Stormwater Permit Renewal Update

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for their thoughts on.the approach. The permittees formed a"monitoring subcommittee" that met on several occasions to discuss monitoring requirements. DEQ met with the monitoring subcommittee in April, 2008 and we were able to coalesce around pesticide monitoring requirements.5 Many permittees are already conducting or will propose monitoring that will meet the requirements of the next permit, but some permittees will need to do additional monitoring to meet the new permit conditions. Anticipafed Permit Language The next permits will include a simplifled table in Schedule B that contains minimum monitoring requirements. This will allow the permittees to adaptively manage their monitoring program through the permit term in order to collect the data necessary to fulfill the six (6) narrative monitoring objectives. Pesticide monitoring within the MS4 system will be required. At minimum, DEQ will require monitoring for 2,4-D (e.g. Weed-n-Feed) and either glyphosate (e.g. Roundup) or diazinon. Pesticide monitoring will be required during the 2nd and 4th year of the permits at a minimum of three locations and two storm events. Language regarding the six narrative monitoring objectives will be retained. Maximum Extent Practicable Determination DEQ anticipates increased scrutiny on the MEP standard employed in the next round of permits. Each Phase I municipality's stormwater management program is unique in how they achieve the MEP standard, perhaps employing different BMPs or emphasizing different program elements (e.g. illicit discharges, construction site runoff, public education, standards for new development). In order to support DEQ's independent determination that a program reduces pollution to the maximum extent practicable, DEQ believes that all municipalities should use a common MEP determination process. DEQ requested that permittees develop a common, consistent process by which they evaluate the effectiveness of program elements and the overall stormwater ~~ management program with respect to the MEP standard. DEQ requested that permittees make °~~- a MEP determination as part of the permit renewal application.s In response to DEQ's request, the permittees developed an "Approach for Demonstrating MEP" template that all of the permittees will follow to achieve consistency:~ The submittals will describe past MEP evaluation/determination efforts, the adaptive management process and will describe how the following evaluation factors were applied to the SWMP submitted with the 2008 permit renewal package: . • Program effectiveness ^ Cocal applicability • Program resources DEQ will evaluate the MEP determination submittals before issuing the next round of permits.. Anficipated Permit Language The permits will require permittees to provide the information and analysis necessary to support DEQ's independent determination that the co-permittee's stormwater management program reduces pollution to the maximum extent practicable. Co-permittees must describe how the management practices, control techniques, and other.provisions contained in the proposed SWMP components were evaluated relative to the MEP standard using the following evaluation factors: 5 Monitoring Subcommittee Meeting Summary 4-I 5-08. 6 ACWA stormwater permit renew.al subcommittee on .11/15/07. Also see 1/11/08 "Renewal Application '}~'' RequesY' letter regazding expectations for the 2008 permit renewal .package. - ~ 4