 1977, these laws became known as the Clean Water Act (CWA). Section 303 (d) of the CWA requires states to identify and list all surface waters that do not, meet applicable water quality standards. The surface waters on the, list do not meet water quality "standards, even after point sources of pollution have installed the minimum required levels of pollution control technology., The CWA further requires states to establish priority rankings for the listed. water bodies and develop action plans, known as Total Maximum Daily Loads (TIVIDLs),. to reduce or eliminate the identified pollutants and improve water quality in support of the beneficial uses. In compliance with the CWA, the State Water Resources Control Board identified a 22- mile -long segment of the Petaluma River as not - meeting water quality standards. Impacts. from urban runoff, construction, land development, and agricultural runoff have resulted in the CWA,Sectiori 303 (d) listing of the Petaluma River- for nutrients, pathogens, and sediment; in our, jurisdiction. The TMDLs for these pollutants are identified has a medium pri ority and -are expected. to be completed in the next several years. Recently, diazinon Was added to the C,WA Section 303 (d) list for the:Petaluma River, with a low priority TMDL. The NPDES Phase II General Permit requires permittees to address the priority °pollutants identified in their watershed. The, City's Storm Water Management Program, is designed to reduce .or eliminate the priority pollutants in :our watershed, and to improve water quality`,iri support of the beneficial uses of our surface water bodies. The Petalunia,River watershed supports beneficial uses for cold and warm freshwater habitat, fish migration, preservation of rare and ;endangered species, fish spawning, wildlife habitat, and contact and non- contactwater recreation. In addition, groundwater is a source of drinking and irrigation water in Petaluma and ; rural :areas of the County. Since the City's jurisdiction encompasses only about 10% of the Petaluma River watershed, effectively addressing the priority pollutants depends largely on the clean `water programs of the other agencies and jurisdictions in the watershed also subject to'Phase I or Phase II NPDES requirements. 0 A 0 ROLES ANDRESPONSIBILITIES FOR PROGRAM IMPLEMENTATION • The City's Phase II Storm Water Management. Program constitutes the first citywide, comprehensive program to significantly reduce or eliminate pollutants in our surface waters. This involves the coordination, monitoring, and reporting of a number of existing activities, along with the implementation of new activities with the goal of protecting water quality. Closely related to this program, the City will also be implementing a storm water operations and maintenance program in the Water Resources and Conservation Department to pro-actively manage the City's surface drainage facilities. The Phase II Storm Water Management Program impacts every City department to some degree. The Water Resources and Conservation Department will coordinate our overall efforts, with the Engineering Manager serving as the Program Leader. Quarterly meetings will be held to update the program leader and allow adjustments to the program to take place. As time goes on, participants will begin to see opportunities to combine efforts and reduce individual workloads. On another level, the Program Leader will be meeting with other Phase II communities, namely, Cotati, Rohnert Park, Sonoma, and Windsor, and Phase I communities and agencies, namely Santa Rosa, Sonoma County, and the Sonoma County Water Agency. Any opportunity to work together, combine resources, and share responsibilities will be explored to ensure we undertake the most feasible and cost effective approach to reducing pollutants and protecting water quality in our watershed. The Phase II program requires the development of a Storm Water Management Plan, which will be presented to the RWQCB on March 10, 2003. The EPA defines a Storm Water Management Plan as a program consisting of six elements that, when implemented together, are expected to achieve significant reductions of pollutant discharges into receiving water bodies, in our case the Petaluma River and its tributaries. The six Minimum Control Measures required by the permit are: ® Public Education and Outreach (PE/0) • Public Participation/Involvement (PP/1) • Illicit Discharge Detection and Elimination (IDDE) • Construction Site Storm Water Runoff Control (CONS I • Post - Construction Storm Water Management (POST- CONST) • Pollution Prevention for Municipal'Operations (Muni P2) A minimum control measure is composed of measurable goals that identify pollutants of concern, such as sediment or metals, the target audience, who is responsible for implementation, and'several `best management practices' (BMPs) or procedures to reduce or eliminate the pollutant. A detailed description of each of the six Minimum Control .Measures is provided in Ekhibit A. As a permttee, the City must evaluate its situation and determine what BMPs work best. , During the development of our Storm Water Management Program, numerous activities considered BMPs were identified as already implemented in all six Minimum Control Measure areas. As well, many of our other activities will be augmented with new components such as record. keeping, formal 3 training, or public education to make them eligible as BMPs under this program. The RWQCB has strongly encouraged, the City to participate in group efforts and activities and adapt othermunicipalities' work, where appropriate, to our situation to make the best use of all resources in our area. TheDepartments affected by this program and the BMP categories that apply are shown in Table 1. C 0 4 Table 1 Best Management Practices Listed.by Department • • Minimum Contact Department Division Control Probable BMPs Position Measures Water Engineering. Engineering All See SWMP, Storm Water Resources & Manager (Program Pollution Prevention Conservation Leader) Ordinance Transmission & Lead Worker Muni P2 Dechlorination procedures for Distribution. flushing Cross- Connection Specialist IDDE Incorporates storm water components into inspections Water Conservation Coordinator PE /O and PP/I Incorporates storm water = surface water - drinking water message Storm Drain Lead Worker Muni P2 See SWMP Maintenance Wastewater Lead Worker IDDE Look for illicit cross - (Collections) connections between sanitary sewer and storm systems Source Control & Engineering IDDE Incorporates storm water P2 Manager (Program components into inspections Leader), Community Permits Assoc. Civil Eng. Construction and Ensures SW BMPs addressed Planning Services Planning Staff Gen. -Plan + CEQA checklist Development Post- Construction plans, BMP revisions placement, Associate Planner Initial check of plans inspection, and Inspection Services Inspection Confirm the CONST BMPs /Code Enforcement Supervisor enforcement in place Engineering City & Assoc. Civil activities will be Revise grading ordinance Services Engineers the focus of this division Public Public Facilities Public Facilities IDDE, Muni P2 Documents areas of leaf Facilities & Manager build -up (residents push into Services streets) for targeting pub. ed. efforts Street Maintenance 'Maintenance IDDE Review bridge &_ dock BMPs Worker III (bridges for applicability & & docks) implementation Airport Airport Manager Muni P2 Airport surface, maintenance, airplane maintenance BMPs Turning Basin Maintenance IDDE Boating BMPs, see Parks - Worker Marina Park & Parks Parks Manager Muni P2 IPM implementation, control Recreation over watering, Replant with drought tolerant native species Parks Maintenance Muni P2 Pet Waste Management & ' Workers PE /O signs and bags Marina Marina Manager Muni P2 Boating BMPs — gather PE /0 materials for Dept. of Boating & Waterways Police 'Pafrol Officers Patrol Sergeants IDDE Call -in illicit dumping sightings, issue nuisance citations for dumping Fire Hazardous Fire Marshall IDDE Alert Program Leader of any Materials/Fire building exterior activities Department that may contribute to storm Ins ectors water pollution Exhibit A includes , a detailed listing of existing BMPs already implemented in various City Departments..In order to complywith the Phase H NPDES requirements, our program includes additional activities for City staff to undertake. The Water Resources and Conservation and Community Development departments will share the bulk of the additional workload. involved with carrying out the Storm Water Management Program. Because of their level of involvement, discussion of their responsibilities is elaborated. herein. Water Resources and Conservation Department As the; department housing the Program-Le'ader, much of the - coord'inati'on and. information gathering responsibilities reside here. The Program Leader will regiiire functional authority (the ability to obtain work from staff members that are not directly supervised) over. the positions identified in the other city departments: The Water Resources and. Conservation Department (WR &C) will handle all storm water maintenance. issues involved with the water distribution, storm water conveyance, and sewer collection systems. There are two areas that could have storm water components added to existing inspection routines, cross- connection specialist .and industrial waste (source control) inspections. ' Engineering Manager will make recommendations for or'write the storm water ordinance and handle budgeting for the program. Although there is a great deal ofwork involved in setting up a, program of this magnitude, we plan. to utilize existing clerical staff to handle the responsibilities of data management for the Program Leader. Closely related to the Storm. Water 1Vlanagement.Program, the Water Resources and Conservation Department will be implementing a storm water operations and maintenance program. The operations and maintenance program was developed in conjunction with the General Plan update and establishes a plan and procedures for managing our surface water drainage infrastructure. Many of the maintenance activities included in the plan, such as the routine inspection and cleaning of storm drain inlets, will qualify as Best Management Practices for our Storm Water Management Program. In support of implementing the storm water operations and maintenance program, it is anticipated that up to three,additional'field staffw. ill need to be added in the Water Resources and Conservation Department. Community Development Department As mentioned above, the Community Development Department (CDD) will have its fair share of.work in this program, also. Much of this effort will build on and supplement. activities already being completed by CDD. The Petaluma River is listed as being impaired for sedimentation, pathogens, and nutrients. The primary sources of sedimentation'are construction sites and urban iunof. . Minimum compliance will require 0 2 coordination between the Building, Planning, Engineering and Inspection divisions. • Modifications of existing and creation of new documents and procedures include: ® General Plan and CEQA checklist amendments to incorporate additional water quality elements; ® Grading & Erosion. Control ordinance revision; o Engineering Design Standards and Standard Plan revisions; ® Building `plan checklist additions; o Building and public works inspections; and ® Best Management. Practices (BMPs) public construction industry education materials for specific construction activities. ® Enforcement Planning/Engineering Division When a business, property owner, or developer submits a project to the Planning Division, approval is granted either by staff, the Planning' Commission, or City Council. During the staff review stage, before any one of these approvals can be granted, construction and more complicated, post- construction issues must be addressed. Staff will have to decide how'a project's layout will impact storm water runoff, how erosion will be controlled during construction, and who will ultimately be responsible for post - construction maintenance, issues. These are complex issues that will need to be discussed • amongst key players. It is advised that staff make site visits to other larger agencies that have been handling these issues for 10 -15 years now. Building and Public Works Inspection At some point, projects are referred to the Building Department for issuance of a building or enroachment permit. Each project of one or more acres should have a site map with -BMPs identified and their location,clearly marked. Projects greater than 1 acre of disturbed area require a state General Construction permit and Storm Water Pollution Prevention Plan (SWPPP). Building will route the application to various City department or divisions, or better yet, will meet once or twice per month, as necessary, to jointly review project submittals and talk through the issues. Specific conditions relating to storm waterpo- Elution reduction will be placed on the permit that will have to be met prior to permit issuance. Public education materials have'been developed that list actions (tasks) a contractor must take fora specific activity such as, erosion control, concrete work, painting, paving, equipment maintenance, and so forth. The building or public works inspector will briefly review the brochure with. the contractor and check off the tasks that must be done for a particular job. The on -site inspector will then carry the brochure to the site as follow -up - during the on -site inspection. There will be an on -site checklist (card) for the building or public works inspector "to use for the first and any follow -up inspections. Repeat • inspections to ensure storm water BMPs are in place will be necessary. The cards will be used as documentation of site inspections and insurance that the appropriate BMPs are being required. The cards will also be useful for compiling statistics for the annual reports. Many of these services are currently provided'by inspection.staff and each will be reviewed for conformance with Phase II regulations. Engineering eering Services Review by Engineering at both the planning and building permit - review stages will be necessary. Engineering will include appropriate storm water control conditions of approval on the project and on the building permit application. The Engineering Design Standards and; the Grading Ordinance will need to be revised to 'incorporate General Permit (Storm Water) requirements. All ;sites with disturbed areas greater than one acre must prove coverage by and compliance with the State Construction Storm Water General Permit as a. condition of approval aproposed project. Coverage is provided by the submittal of a Notice of Intent. Compliance,is provided_bythe implementation of the requirements of the Notice of.Intent. The City is then required to follow- through with the verification of each site's - implementation of.storm waterrcontrols. Post- construction maintenance of storm water pollution prevention measures must also be written into the development approval . process. As a regulated small MS4 servinga.population over 50,000, the , State's NPDES Phase II General Permit also, requires the City to adopt an ordinance known as a. Standard Urban Storm Water'Mitigation'Plan (SUSMP) by the end of the first five-year permit term. The WSMP is'meant to ensure post - construction pollution controls continue protecting water quality. PERSONNEL. AND RESOURCE NEEDS Our program recommends that. at least 60 % of one Full Time Equivalent (FTE), or 0. 6 FTE, be utilized for the Program Leader to carry out the. organization, coordination, supervision and direction_ of the city's Storm, Water Management Program. Other departments will have to devote -time to implementing their respective responsibilities for the program as well. It is expected the Community Development Department will need 0.3 FTEs to handle the plan review, and 0.1 FTE for post- construction storm water BMPs for all projects within the. City., The Building and Public Works inspectors will require 0.2 FTEs; to review storm water BMP placement in construction plans, and several inspections of sites following rainfall events of:a4esignated magnitude.. The Program Leader will rely on the other department staff members to summarize their activities in order to document compliance for :the program. This is a complex and multifaceted program that impacts almost every department;in the City; however, it is expected the initial implementation of the program activities can be accomplished with existing staff. Administration of the City's Storm Water Management Program will involve oversight..of data entry, data racking, secretarial, 'and other administrative tasks. While the paperwork and record - keeping portion of the Program maybe substantial, we expect to begin the administration of this program with the existing Water Resources and Conservation Department staff. However, as the program progresses, and other, activities are undertaken, it is anticipated additional staff will be required in the Water Resources and • Conservation Department in fiscal year 2003 -04 to assist in administration of the program. The specific personnel and resources needs to implement the proposed BMPs within each of the Program. Areas are outlined in Exhibit A. SCHEDULE OF IMPLEMENTATION Exhibit A includes a five-year schedule for the implementation of the components of the Storm Water Management Program (SWMP): The: schedule for implementation of the BMPs presumes a phased approach to implementation of the SWMP over the first five - year permit term. The first two years will focus on creating the legal and administrative framework for the SWMP. During this time, existing ordinances will be modified to include Phase II storm water'requirements, new ordinances will be created to address missing elements of the SWMP, design standards will be-revised, maintenance procedures will be updated /revised to reflect new practices, and training will occur for municipal staff from various .departments to educate City employees on concepts such as pollution prevention, Following these changes, the remainder of the permit term will primarily focus on implementing BMPs. Throughout the permit term, the Program Leader will coordinate storm water activities within departments, between departments, and amongst the other Phase II communities in Sonoma, County. • 3. ALTERNATIVES The City of Petaluma, operates a municipal separate'storm sewer system and is automatically designated 'by the U.S. Environmental Protection Agency as a regulated small MS4 under the Phase II rule. Accordingly, the City is required to develop a Storm Water Management Program and submit a permit application (either separately or as a co- permittee) to the Regional Water Quality Control Board for operation of our storm water system. Alternatives available for procurement of the permit include: a. Submittal of the City's Storm Water Management Program and application for General Permit Coverage as a. separate. municipality: b. Submittal of the City's Storm Water Management Program and application for General Permit Coverage as a Co- Permittee. C. Take no action. 4. FINANCIAL IrAPACTS Compliance with the, NPDES Phase II Permit requires implementation of the City's Storm Water Management Program and payment of an annual permit fee. Exhibit;A.includes d,detailed estimate of the costs and other resources necessary to implement the ;BMPs within each area of the program. Included are estimates of hard Failure to secure General Permit coverage would result in the issuance of a Notice of Violation by the Regional • Water Quality Control Board. This violation could include fines up to $27,500 per day in accordance with Section 13385 of the Porter - Cologne Water Quality Control Act, and may expose the City, to third -party lawsuits. 0 dollar costs for materials and fees, and personnel resources by Full -Time Equivalents (FTEs), split out by fiscal year. It is important to note the City's estimated annual implementation costs are dependent on °the BMPs ultimately chosen, and the level of implementation the City selects. Also, the cost estimates represent only additional costs, above and beyond what is already budgeted for existing activities, that the City will incur as a result of implementing the recommended BMPs. Thus, the total costs represent the total of the costs necessary to implement the' additional BMPs requiredfor compliance with the PhaseII rule. Table 2 provides a summary of the expected implementation costs for each:Minimum Control Measure, including program administration, for the:next five years. Table, 2 Storm Water Program Area Costs by Fiscal Year Mffiimum.Control c Measure/Progra. m Type of FY FY FY FY FY Cost 63/04 04/05 05/06 06/07 07/08 Area Public Education Labor .17 FTE .22 FTE .21 FTE 16 FTE .16 FTE and Outreach Materials $5,000 $5,000 $5;000 $2,0,00 $2,000 Public Involvement Labor .06 FTE .11 FTE .11 FTE _ 11 FTE .11 FTE & Participation Materials $2,000 $2,000 $2,000 $2,000 $2,000 Illicit.Discharge 'Labor .25 FTE .25 FTE .20 FTE 15 FTE .15 FTE Detection & Elimination . Materials $2 $2;500 $2 $2 ; 500 $2,500 Construction Site Labor 1.2 FTE 1.2 FTE 1.15 FTE 1.15 FTE 1.15 FTE Storm Water Runoff Control Materials $3,000 $3,000 $3,000 $3,000 $3,000 Post= Coiisti-uction Storm Water Labor :09 FTE .24 FTE .24 FTE .24 FTE .19 FTE Management in New' Development Materials $0 $1,000 $3 $3,000 $2;000 & Redevelopment Pollution ion Preventio Labor 1.05 FTE 1.10 FTE L I 0 FTE 1.10 FTE 1.10 FTE Housekeeping for Municipal Materials $10,000 $10,000 $10,000 $10,000 $1.0;000 Operations Fees /Annual Labor .10 FTE .10 FTE .10 FTE .10 FTE . l 0 FTE, Reporting, Monitoring,& Assessment Fees $7,500 $7,500 $7,500 $7,500 $7,500 Storm Water Labor 2.92 FTE 3.22 FTE 3.11 FTE 3.01 FTE 2.96 FTE Management Program Fees $30,000 $39,000 $33,000 $30,000 $29,000 Total = FTE = Full- Time' Equivalent 0 10 The labor requirements. for implementation of this program. will initially be met with existing. city personnel -As the program develops, additional staff will be necessary in the • Water Resources and Conservation Department in fiscal year 2003 -04 to administer the program. CONCLUSION The U.S. EPA promulgated Phase II.regulations for storm water discharges. and designated the State Water Resources Control, Board ( SWRCB) as the statewide permitting authority. The City must prepare a Storm Water Management Program and a National Pollutant Discharge Elimination System (NPDES) Phase H application for coverage under the General Permit in order to continue operating our storm drainage system. Although the City has already implemented a number of policies and procedures to improve water quality, compliance with the SWRCB General Permit constitutes the first citywide, comprehensive program to significantly reduce or eliminate priority pollutants in our surface waters. During the initial phases of the program, the City will identify pollutants of concern, implement best management practices for reducing these pollutants, and begin development of the necessary policies and procedures to formalize these new practices. Since effectively addressing; the issue of surface water pollutants also requires consideration of the watershed as a whole, the City will continue to work with other municipalities and organizations in our region with similar goals and requirements. E. OUTCOMES OR PERFORMANCE MEASUREMENTS THAT WILL.IDENTIFY SUCCESS OR COMPLETION A key component of our Storm Water Management Program includes the • monitoring and evaluation of measurable goals toward improving water quality. As shown in Exhibit A, our program includes quantifiable targets for each of the proposed Best Management Practices, in all six Minimum Control Measure areas. These quantifiable targets are used to establish a baseline against which our progress towards reducing pollutants by implementing each BMP will be measured. Annually, the Program Leader will request every City department responsible for implementing any of the BMPs submit a summary of their- activities for the preceding fiscal year: These summaries will be incorporated into an annual report that will document our accomplishments for the previous year, and set goals and objectives for the new year. The annual report-will be submitted bythe- Department of Water Resources and Conservation to the Regional Water Quality Control Board in September each year for review and comment. The comments received from the Regional Board will be incorporated into the, following year's activities to ensure our program is adjusted, as necessary, to continue improving water quality. Our °first annual report will be due in September 2004 forthe preceding 18 months, March 2003 — June 2004. 7. RECOMMENDATION City Management recommends the City Council consider the presentation. on the Storm Water Management Program, receive public comments, provide direction to City `Management on clarifications, if appropriate, and adopt the resolution approving, the .Storm Water Management Program and authorizing the City Manager to, execute, and submit the Notice of Intent and Storm Water Management Program to the San Francisco Bay Regional Water Quality Control Board for coverage • 11 under the State General Permit for storm water discharge pursuant to the National Pollutant Discharge Elimination System Phase -lI Storm Water Regulations. 0 • 12