Hemet City Council
September 10, 2024

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Section 5  Overview of EWMP Control Measures: Green Infrastructure and Institutional BMPs Upper LA River EWMP 5-16 Draft June 2015

5.5.6 Arroyo Seco Urban Runoff Project No. 3
Urban runoff mitigation in this area would contribute to the reduction of bacteria and pollutants in the Arroyo Seco tributary. To achieve compliance with the LA River Bacteria TMDL, the proposed project will install a detention/retention basin on identified parkland in Hermon Dog Park. Stormwater flow would be diverted from an existing storm drain to the newly constructed detention/retention basin for infiltration and subsurface use.

Concept designs for Arroyo Seco Load Reduction Strategy projects are presented in Appendix 5B.

At a Glance:
 Location: Arroyo Seco and Via Mirasol
 Control Measures: Retention/Detention
Basin
 Expected Completion: Winter 2019
 Approx. Cost: $5.12M
Existing condition of Dog Park on Via
Mirasol, oriented north towards Arroyo
Seco (Source: Google Earth)
Proposed project location
(Source: Google Earth)

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Section 5  Overview of EWMP Control Measures: Green Infrastructure and Institutional BMPs Upper LA River EWMP 5-17 Draft June 2015

5.5.7 Arroyo Seco Urban Runoff Project No. 4
Urban runoff mitigation in this area would contribute to the reduction of bacteria and pollutants in the Arroyo Seco tributary. To achieve compliance with the LA River Bacteria TMDL, the proposed project includes the construction of the following treatment control structures: a diversion/
maintenance structure, a trash/sedimentation tank system for the removal of trash, metals, and toxics, connecting pipes, a storage tank, and a control and pump system for subsurface water irrigation and infiltration.

Concept designs for Arroyo Seco Load Reduction Strategy projects are presented in Appendix 5B.

At a Glance:
 Location: Arroyo Seco and South Avenue 60
 Control Measures: Storage Tank,
Subsurface Water Irrigation and Infiltration
 Expected Completion: Winter 2019
 Approx. Cost: $4.8M
Existing condition of South Avenue 60
oriented NW towards Arroyo Seco
(Source: Google Earth) Proposed project location
(Source: Google Earth)
(Google Earth)
A subsurface storage tank and treatment
system being installed (source: Neal
Shapiro, City of Santa Monica)

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Section 5  Overview of EWMP Control Measures: Green Infrastructure and Institutional BMPs Upper LA River EWMP 5-18 Draft June 2015

5.5.8 Arroyo Seco Urban Runoff Project No. 5
Urban runoff mitigation in this area would contribute to the reduction of bacteria and pollutants in the Arroyo Seco tributary. To achieve compliance with the LA River Bacteria TMDL, the proposed project includes the construction of vegetated bioswales along 51st Street, which is located south of Echo Street in the Arroyo Seco subwatershed. Along with three parkway bio-swales, installation of curbside grating basins and planting of native vegetation will also be implemented.

Concept designs for Arroyo Seco Load Reduction Strategy projects are presented in Appendix 5B.

At a Glance:
 Location: South Ave 51 and Echo
 Control Measures: Bioswale, Curbside
Grating
 Expected Completion: Winter 2019
 Approx. Cost: $4.8M
Existing condition of South Avenue 51
oriented NW towards Echo Street
(Source: Google Earth)
Proposed project location
(Source: Google Earth)
Streetside bioswale

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Section 5  Overview of EWMP Control Measures: Green Infrastructure and Institutional BMPs Upper LA River EWMP 5-19 Draft June 2015

5.5.9 Residential Neighborhood “Pilot-to-Scale” Landscape Transformation Project
As discussed in the Residential LID section
above, these programs are ideally suited
for partnerships with key NGOs to support
the program design and implementation.

One of these key NGOs, TreePeople, has
recently completed an exploratory effort to
evaluate the potential for cross-agency
collaboration to promote and incentivize
residential stormwater capture and
treatment projects throughout the Los
Angeles area. In addition to several key
findings on the collaboration itself, a hydrologic analysis was performed to preliminarily approximate the potential range of impact a widely-implemented program might have. The results of the scaling analysis estimate that hypothetical implementation rates between 25% and 50% of all residential properties in the Upper LA Watershed could yield 21,017 to 42,034 acre-feet per year; similarly the Ballona Creek Watershed could yield 3,665 to 7,872 acre-feet per year.

Building upon this analysis and the collaborative work already completed, TreePeople proposes two residential neighborhood landscape transformation areas to capture stormwater in the following Upper LA Watershed candidate neighborhoods: Pacoima, Sylmar, and Sun Valley; and/or in the following Ballona Creek/Dominquez Channel Watershed: Mar Vista, and Culver City. The landscape transformation would implement a small number of residential-scale stormwater capture BMPs (e.g., rain gardens and bioretention basins for infiltration and cisterns and rain tanks for capture and use), entirely on private residential properties. Key elements of the proposed design include the evaluation of active control configurations and detailed BMP performance and operations monitoring.

The purpose of this project is twofold: (1) to further demonstrate and quantify the viability of a residential BMP retrofit program – especially as an alternative or complement to capital projects such as regional BMPs or green streets; and (2) fully explore (in a test environment) the feasibility and potential depth of cross-agency collaboration and cooperation in executing a tangible, in-the-ground, programlevel project. Several elements of the program will be explored, including the costs of implementation, the depth of homeowner engagement, BMP effectiveness, and varied physical configurations. Ultimately, the pilot-to-scale project will retrofit a number of private parcels, evaluate the cost and performance of the systems, and identify any barriers that might limit the extent or effectiveness of scaling up the program. Based on the findings of the study, a
range of potential implementation scenarios will
be summarized to estimate the total potential
impact in terms of program cost, water quality
improvement, and water supply augmentation. A
full account of the collaborative effort will also be
provided and summarized to provide meaningful
feedback and guidance on how to further
improve the management of a mutually
beneficial cross-agency program.

At a Glance:
 Locations: Neighborhoods in the Upper LA
and the Ballona Creek/Dominguez Channel
Watersheds
 Control Measures: Infiltration and capture
practices on private residential properties
 Expected Completion: TBD
 Approx. Cost: TBD

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Section 5  Overview of EWMP Control Measures: Green Infrastructure and Institutional BMPs Upper LA River EWMP 5-20 Draft June 2015

5.6 How are Institutional Control Measures incorporated into the EWMP?
Institutional BMPs are non-constructed control measures that limit the amount of stormwater runoff or pollutants that are transported within the MS4 area. If institutional control measures are effective, they ultimately offset the need for more expensive structural control measures. Most institutional BMPs are implemented to meet requirements for MCMs in the MS4 Permit.

The MS4 Permit categorizes institutional BMPs and MCMs into the following six program categories:
 Development Construction Program
 Industrial/Commercial Facilities Program
 Illicit Connection and Illicit Discharges Detection and Elimination Program  Public Agency Activities Program
 Public Information and Participation Program
 Planning and Land Development Program
Specific institutional BMPs currently implemented by the ULAR EWMP Group members as part of these stormwater program categories are reported in the Los Angeles County MS4 Permit Unified Annual Report 16.

The MCMs that were implemented as part of the 2001 Permit are assumed to be a component of the “baseline” condition for the EWMP and RAA. The 2012 Permit includes an extensive list of additional MCMs that are required to be implemented by the MS4s, which are assumed by the RAA to provide a 5% reduction in pollutants. A summary of these changes in Permit requirements is provided in Appendix 5.A., and key items are noted below:

Table 5-2. Permit Requirements
MCM ADDITIONAL REQUIREMENT IN 2012 PERMIT vs 2001 PERMIT Progressive Enforcement Develop and maintain a Progressive Enforcement Policy to track compliance, including:
1) follow-up inspection, 2) enforcement action, 3) records retention, 4) referral of violations, 5) investigation of complaints, 6) assistance with Regional Board enforcement actions
Public Information and
Participation Program (PIPP)
More robust public participation program that measurably increases knowledge and changes behavior, and involves a diversity of socio-economic and ethnic communities Industrial/Commercial
Facilities Program
Added education component to notify of BMP requirements applicable to the site Expanded inspection to all commercial and industrial facilities that may contribute substantial pollutants
Planning and Land
Development Program
Updated ordinance/design standards to conform with new requirements (LID and hydromodification)
Increased performance measure to require onsite retention or bioretention/biofiltration

16 Los Angeles County provides access to Permittee Annual Reports at the following website:
http://ladpw.org/wmd/NPDESRSA/AnnualReport/

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Section 5  Overview of EWMP Control Measures: Green Infrastructure and Institutional BMPs Upper LA River EWMP 5-21 Draft June 2015
Table 5-2. Permit Requirements
MCM ADDITIONAL REQUIREMENT IN 2012 PERMIT vs 2001 PERMIT Provision for alternative compliance measures due to technical infeasibility of onsite retention, or opportunity for groundwater replenishment at offsite location Planning and Land
Development Program
Updated ordinance/design standards to conform with new requirements (LID and Development Construction
Program
For sites disturbing less than an acre, added requirement to inspect construction sites based upon water quality threat
The use of BMPs are tailored to the risks posed by the project, ranked from Low Risk (Risk 1) to High Risk (Risk 3)
Increased frequency of inspections, at least once every 2 weeks for high threat sites, at least monthly for lower threat sites, and during all phases of construction (at least three times)
Public Agency Activities
Program
Added requirement to maintain an updated inventory of all public facilities that are potential sources of stormwater pollution and inventory of existing development for retrofitting opportunities.

Illicit Connections and Illicit
Discharges Elimination
Program
Required to implement a spill response plan for all sewage and other spills that may discharge into its MS4
In addition, four of the ULAR jurisdictions have elected to implement additional institutional control measures to achieve a total 10% reduction. The jurisdictions and their planned additional institutional control measures are detailed in the EWMP Implementation Strategy section (7.5). Over time, it is anticipated that additional ULAR jurisdictions will implement enhanced institutional control measures and offset the need for structural control measures.

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Section 5  Overview of EWMP Control Measures: Green Infrastructure and Institutional BMPs Upper LA River EWMP 5-22 Draft June 2015

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Upper LA River EWMP 6-1 Draft June 2015
Section 6
Reasonable Assurance Analysis (RAA)
A key element of the EWMP is the RAA, which is prescribed by the Permit as a process to demonstrate “that the activities and control measures…will achieve applicable WQBELs and/or RWLs with compliance deadlines during the Permit term” (Permit section C.5.b.iv.(5), page 63). In 2014, the Regional Board issued RAA Guidelines (Regional Board, 2014), which outline expectations for developing RAAs, and those guidelines were followed closely during development of this RAA. While the Permit prescribes the RAA as a quantitative demonstration that control measures will be effective, the RAA also promotes a modeling process to support the EWMP Group with selection of control measures.

In particular, the RAA was used to evaluate the many different scenarios/combinations of institutional, distributed and regional control measures (described in Section 4) that could potentially be used to comply with the RWLs and WQBELs of the Permit, and was then used to select the control measures specified in the EWMP Implementation Strategy (described in Section 7).

This section describes key elements of the RAA including the following:
 Modeling system used for the RAA (6.1)
 Baseline critical conditions and required pollutant reductions (6.2) - Baseline model calibration (6.2.1)
- Water quality targets (6.2.2)
- Critical conditions for wet weather and dry weather (6.2.3) - Selection of limiting pollutants (6.2.4)
- Required interim and final pollutant reduction (6.2.5)  Representation of control measures in RAA (6.3)
 Approach for selecting control measures for the EWMP Implementation Strategy (6.4) As referenced throughout this section, many details of the RAA are provided in the RAA Appendix which is attached as Appendix 6 (including several sub-appendices 6.A thru 6.H).

6.1 Modeling System
The Watershed Management Modeling System (WMMS) is the modeling system used to conduct the RAA for the ULAR EWMP. WMMS is specified in the Permit as an approved tool to conduct the RAA. The LACFCD, through a joint effort with USEPA, developed WMMS specifically to support informed decisions for managing stormwater. The WMMS is a comprehensive watershed model of the entire Los Angeles County area that includes the unique hydrology and hydraulics features and characterizes water quality loading, fate, and transport for all of the key TMDL constituents (Tetra Tech 2010a, 2010b). The ultimate goal of WMMS is to identify cost-effective water quality improvement projects through an integrated,

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Section 6  Reasonable Assurance Analysis (RAA)
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watershed-based approach. A version of WMMS17 is available for public download from Los Angeles County Department of Public Works website (http://dpw.lacounty.gov/wmd/wmms/res.aspx).

The WMMS domain encompasses Los Angeles County’s coastal watersheds of approximately 3,100 square miles, representing 2,566 subwatersheds. Of those, the ULAR EWMP area encompasses 1,129 subwatersheds18 (Figure 6-1).

The WMMS is a suite of three modeling tools to support BMP planning:

1. A watershed model for prediction of baseline hydrology and pollutant loading (Loading Simulation Program – C+ [LSPC]);

2. A model for simulating the performance of control measures in terms of flow, concentration and load reduction (System for Urban Stormwater Treatment Analysis and Integration [SUSTAIN]); and

3. A tool for running millions of potential scenarios and optimizing/selecting control measures based on cost-effectiveness (also within SUSTAIN).

The LSPC and SUSTAIN models within WMMS are described in more detail in the following subsections.

6.1.1 LSPC
The watershed model included within WMMS is the LSPC (Tetra Tech and USEPA 2002; USEPA 2003; Shen et al. 2004). LSPC is a watershed modeling system for simulating watershed hydrology, erosion, and water quality processes, as well as in-stream transport processes. LSPC also integrates GIS, comprehensive data storage and management capabilities, and data analysis/post-processing system into a convenient Windows-based environment. The algorithms of LSPC are identical to a subset of those in the Hydrologic Simulation Program–FORTRAN model with selected additions, such as algorithms to dynamically address land use change over time. USEPA’s Office of Research and Development (Athens, Georgia) first made LSPC available as a component of USEPA’s National TMDL Toolbox (http://www.epa.gov/athens/wwqtsc/index.html). LSPC has been further enhanced with expanded capabilities since its original public release.

17 The version of WMMS used for this RAA was enhanced from the version available for download. Enhancements include updates to calibration parameters according to the RAA Guidelines (Regional Board, 2014), more refined BMP routing assumptions, and application of an updated two-tier, jurisdiction-based BMP optimization approach. 18 The subwatersheds in WMMS were further segregated into the subwatersheds within each jurisdiction (“jurisheds”) to allow for development of jurisdiction-specific implementation strategies. The 1,129 subwatersheds in ULAR EWMP area are after jurisdictional segregation of 783 subwatersheds in WMMS.

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Section 6  Reasonable Assurance Analysis (RAA)
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Figure 6-1. ULAR EWMP Area and 1,129 Subwatersheds Represented by WMMS.

6.1.2 SUSTAIN
SUSTAIN was developed by the USEPA to support practitioners in developing cost-effective management plans for municipal stormwater programs and evaluating and selecting BMPs to achieve water quality goals (USEPA, 2009; http://www2.epa.gov/water-research/system-urban-stormwatertreatment-and-analysis-integration-sustain). SUSTAIN was specifically developed as a decision-support system for selection and placement of BMPs at strategic locations in urban watersheds (see Figure 6-2).

It includes a process-based continuous simulation BMP module for representing flow and pollutant transport routing through various types of structural BMPs. This simulation provides the primary application of SUSTAIN – simulating the performance of selected stormwater control measures.

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Section 6  Reasonable Assurance Analysis (RAA)
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The secondary application of SUSTAIN is BMP selection, which is based on cost-benefit of different BMP alternatives. The SUSTAIN model in WMMS includes a cost database19 comprised of typical BMP cost data from a number of published sources including BMPs constructed and maintained in Los Angeles County (Tetra Tech 2010a, 2010b). SUSTAIN considers certain BMP properties as “decision variables,” meaning they are allowed to vary within a given range during model simulation to support BMP selection and placement optimization. As BMP sizes and locations change, so do cost and performance.

SUSTAIN runs iteratively to generate a cost-effectiveness curve comprised of millions of BMP scenarios (e.g., the model was used for the EWMP to evaluate the different combinations of green infrastructure as compared to regional BMPs, and provides a recommendation on the most cost-effective scenario)20.

Figure 6-2. SUSTAIN Model Interface Illustrating BMP Opportunities in Watershed Settings.

6.2 Baseline Critical Conditions and Required Pollutant Reductions

6.2.1 Assessment areas
This section describes the application of the LSPC model to simulate current conditions, identify critical conditions and calculate required pollutant reductions. The calculated required pollutant reductions drive the extent of the control measures to be implemented by the EWMP under the EWMP Implementation Strategy.

6.2.2 Calibration
A fundamental element of the RAA is simulating baseline / existing conditions in the watershed prior to implementation of control measures. For the ULAR RAA, baseline conditions were simulated using the LSPC watershed model in WMMS, including predictions of flow rate and pollutant concentrations over a 10-year period, as follows:

19 The BMP cost database from WMMS was updated for this EWMP, as described in Section 6.6. 20 For the EWMP, optimization was conducted at the jurisdictional-level using SUSTAIN as opposed to the watershed-level using the Nonlinearity-Interval Mapping Scheme (NIMS) component of WMMS.

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Section 6  Reasonable Assurance Analysis (RAA)
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 The simulation period is October 1, 2001 to September 20, 201121.  Simulated pollutants include total suspended solids, E. coli, total copper, total zinc, total lead, total nitrogen and total phosphorous.
 Discharges from publicly owned treatment works are represented including Tillman, Glendale and Burbank Water Reclamation Plants.
 An hourly time step was used to simulate the flow rate and pollutant concentration at each of the 1,129 subwatershed outlets (see Figure 6-1) and the resultant downstream receiving water conditions.

To encourage accurate representation of existing/baseline conditions, the RAA Guidelines provide “model calibration criteria” for demonstrating the baseline predictions are accurate and to ensure the “calibrated model properly assesses all the variables and conditions in a watershed system” (Regional Board, 2014). Detailed hydrology and water quality calibrations were performed for the ULAR RAA, as follows (see Figure 6-3 for a map of water quality and hydrology calibration stations):
 Water quality calibration: the water quality calibration process for the ULAR RAA leveraged two primary monitoring datasets: (1) small-scale, land use-specific water quality monitoring data collected by the Southern California Coastal Water Research Program (LACDPW, 2010b) and (2) large-scale receiving water monitoring data collected by the Coordinated Monitoring Program for the Los Angeles River Metals TMDL and mass emission monitoring by Los Angeles County Department of Public Works (LACDPW) at stations in LA River including Wardlow Road (S10).  Hydrology calibration: nine LACDPW streamflow gages, three on the LA River mainstem and six on tributaries, were used for the hydrology calibration. Several additional gages were referenced along Rio Hondo to balance calibration of undeveloped headwaters, spreading grounds and flow diversions.

The comparison of the calibrated hydrology model to the RAA Guidelines is shown in Table 6-1, and the water quality calibration is shown in Table 6-2. The baseline (LSPC) model performs quite well for representing existing hydrologic and water quality conditions. For each hydrology station, at least one of the following calibration metrics achieved an assessment of “Fair” or better: Total Annual Volume, Highest 10% of Flows or Annual Storm Volume. Details of the baseline model development and calibration are presented in Appendix 6.A.

21 All stormwater control measures implemented prior to September 30, 2011 are assumed to be implicitly represented within the baseline conditions.

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Section 6  Reasonable Assurance Analysis (RAA)
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Table 6-1. Summary of Hydrology Calibration Performance by Baseline Model Location Model Period Hydrology Parameter Modeled vs.

Observed
RAA Guidelines
Performance
Assessment
Los Angeles River
at Wardlow Avenue
10/1/2002 –
9/30/2011
Total Annual Volume 22.9% Fair
Highest 10% of Flows 3.1% Very Good
Annual Storm Volume 22.7% Fair
Los Angeles River
at Tujunga Wash
10/1/2002 –
9/30/2011
Total Annual Volume 10.9% Good
Highest 10% of Flows -10.1% Good
Annual Storm Volume 7.3% Very Good
Los Angeles River
at Arroyo Seco
10/1/2002 –
9/30/2011 Highest 10% of Flows 8.3% Very Good
Santa Anita Wash
at Longdem Avenue
10/1/2002 –
9/30/2011
Total Annual Volume 12.7% Good
Highest 10% of Flows -21.1% Fair
Annual Storm Volume -6.9% Very Good
Arcadia Wash
Below Grand Avenue
10/1/2002 –
9/30/2011
Total Annual Volume 4.3% Very Good
Annual Storm Volume -7.4% Very Good
Eaton Wash
Below Grand Avenue
10/1/2002 –
9/30/2011
Total Annual Volume -7.0% Very Good
Annual Storm Volume -4.5% Very Good
Verdugo Wash at
Estelle Avenue
10/1/2002 –
9/30/2011
Total Annual Volume -2.0% Very Good
Highest 10% of Flows -8.0% Very Good
Burbank Western
Channel at Riverside Drive
10/1/2002 –
9/30/2011
Total Annual Volume -11.2% Good
Annual Storm Volume 10.7% Very Good
Compton Creek
Near Spring Street
10/1/2002 –
9/30/2011 Highest 10% of Flows 20.4% Fair
Note: for each station, at least one of the following calibration metrics achieved an assessment of “Fair” or better: Total Annual Volume, Highest 10% of Flows or Annual Storm Volume.

Table 6-2. Summary of Water Quality Calibration Performance by Baseline Model Water Quality
Parameter Sample Count
Modeled vs.

Observed Load
(% Error)
RAA Guidelines
Performance Assessment
Total Sediment 80 8.6% Very Good
Total Copper 54 -20.1% Good
Total Zinc 54 -27.7% Fair
Total Lead 49 -32.5% Fair
E. coli * 49 -32.1% Fair
Total Phosphorous 49 -13.1% Very Good
* E. coli was assumed to have a 1:1 translator with fecal coliform.

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Section 6  Reasonable Assurance Analysis (RAA)
Upper LA River EWMP 6-7 Draft June 2015
Figure 6-3. Hydrology and Water Quality Calibration Stations for ULAR RAA.

6.2.3 Non-stormwater (dry weather) simulations
Two components of the ULAR EWMP provide assurance that non-stormwater discharges will be addressed:

1. The Load Reduction Strategy (LRS) process of the LA River Bacteria TMDL is incorporated into the EWMP. Following the LRS process provides assurance that bacteria WQBELs/RWLs will be achieved by the EWMP. Because E. coli is a limiting pollutant (as described in Section 6.5.3), the LRS also addresses other dry weather Water Quality Priorities.

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Section 6  Reasonable Assurance Analysis (RAA)
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2. The wet weather control measures in the ULAR EWMP will provide significant reductions in nonstormwater. A separate RAA was performed for dry weather conditions to demonstrate that EWMP control measures will address non-stormwater discharges that are effectively prohibited.

The subsections below describe these two components of the dry weather RAA.

6.2.3.1 Load Reduction Strategy Approach
The LRS process identified in the LA River Bacteria TMDL is based on Monte Carlo modeling that simulates that loading of E. coli from outfalls along each segment or tributary of the LA River. The schedule for the LRS process is phased, with Segment B of the LA River being addressed first and Segment C being addressed last. For each segment, the Monte Carlo model is driven by outfall monitoring data, consisting of at least six “snapshot” monitoring events where every outfall observed to be flowing is subject to flow rate and E. coli concentration monitoring. The Monte Carlo model is used to compare the current E. coli loading to the TMDL wasteload allocation, consider alternatives for control measures that would achieve the wasteload allocation, and select an implementation strategy. Shown in Figure 6-4 is an example Monte Carlo output for a selected LRS. The details of the LRS process including the required Monte Carlo modeling can be found in Appendix 1 of Section 8 of the CREST Bacteria TMDL Technical Report – Dry Weather Implementation Plan.

Figure 6-4. Example Monte Carlo Model Output for a Bacteria TMDL Load Reduction Strategy This example Monte Carlo model output is for the City of Los Angeles jurisdiction in Arroyo Seco. The LRS by the City of LA is based on addressing E. coli loading from three “Priority Outfalls” AS-15, AS-21 and AS-17. By addressing these three outfalls, the LRS has reasonable assurance of achieving the TMDL wasteload allocations (dotted lines). The EWMP Implementation Strategy in Section 7 presents the LRS control measures for Segment B and Arroyo Seco.

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Section 6  Reasonable Assurance Analysis (RAA)
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6.2.3.2 Effect of Wet Weather Control Measures on Non-stormwater To demonstrate that non-stormwater is addressed by the ULAR EWMP, a non-stormwater model was developed. A detailed description of the non-stormwater simulation is provided in Appendix 6.B.

The MS4 Permit effectively prohibits discharges of non-stormwater22 and states that EWMPs shall “ensure that discharges…do not include non-stormwater discharges that are effectively prohibited.” In addition, the MS4 Permit includes dry weather WQBELs for LA River Metals and Bacteria TMDLs. A baseline non-stormwater model was developed for the ULAR EWMP based on the following components:
 Simulation of non-stormwater sources that generate dry weather runoff: the primary source of non-stormwater is outdoor water use. As such, the dry weather RAA is based on a simulation of non-stormwater whose source is outdoor water use23 in each of the subwatersheds within the EWMP area and whose sink is evapotranspiration and retention by wet weather EWMP control measures.
 Non-stormwater generated by outdoor water use based on extensive literature review: the amount of non-stormwater generated in each ULAR subwatershed was estimated as the product of [1] the estimated population based on U.S. census blocks and [2] the estimated per capita outdoor water use based on compilation of 25 estimates relevant to southern California (see Figure 6-5). The use of median historical outdoor water use is likely conservatively high, as outdoor water use has likely fallen substantially during the recent drought periods.  Thirty (30) day simulation of critical dry period: the period of the simulation was a critical dry period identified in the average water year (August 21, 2007 to September 20, 2007). This portion of the year (late August to September) historically receives the least amount of rainfall. The evapotranspiration during this period provides the weather boundary condition for the nonstormwater simulation.

While the critical conditions for dry and wet weather are uniquely defined, it is important that dry and wet weather conditions not be evaluated in separate silos – the EWMP includes a large network of wet weather BMPs that will eliminate a majority of non-stormwater discharges. The dry weather RAA quantifies the reduction of wet weather BMPs on non-stormwater discharges, and assures that TMDL milestones are attained on the required implementation timeline. The EWMP Implementation Strategy for non-stormwater is presented in Section 7.5.

22 Non-stormwater does not include all dry weather runoff. For example, permitted dry weather discharges (e.g., dewatering) and groundwater baseflow are exempted/allowed by the Permit. 23 By focusing on the non-stormwater portion of dry weather runoff, the non-stormwater analysis and dry weather RAA are focused on the portion of dry weather runoff that is required to be controlled by MS4s. Non-stormwater volumes are not necessarily equal to dry weather runoff volumes in the EWMP area. Non-stormwater is the portion of dry weather runoff that is effectively prohibited by the Permit. Dry weather runoff would also include groundwater that is discharged through the MS4 system (if any), which is allowed by the Permit.

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Section 6  Reasonable Assurance Analysis (RAA)
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Figure 6-5. Outdoor Water Use Estimates from Literature Review

6.2.4 Water Quality Targets
The RAA is designed to achieve the RWLs and WQBELs of the MS4 Permit, which are derived from applicable TMDLs (see Attachment M of the Permit) and the Basin Plan (see Receiving Water Limitations, Section V of the Permit). In particular, the RAA addresses the Water Quality Priorities identified in Section 2. The RWLs and WQBELs serve as the “water quality targets”, or loads or concentrations to be achieved through implementation of the control measures specified by the EWMP.

Not all pollutants are directly modeled; the pollutants that are the most problematic and generally require the most stormwater treatment are directly modeled – total solids, zinc, copper, lead, nitrogen, phosphorous, and E. coli. The targets for modeled pollutants are listed in Table 6-3, organized by pollutant class. For the remaining (non-modeled) Water Quality Priorities, the RAA uses analyses of monitoring data to demonstrate that control of one or more “limiting pollutants” will address the nonmodeled pollutants (as discussed in the next subsection).

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Section 6  Reasonable Assurance Analysis (RAA)
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Table 6-3. Targets for Modeled Water Quality Priority Pollutants Pollutant
Class Pollutant
Target for RAA
(units are g/L except when noted otherwise) Assessment Area where Target was Evaluated
Dry Weather Source Wet
Weather Source
Metals Zinc, Copper, Lead
See Part
C.2.b of
Attachment
O of Permit
Permit /
Metals
TMDL
See Part
C.2.d of
Attachment
O of Permit
Permit /
Metals
TMDL
All Assessment Areas
Bacteria E. coli
Final WLA
determined
by Load
Reduction
Strategy
Bacteria
TMDL
235 MPN per
100 mL 1
Bacteria
TMDL All Assessment Areas
Organics
and Legacy
Pollutants
Total DDTs 0.057 grams per year 2,3 Harbor
Toxics
TMDL
Average Annual Loading from EWMP Area
(assessed at most downstream end of LA
River below Sepulveda Basin)
Total PCBs 0.185 grams per year 2,3
Total PAHs 1.32 kilograms per year 2,3
Total PCBs 0.17 ng/L2
Echo Park
Lake TMDL
Subwatersheds that drain
Chlordane 0.59 ng/L to Echo Park Lake 2
Nutrients
Total Nitrogen Average annual loading specified in Section G of Attachment O of Permit
LA Area
Lakes
TMDL
Subwatersheds that drain to Echo Park,
Calabasas and Legg Lakes. Total Phosphorous
1 – Per the Bacteria TMDL, the target incorporates 10 Allowable Exceedance Days in waterbodies subject to the High Flow Suspension (HFS) and 15 Allowable Exceedance Days in waterbodies not subject to HFS. All assessment areas except Compton Creek and Arroyo Seco are subject to the HFS. 2 – The loading of these pollutants was modeled by simulating TSS loading and estimating baseline stormborne sediment concentrations. Baseline stormborne sediment concentrations were estimated based on summary statistics from stormborne sediment collected in Ballona Creek watershed, as reported in appendix of Ballona Creek EWMP Work Plan. For chlordane, the assumed baseline concentration is 0.026 ug/g based on the average concentration of stormborne sediments collected in Ballona Creek. For DDTs, the assumed baseline concentration is 0.036 ug/g based on the average concentration reported. For PCBs, the assumed baseline concentration is 0.017 ug/g based on the maximum concentration reported (there were too few detections to report an average). For PAHs, the assumed concentration is 0.153 ug/g based on the maximum concentration reported (there were too few detections to report an average). No data were available for dieldrin. 3 – The MS4 WLA for Los Angeles River for LA County et al. was multiplied by 57.77% to represent the portion of the LAR watershed that is the ULAR EWMP area.

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Section 6  Reasonable Assurance Analysis (RAA)
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6.2.5 Critical Conditions and Required Reductions
This following subsections describe the critical conditions for wet weather (stormwater) and dry weather (non-stormwater).

6.2.5.1 Wet Weather Critical Conditions
A key consideration of the RAA is the “critical condition” under which water quality targets must be achieved. Stormwater management for different size storms generally requires different size BMPs. For example, for most pollutants management of a 90th percentile storm requires larger BMPs than management of a median (50th percentile) storm. The RAA Guidelines specify the RAA for final compliance should be based on critical conditions, for example, the 90th percentile flow rates and/or the critical conditions specified by applicable TMDLs (Regional Board, 2014). For the ULAR RAA, three primary wet weather critical conditions were considered as follows:

1. 90th percentile metals Exceedance Volume: the LA River Metals TMDL uses the 90th percentile daily flow rate to define the wet weather condition. In turn, the ULAR RAA analyzes the volume of runoff during each rolling 24-hour period24 of the 10-year simulation when water quality targets were exceeded, referred to as the “Exceedance Volume” (see Figure 6-6). The storm that produces the 90th percentile Exceedance Volume25 is the critical condition for metals and the overall primary critical condition for management26 of stormwater by ULAR EWMP. The Exceedance Volume differs for each metal (zinc, copper and lead) and for different subwatersheds (end-of-pipe) and assessment areas (instream) depending on land use, imperviousness, slope, etc. Shown in Table 6-4 are the summary statistics for zinc Exceedance Volumes in ULAR. The table shows the 90th percentile volume is indeed a critical condition, with volumes being up to ~10 times larger than the median volumes. The EWMP manages (retains and treats) the Exceedance Volume from each of the 1,129 subwatersheds in the ULAR area to achieve metals RWLs.

2. Critical bacteria storm: for addressing E. coli impairments, the “critical bacteria storm” is the 90th percentile wet day when bacteria RWLs apply. According to the LA River Watershed Bacteria TMDL, bacteria RWLs do not apply during days subject to the High Flow Suspension (HFS) or on Allowable Exceedance Days. The bacteria TMDL allocates 15 Allowable Exceedance Days per year in waterbodies that are not subject to the High Flow Suspension

24 A duration of 24-hours was selected for several reasons. First, the LA River Metals TMDL uses a daily flow rate as the critical condition and thus 24-hours is an analogous duration. Second, the 24-hour duration allows the Exceedance Volume to be directly compared to the runoff volume from the 85th percentile, 24-hour storm. Finally, stormwater control measures are generally sized to manage an individual storm – and thus the 24-hour Exceedance Volume is much more relevant to BMP sizing than an annual runoff volume. 25 The Exceedance Volume is an appropriate metric for RAA critical conditions because the volume of stormwater to be managed ultimately drives the capacity of control measures in the EWMP. The Exceedance Volume allows the volume to be defined based on applicable RWLs and assures attainment of RWLs. For example, a storm that generates a large volume of stormwater runoff with pollutant concentrations slightly above the RWLs is more difficult to manage than a storm that generates a small volume of runoff with concentrations that greatly exceeds the RWLs. Also, the Exceedance Volume reflects the effect of varying water quality targets / RWLs – if a target / RWL is increased then the volume of stormwater to be managed is decreased. 26 The term “manage” incorporates both retention and treatment approaches. Retention of the Exceedance Volume assures attainment of RWLs. Treatment of the Exceedance Volumes to concentrations below the RWLs also assures RWL attainment. Furthermore, institutional control measures reduce pollutant build-up on watershed surfaces and thus can also decrease the Exceedance Volume.

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Section 6  Reasonable Assurance Analysis (RAA)
Upper LA River EWMP 6-13 Draft June 2015
(HFS) and 10 per year in waterbodies that are subject to the HFS. To identify the critical bacteria storm, within each water year between 2002 and 2012, the 11th- or 16th- wettest day was determined (the first day that RWLs apply) in each waterbody/assessment area. For the 10-year simulation, there are 10 of those days (one per year) for each waterbody and the 2nd wettest is the critical bacteria storm (the 2nd highest of 10 values is the 90th percentile). The simulated critical bacteria storm is a 24-hour storm. The EWMP retains27 the runoff from the critical bacteria storm (from each subwatershed outlet, prior to discharge to receiving waters) to achieve E. coli WQBELs.

3. Annual average toxics loading: the Los Angeles River Harbor and USEPA Urban Lakes TMDLs (toxics/legacy pollutants) use annual average loading as the critical condition. For the RAA, the average year was defined as the 2007-08 Water Year. The pollutant loading that occurs over the course of 2007-08 is considered the average annual pollutant loading for the RAA. The EWMP manages (retains and treats) the annual runoff from in the ULAR EWMP area to achieve WQBELs for toxics/legacy pollutants. Some sources of toxics, however, are not due to runoff (e.g., contaminated sediments) and thus EWMP Implementation Strategy includes a defined schedule to address “residual” toxics sources after runoff is managed.

Figure 6-6. Illustration of How Metals Exceedance Volume is Calculated for Critical Condition Determination

27 Addressing bacteria though retention of the critical bacteria storm has several benefits for the RAA. First, the RAA for bacteria is essentially based on hydrology rather than prediction of bacteria concentrations / loads which can be challenging given the variability of bacteria concentrations in the environment and multitude of potential bacteria sources. By emphasizing retention prior to discharge to receiving waters, the RAA acknowledges that few stormwater control measures are able to reliably treat bacteria to concentrations below applicable RWLs. In essence, the entire volume of runoff from the critical bacteria storm is assumed to be an Exceedance Volume. Note the depth of rainfall that generates the critical bacteria storm varies by subwatershed based on historic rainfall at rain gages in the EWMP area (e.g., generally larger storms at higher elevations and smaller storms at lower elevations).

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Section 6  Reasonable Assurance Analysis (RAA)
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Table 6-4. Zinc Exceedance Volume Summary Statistics for Upper Los Angeles River (acre-feet) Condition and
Pollutant
Addressed
RAA Assessment Area
Compton
Creek
Rio
Hondo
Los
Angeles
River
Reach 2
Arroyo
Seco
Verdugo
Wash
Burbank
Western
Channel
Tujunga
Wash
Bull
Creek
Los
Angeles
River
Reach 6
Aliso
Wash
Browns
Canyon
Wash
McCoyDry
Canyon
Creek
Bell
Creek
Number of rolling,
24-hour periods with
an EV in 10-year
simulation (out of a
total of 87,660
periods)
7,254 6,217 4,172 2,943 5,363 5,408 2,289 6,075 5,532 6,325 4,344 5,245 4,752 Average EV 192 533 1,808 100 82 68 360 68 310 53 40 32 34 10th percentile EV 10 119 320 18 12 9 63 11 37 4 7 4 2
25th percentile EV 20 179 806 40 22 18 168 19 70 9 11 8 5 Median EV 64 320 1,310 85 43 36 301 42 169 23 22 19 16
75th percentile EV 229 675 2,279 146 97 82 471 86 408 74 47 43 42 90th percentile EV 626 1,215 3,925 197 177 176 747 167 784 136 85 81 70 Note: The storm that generates the 90th percentile zinc EV is the critical condition for final metals compliance. The storm that generates the average zinc EV is the interim condition for metals.

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Section 6  Reasonable Assurance Analysis (RAA)
Upper LA River EWMP 6-15 Draft June 2015

6.2.5.2 Dry Weather Critical Conditions
For demonstration of the effect of wet weather control measures on non-stormwater, the dry weather critical condition was based on two factors (see Section 6.2.3): [1] median outdoor water use, which is conservatively high considering recent water conservation efforts due to drought conditions and [2] a critical dry period identified in late August to September. The LRS analyses are based on the dry weather critical conditions of the LA River Bacteria TMDL.

6.2.6 Limiting Pollutant Analysis
The RAA Guidelines allow the EWMP to be developed with consideration of a “limiting pollutant”, or the pollutant that drives BMP capacity (i.e., control measures that address the limiting pollutant will also address other pollutants). The detailed limiting pollutant selection and justification for each WQP pollutant is provided in Table 6-5. The limiting pollutants are as follows:
 Wet weather – zinc and E. coli: according to the Exceedance Volume analysis and review of monitoring data, control of zinc and E. coli requires BMP capacities that are the largest among the WQP pollutants, and thus control of zinc and E. coli has assurance of addressing the other ULAR wet weather Water Quality Priorities. The RAA for the ULAR EWMP first identifies the control measures to attain zinc RWLs (during the zinc critical condition) and then identifies additional capacity, if any, needed to achieve bacteria WQBELs (through retention of the critical bacteria storm) as shown in Figure 6-7.
 Dry weather – E. coli: among all the pollutants monitored during dry weather at mass emission stations in LA County, E. coli most frequently exceeds RWLs. During monitoring “snapshots” of over 100 outfalls along the LA River, over 85% of samples exceeded WQBELs for E. coli during dry weather (CREST, 2008). As presented in Appendix 2.A, of all the constituents analyzed in Reach 2 of the LA River, E. coli has the highest dry weather exceedance rate with 95% of samples (568 of 591) exceeding. The average concentration of 2,670 MPN per 100 milliliters is approximately 20 times higher than the RWL. This same relative comparison of E. coli to other pollutants is reflected in the other reaches of the LA River and tributaries. Among the dry weather WQP pollutants, achievement of dry weather RWLs for E. coli will be the most challenging.

As shown in Figure 6-7, the RAA sequentially addresses the limiting pollutants in stormwater (wet weather RAA) and non-stormwater (dry weather RAA) based on the limiting pollutant analysis.

It is important to distinguish between reasonable assurance and required implementation actions when considering limiting pollutants. While control of zinc and E. coli has reasonable assurance of addressing other Water Quality Priorities, it is not necessary to fully control zinc and E. coli to address the other Water Quality Priorities. For example, as shown in Table 6-5, exceedances of metals during dry weather are rare and thus existing MCMs and control measures have reasonable assurance of attaining metals RWLs during dry weather. Similarly, for Category 2 and 3 WBPCs, which also have very low exceedance frequencies, the MCMs and associated control measures have reasonable assurance of attaining RWLs.

As such, if exceedances of metals during dry weather or exceedances of Category 2 or 3 WBPCs identified in Table 3-7 occur during EWMP implementation, then compliance determination should not be based on the status of implementation of zinc and E. coli control measures. Instead, compliance determination should be based on evaluation of whether the existing level of implementation for MCMs and control measures (as of June 2015) has been maintained and adapted, as necessary, to meet interim and final limitations. As important, compliance should be determined separately for each constituent and condition (wet or dry).

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Section 6  Reasonable Assurance Analysis (RAA)
Upper LA River EWMP 6-16 Draft June 2015
Figure 6-7. RAA Process for Establishing Critical Conditions and Addressing Water Quality Priorities

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Section 6  Reasonable Assurance Analysis (RAA)
Upper LA River EWMP 6-17 Draft June 2015
Table 6-5. Limiting Pollutant Selection and Justification for RAA Pollutant
Class Pollutant
RAA approach to Addressing Pollutant
Wet Weather
RWLs:

Addressed by
Justification for control approach
Dry
Weather
RWLs:

Addressed by
Justification for control approach
Bacteria E. coli E. coli controls E. coli is one of two wet weather limiting pollutants. E. coli controls E. coli is the dry weather limiting pollutant.

Metals
Copper
Zinc controls
A large portion of copper loading is being
phased out through brake pad replacement
(AB346). The reduction will cause zinc to
become limiting the limiting metal.

Existing
MCMs and
BMPs
Exceedances of metals during dry weather are
relatively rare. Existing MCMs and BMPs, including
the additional MCMs incorporated under the 2012
Permit, have reasonable assurance of addressing
dry weather metals exceedances (because they
currently rarely occur).

Zinc Zinc is one of two wet weather limiting
pollutants.

The volumes of stormwater to be managed for
zinc control are greater than volumes for
control of these other metals.

Lead
Cadmium
Thallium
Mercury
Organics and
Legacy
Pollutants
Total DDTs
Annual load reduction will be achieved through zinc controls (and residual source controls, if necessary)
The volumes of stormwater to be managed for zinc
control are greater than volumes for control of
these organic / legacy pollutants.

Total PCBs
Total PAHs
Chlordane
Dieldrin
Dioxin
Diazinon
Nutrients
Total
Phosphorous Annual load reduction will be achieved through zinc controls (and residual source controls, if necessary)
The volumes of stormwater to be managed for zinc
control are greater than volumes for control of
these nutrients. Total Nitrogen
All Pollutants in Table 3-7
Exceedances of the RWLs for these pollutants are rare, insufficient to meet 303(d) listing criteria. Existing MCMs and BMPs have reasonable assurance of addressing exceedances (because they currently rarely occur).

All Pollutants in Table 3-8
These pollutants are either not considered to originate from the MS4, or the WBPC is a condition rather than a “pollutant” with the potential to be discharged from the MS4.

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Section 6  Reasonable Assurance Analysis (RAA)
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6.2.7 Required Interim and Final Pollutant Reductions
The RAA Guidelines specify that required pollutant reductions should be determined by comparing baseline/current pollutant loading to the allowable pollutant loading (Regional Board, 2014). With a set of defined critical conditions and identified limiting pollutants for ULAR (as described in the previous two subsections), the required pollutant reductions for ULAR can be determined, as shown in Table 6-6.

The control measures to be implemented by the EWMP are designed to achieve these reductions, and the RAA provides assurance the required reductions will be achieved by the selected control measures.

Each EWMP Group member is held to achieving equitable reductions for the receiving waters / assessment areas to which they discharge. It is noted that the several of the assessment areas require greater than 75% reduction in zinc loading, which is rather high and leads to requirements for extensive structural control measures.

An important consideration for the RAA and scheduling of control measures is the difference between interim and final requirements. While the critical condition (90th percentile) is used to define the required reductions for final compliance, interim compliance is based on average conditions according to the RAA Guidelines (Regional Board, 2014):

For interim WQBELs and/or receiving water limitations, the percent reduction based on annual average baseline loading may be used to set targets/goals for BMPs/watershed control measures. A gradual phasing of percent load reduction for interim WQBELs/RWLs to final WQBELs/RWLs shall be applied over the course of the implementation schedule. [page 7]
For the ULAR RAA, the gradual phasing is achieved by determining the ratio of loading during average to 90th percentile conditions, as shown in Table 6-6. Zinc loading during the interim/average condition is between 26% and 41% of the loading that occurs during the final/90th percentile condition. The approach for applying this ratio during scheduling of control measures for EWMP/TMDL milestones is described in Appendix 6.G.

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Section 6  Reasonable Assurance Analysis (RAA)
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Table 6-6. Limiting ULAR Pollutant Reductions for Interim and Final Compliance Condition
and
Pollutant
Addressed
Reduction
Metric
RAA Assessment Area
Compton
Creek
Rio
Hondo
Los Angeles
River Reach
2 Arroyo
Seco
Verdugo
Wash
Burbank
Western
Channel
Tujunga
Wash
Bull
Creek
Los
Angeles
River
Reach 6
Aliso
Wash
Browns
Canyon
Wash
McCoyDry
Canyon
Creek
Bell Creek
Final
Compliance
with Metals
and Other
Water
Quality
Priorities
(except E.
coli)
Required
Load
Reduction 1
77% 59% 32% 39% 41% 75% 32% 65% 84% 62% 89% 84% 23%
Interim
Compliance
with Metals
and Other
Water
Quality
Priorities
(except E.
coli)
Loading
during
average/inter
im condition
(pounds)2
341 382 2,235 85 105 173 267 149 581 114 87 58 58
Loading
during 90th
percentile/fin
al condition
(pounds)3
1,359 1,123 4,323 298 401 532 720 335 1,712 284 298 136 104 Ratio used to
gradually
phase from
interim to
final required
reduction

0.25 0.34 0.52 0.29 0.26 0.33 0.37 0.44 0.34 0.40 0.29 0.43 0.56 Final
Compliance
with E. coli
Runoff
volume to be
retained
Runoff from critical bacteria storm is retained
prior to discharge to receiving water
(excluding open space subwatersheds)
1 – Based on control of zinc during storm that generates the 90th percentile zinc Exceedance Volume 2 – Loading of zinc at mouth of watershed from storm that generates the average zinc Exceedance Volume 3 – Loading of zinc at mouth of watershed from storm that generates the 90th percentile zinc Exceedance Volume

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Section 6  Reasonable Assurance Analysis (RAA)
Upper LA River EWMP 6-20 Draft June 2015

6.3 Representation of EWMP Control Measures
Once the model is set up to accurately simulate baseline hydrology and water quality conditions, the targets have been calculated, and the required reductions estimated, the next stage of the RAA determines the optimal combination of BMP types to achieve applicable RWLs and WQBELs. This step requires a robust set of assumptions to define the watershed-wide extent and configuration of each of the types of control measures that make up the EWMP Implementation Strategy.

The representation of control measures in the model is an important element of the RAA, as it provides the link between future watershed activities, model-predicted water quality improvement, and, ultimately, compliance. Since the BMP modeling parameters will greatly influence the outcome of the RAA, it is imperative that the suite of BMP assumptions are based on the best available data and represent the opportunity and limitations that will be faced by designers, contractors, and maintenance crews in the field as these BMPs are implemented over time. Further, the technical rigor of the analysis must be appropriately balanced with the resolution of the modeling system and the accuracy of the key datasets.

This section presents and reviews the following three primary elements for representing BMPs in the RAA model:
 Opportunity – Where can these BMPs be located and how many can be accommodated?  System Configuration – How is the runoff routed to and through the BMP and what is the maximum BMP size?
 Cost Functions – What is the relationship between BMP volume/footprint/design elements and costs?
The following sections provide an overview of methods, summarize key assumptions, and highlight potential data limitations. Appendices 6.C through 6.F, as summarized in the following subsections, contain additional information including details on how each type of control measure (LID, green streets, regional BMPs) was represented in the modeling system (SUSTAIN).

6.3.1 BMP Opportunities
BMPs can only feasibly be implemented at certain locations in the watershed. While physical constraints may limit implementation in some areas (e.g., high slopes, insufficient space), practical or preferential constraints are also an important consideration for each jurisdiction (e.g., parcel ownership, redevelopment rates). To ensure that the spatial and temporal extent of BMP opportunities were accurately accounted for in the model, a BMP opportunity assessment was customized for each individual BMP category and type. The best available data and GIS layers were specifically selected to screen out inappropriate opportunities and/or identify high priority project opportunities (e.g. regional projects on public parcels). A summary of these methods is provided in Table 6-7 and detailed methods and screening results are provided in Appendix 6.C.

In addition to the spatial opportunity screening process, which highlighted on potential roadblocks to BMP implementation, the individual preferences of the EWMP Group members were incorporated into the RAA, in order to allow the EWMP Implementation Strategy to be customized to each jurisdiction.

These preferences are summarized in Table 6-8.

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Section 6  Reasonable Assurance Analysis (RAA)
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Table 6-7. Summary of BMP Opportunities for Final Compliance RAA BMP
Category Type Opportunity Identified
Institutional Institutional
Assumed to achieve 5% reduction for most jurisdiction. For those jurisdictions that elected to assume 10%, an enhanced set of institutional control measures is presented in the EWMP Implementation Strategy. The reductions were assumed to only be applicable to pollutants primarily associated with sediments (e.g., metals and historical organics), represented by total zinc. The 5% reduction was not directly applied to E. coli.

Low Impact
Development
Ordinance Acreage subject to redevelopment based on growth rates reported by City of Los Angeles.

Planned BMPs constructed after September 2011 were included based on list submitted in ULAR EWMP Work Plan.
on Residential 1% of residential parcels enrolled per year, starting in 2017. on Public Parcels flagged as opportunities based on screening for slopes, soil contamination, and ownership.

Green
Streets Green Streets Available opportunity approximated for each subwatershed based upon street types and slopes.

Regional
Very High
projects on
Public
Top 20 ranked parcels from regional BMP selection process.

High & Medium
projects on
Public
Parcels flagged as opportunities based on screening and prioritization conducted for regional project selection process.
on Private Control measures located on acquired private parcels to capture runoff near the subwatershed or jurisdiction outlet.

Table 6-8. Summary of BMP Preferences for ULAR EWMP Agencies Jurisdiction Institutional
LID
Ordinance
Residential
LID
Incentive
Program
LID
Retofits
on
Municipal
Parcels
Green
Streets with
Bioretention
and
Permeable
Pavement
Very
High/High
Regional
BMPs
Medium
Regional
BMPs on
School
Properties
Alhambra 5% Yes Yes Yes Yes Yes No
Burbank 10% a Yes Yes Yes Yes Yes Yes
Calabasas 5% Yes Yes Yes Yes Yes No
Glendale 10% a Yes Yes Yes Yes Yes No
Hidden Hills 5% Yes Yes Yes Yes Yes No
La Canada
Flintridge
5% Yes Yes Yes Yes No No
Los Angeles 5% Yes Yes Yes Yes Yes No
Montebello 5% Yes Yes Yes Yes Yes Yes
Monterey Park 5% Yes No Yes Yes Yes No
Pasadena 5% Yes Yes Yes Yes Yes No

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Section 6  Reasonable Assurance Analysis (RAA)
Upper LA River EWMP 6-22 Draft June 2015
Table 6-8. Summary of BMP Preferences for ULAR EWMP Agencies Jurisdiction Institutional
LID
Ordinance
Residential
LID
Incentive
Program
LID
Retofits
on
Municipal
Parcels
Green
Streets with
Bioretention
and
Permeable
Pavement
Very
High/High
Regional
BMPs
Medium
Regional
BMPs on
School
Properties
Rosemead 5% Yes Yes Yes Yes Yes No
San Fernando 5% Yes Yes Yes Yes Yes No
San Gabriel 5% Yes Yes Yes Yes Yes No
San Marino 5% Yes Yes Yes Yes Yes No
South El Monte 5% Yes Yes Yes Yes Yes Yes
South Pasadena 10% a Yes Yes Yes Yes Yes No
Temple City 10% a Yes No Yes Yes Yes Yes
Unincorporated
LA County
5% Yes Yes Yes Yes Yes Yes
a – See Table 7-4 in Section 7.5 for description of enhanced institutional control measures that will achieve the 10% reduction.

6.3.2 BMP Configuration
BMP configuration is determined by a combination of [1] physical watershed properties that are generally unchangeable (e.g., location of parcels or streets, soil types, drainage areas, space available for BMPs) and [2] BMP design assumptions which are at the discretion of the responsible agency (e.g., standard BMP profiles, underdrain configurations, soil media mixes). Table 6-9 provides a brief overview of BMP configuration assumptions and Appendix 6.D provides details on how variables were defined for each BMP categories/types, including the following:
 Drainage Area – Determined by the physical setup of the watershed and the placement of the BMP, drainage area ultimately defines how much water and pollutant load could possibly arrive at the site. A typical (or specific, where possible) drainage area is estimated for each category of BMP in Appendix 6.C and Appendix 6.D.
 Infiltration Rate – Determined by the soil types in the area, infiltration rate defines the rate at which water exits the BMP into the soil. Appendix 6.C provides details for how infiltration rates were spatially estimated.
 Routing – Determined by the drainage network in the local area, the runoff conveyance method is critical to determining how much of the runoff and associated pollutants are accessible by the BMP. Conveyance systems that are underground or well below-grade often require pumping to lift the runoff to a BMP. Table 6-9 provides details on when pumping is assumed.  BMP Design – Determined by the physical space available at the site and the standard profile assumed, BMP design defines the spatial footprint, depth, and internal hydraulic routing of runoff through the BMP. Appendix 6.D provides BMP design details for each individual BMP category and type.

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Section 6  Reasonable Assurance Analysis (RAA)
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 BMP Efficacy – Determined by the BMP type selected, BMP efficacy defines the pollutant removal rates for overflow or underdrain effluent from the BMP. Appendix 6.D provides BMP efficacy details.

Careful analyses were performed to specifically tailor each of the above variables for each individual BMP category and type. The results of these analyses have yielded a robust and defensible suite of BMP configuration assumptions that reasonably represent future BMP implementation in the watershed.

6.3.3 Cost Functions
To support BMP optimization, cost functions were developed for each type of structural BMP to relate capital and operations and maintenance (O&M) costs to physical BMP characteristics such as depth, footprint, and configuration. The cost functions are primarily based on those presented in the WMMS developed for TMDL Implementation Strategy in Los Angeles County (County of Los Angeles, 2012; Tetra Tech, Inc., 2011). While maintenance costs from previous efforts were based on national literature review estimates, those costs were updated for the RAA to provide customized regional cost functions.

Maintenance professionals from municipalities in Southern California were interviewed to determine actual costs for routine and intermittent maintenance practices such as mowing grass, pruning, spreading mulch, replacing soil media, sediment removal and street sweeping (Caltrans, City of La Mesa, City of Lemon Grove, City of San Diego, County of San Diego, and Unified Port of San Diego, 2013). The costs account for labor to perform the maintenance as well as costs for maintenance and upkeep of the equipment. A summary of the BMP cost functions, expressed as a function of BMP geometry is presented in Table 6-10.

It is important to note the cost functions are based on 20-year life cycle costs including O&M.

Table 6-9. Summary of BMP Design Assumptions for Final Compliance RAA BMP
Category Type Key Design Parameters
Institutional Institutional Assumed 5% reduction based on increased requirements in 2012 MS4 Permit.

Low Impact
Development
Ordinance Bioretention/Biofiltration sized to capture 85th percentile runoff from parcel.

Underdrains required if subsoil infiltration rate less than 0.3 in/hr.

Planned Bioretention/Biofiltration sized to capture 85th percentile runoff from parcel.

Underdrains required if subsoil infiltration rate less than 0.3 in/hr. on Residential Bioretention sized to approximately 4% of parcel area (typical sizing to capture 85th percentile runoff)
on Public Bioretention/Biofiltration sized to capture 85th percentile runoff from parcel.

Underdrains required if subsoil infiltration rate less than 0.3 in/hr.

Green Streets Green Streets
Bioretention/biofiltration is 4-ft wide. Permeable pavement/subsurface storage is 5- ft wide and used in tandem with bioretention/biofiltration. 50% of street length retrofittable. Underdrains required if subsoil infiltration rate less than 0.3 in/hr.

Regional
Very High
Projects on Public
BMP footprint delineated and ponding depth specified based on site configuration, topography, depth to groundwater, and infrastructure. Pump specified if greater than 100 ft from major storm drain using optimum diversion rate (0.09 cfs/ac).

High & Medium
Projects on Public
Same as Very High except ponding depth was assumed to be 3 ft (rather than based on site-specific configuration). Also, drainage areas and footprints are coarser due to the large number of these projects.
on Private Assumed 3-ft-deep infiltration basin at subwatershed outlets. Pumping assumed with no diversion limitations. Maximum footprint = 5% of contributing area.

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Section 6  Reasonable Assurance Analysis (RAA)
Upper LA River EWMP 6-24 Draft June 2015
Table 6-10. Summary of BMP Cost Functions for Final Compliance RAA (20-year, including O&M) BMP
Category
BMP types Functions for Estimating Total Costs 1
LID and
Green
Streets
Bioretention with Underdrain Cost = 64.908 (A) + 2.165 (Vt) + 2.64 (Vm) + 3.3 (Vu) Bioretention without Underdrain Cost = 56.658 (A) + 2.165 (Vt) + 2.64 (Vm) Residential LID Cost = 4.000 (A)
Permeable Pavement with Underdrain Cost = 65.849 (A) + 3.3 (Vu) Permeable Pavement without Underdrain Cost = 57.599 (A) Regional
BMPs
Pump Cost = 56,227*(Pump Capacitycfs) + $1,207,736
Regional Project on Public Parcel Cost = 45.42 (A) + 2.296 (Vt) + 2.8 (Vm) Regional Project on Private Parcel Cost = 45.42 (A) + 2.296 (Vt) + 2.8 (Vm) + 129 (A) 1 – Functions describe 20-year life cycle costs including O&M using the following variables: (A) is the area of the BMP footprint in square feet, (Vt) is the total volume of the BMP in cubic feet, (Vm) is the volume of the BMP soil media in cubic feet, and (Vu) is the volume of the BMP underdrain in cubic feet.

6.4 BMP Selection
The RAA process is an important tool for assisting EWMP agencies with selection of control measures for EWMP implementation (known as the EWMP Implementation Strategy). A major challenge associated with stormwater planning is the multitude of potential types and locations of control measures and the varying performance and cost of each scenario. This subsection describes the process for selecting the control measures for the EWMP Implementation Strategy by each jurisdiction.

6.4.1 Selection of Control Measures for Final Wet Weather Compliance The SUSTAIN model within WMMS provides a powerful tool for considering millions of scenarios of control measures and recommending a solution based on cost-effectiveness. The cost functions described in the previous subsection are used to weigh the cost of different BMP scenarios with benefits in terms of pollutant load reduction. As shown in Figure 6-7, the RAA process for the ULAR EWMP first determines the control measures to achieve zinc RWLs under critical conditions and then determines the additional capacity (if any) to retain the critical bacteria storm. The optimization modeling is conducted stepwise to determine the control measures for final compliance that are selected for the EWMP Implementation Strategy, as follows:

1. Determine the cost-effective BMP solutions for each subwatershed in the EWMP area: an example set of “BMP solutions” is shown in Figure 6-8, which shows thousands of scenarios considered for an individual subwatershed in the EWMP area. The scenarios are based on the available opportunity (e.g., the available footprints for regional BMPs and length of right-of-way for green streets) and predicted performance for controlling zinc if BMPs were implemented at those opportunities with varying sizes. The most cost-effective BMP solutions for each of the 1,129 subwatersheds in the EWMP area provide the basis for cost optimization.

2. Determine the cost-effective scenarios for each Group member: by rolling up the BMP solutions at the subwatershed level, the most cost-effective scenarios for each jurisdiction can be determined for a wide range of required zinc reductions. These “cost optimization curves” provide a potential EWMP Implementation Strategy for a range of required reductions.

Figure 6-9 shows example cost optimization curves for the jurisdictions that drain to Arroyo Seco. Each scenario is a “recipe for compliance” for all the subwatersheds in the jurisdictional area (for a given percent reduction). The complete set of cost optimization curves for the ULAR EWMP are presented in Appendix 6.G.

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3. Extract the cost-effective scenarios for the required reduction: the required zinc reductions specified in Table 6-7 determine the specific scenario that is selected from the cost optimization curves. All Group members within the assessment areas are held to the same percent reduction.

The selected scenarios become the EWMP Implementation Strategy. Figure 6-10 illustrates the process for extracting the control measures to achieve zinc RWLs from the cost optimization curve. The extracted control measures comprise a detailed recipe for compliance with RWLs for metals and other Water Quality Priorities for each subwatershed in the jurisdictional area.

4. Route the critical bacteria storm through the control measures in the extracted scenario:
the effectiveness of the selected control measures for retaining the critical bacteria storm is evaluated. The additional capacity (if any) to retain the critical bacteria storm is determined for each subwatershed.

The resulting EWMP Implementation Strategy for final compliance is presented in Section 7.

Figure 6-8. Example BMP Solutions for a Selected Subwatershed and Advantage of Cost-Benefit Optimization
This figure shows an optimization output for a single subwatershed. A similar curve was generated for each of the 1,129 subwatersheds in the ULAR EWMP area. The EWMP Implementation Strategy is based on an optimization routine that searches through those curves and selects the combination of solutions in each assessment area / watershed that provides the greatest cost-benefit for the required pollutant reduction.

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Figure 6-9. Example Cost Optimization Curves for a Watershed: Arroyo Seco This example shows the set of optimized BMP solutions for ULAR EWMP jurisdictions that drain to Arroyo Seco. Each optimization curve represents over 1 million BMP scenarios that were evaluated for cost-effectiveness. All jurisdictions in Arroyo Seco are held to an equitable 39% reduction, but the curves differ among jurisdictions due to differing BMP opportunities. Different watersheds are subject to different percent reductions (see Section 6.5.4). See Appendix 6.G for the complete set of cost optimization curves.

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Section 6  Reasonable Assurance Analysis (RAA)
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Figure 6-10. Illustration of how the EWMP Implementation Strategy is Extracted from a Cost Optimization Curve.

This illustration uses the City of Los Angeles jurisdiction in the Arroyo Seco watershed as an example. Three steps are shown for RAA development: cost-optimized BMP solutions are developed for a wide range of % load reductions (1st, uppermost text box), followed by determination of the equitable % load reduction needed to attain RWLs for the corresponding receiving water (2nd, middle text box), and then the corresponding BMP solution is extracted to complete the RAA and determine the EWMP Implementation Strategy for the jurisdictional area (3rd, bottom text box). The EWMP Implementation Strategy for all jurisdictions and assessment areas is presented in Section 7. Note that while all jurisdictions in an assessment area/watershed are held to an equivalent % reduction, subwatersheds within a jurisdiction may have variable reductions based on optimization (which is why some subwatersheds have high % reductions [red shaded rows in table] and others have low % reductions).

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Section 6  Reasonable Assurance Analysis (RAA)
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6.4.2 Selection of Control Measures for Interim Wet Weather Compliance With the EWMP Implementation Strategy for final compliance determined, the remaining step for the wet weather RAA is scheduling of control measures over time to achieve interim milestones. The following interim wet weather milestones were utilized for development of the ULAR EWMP, primarily based on the milestones of the LA River Metals and Bacteria TMDLs28:
 Achieve 31% of the reduction for zinc29 and WBPCs identified in Tables 3-6 and 3-7 (2017)  Achieve 50% of the reduction for metals and WBPCs identified in Tables 3-6 and 3-7 (2024)  Achieve 100% of the reduction for metals and WBPCs identified in Tables 3-6 and 3-7 (2028)  Achieve 100% of the reduction for toxics (2032)
 Achieve 100% of the reduction for bacteria (2037)
The scenario of control measures that corresponds to each of the EWMP / TMDL milestones was extracted and used for scheduling of the EWMP Implementation Strategy, as presented in the next section.

As described in Section 6.5.4, the applicable critical condition gradually phases from average conditions for interim milestones to critical conditions (90th percentile) for final compliance. The approach for determining the control measures that correspond to each milestone was as follows:

1. Simulate the BMP performance of increasing levels of control measure implementation:
multiple increments of “percent completion” of the final EWMP Implementation Strategy were simulated to determine the relative performance as control measures are implemented toward final compliance. The result is a curve of Percent of Final Reduction versus Percent of Final Capacity (see Figure 6-11).

2. Incorporate the gradual phasing from average the critical conditions: the gradual phasing was accomplished by applying the average:final ratios in Table 6-6 to the BMP sequencing. An illustration of the phasing approach is shown in Figure 6-11. The orange “translator” from average to final phases from relying entirely on average conditions at 0% completion and phases to relying entirely on final conditions at 100% completion. The formulation of the orange translator line is based on the quadratic equation, as detailed in Appendix 6.H.

The scenario of control measures that corresponds to each of the EWMP / TMDL milestones was extracted and used for scheduling of the EWMP Implementation Strategy, as presented in the next section.

28 Milestones for the San Gabriel River portion of South El Monte are described in Appendix 1.B. 29 While these milestones are expressed as reduction in zinc, because zinc is a limiting pollutant (see Section 6.5.3), achievement of zinc RWLs by these dates assures even greater reduction in other Water Quality Priority pollutants.

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Figure 6-11. Illustration of Gradually Phasing from Average to Critical Conditions for Interim Milestones
The orange “translator” line phases from average to final by relying entirely on average conditions at 0% final BMP capacity and then phases to relying entirely on final conditions at 100% BMP capacity.

In the example, the average:final ratio is 0.34 (see right hand side of figure). The percent BMP completion based on the final compliance target (critical conditions) is represented by the top blue line [segment AC], while percent BMP completion based on the interim target (average conditions) is represented by bottom blue line [segment AB]. The orange curve represents the “translator” for phasing of the pollutant reduction target from average to critical conditions to match the approach recommended by the RAA Guidelines (and account for the average:final ratio of 0.34). A reduction of 35% under average conditions represents a 20% reduction under final conditions. A 65% reduction under average conditions represents a 50% reduction under final conditions. The relative difference depends on the average:final ratio, which is watershed-specific (see Table 6-6). As the ratio approaches 1.0, average and final conditions become identical.

Average
90th Percentile
65%
35%
10%
10% ramp
35% ramp
65% ramp
Ratio: = 34%
90th Percentile
100%
C
B
A

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Section 7
Detailed EWMP Implementation Strategy and
Compliance Schedule
The EWMP Implementation Strategy is the “recipe for compliance” of each jurisdiction to address Water Quality Priorities and comply with the provisions of the MS4 Permit. Through the RAA, a series of quantitative analyses were used to identify the capacities of LID, green streets and regional BMPs that comprise the EWMP Implementation Strategy and assure those control measures will address the Water Quality Priorities. The EWMP Implementation Strategy includes individual recipes for each of the 17 jurisdictions and each watershed/assessment area – Los Angeles River above Sepulveda Basin, Los Angeles River below Sepulveda Basin, Compton Creek, Rio Hondo, Verdugo Wash, Arroyo Seco, Burbank Western Channel, Tujunga Wash, Bull Creek, Aliso Wash, Bell Creek, McCoy-Dry Canyon, and Browns Canyon Wash (see Figure 6-1 for a map of these assessment areas). Implementation of the EWMP Implementation Strategy will provide a BMP-based compliance pathway for each jurisdiction under the MS4 Permit. This section describes the EWMP Implementation Strategy and the pace of its implementation to achieve applicable milestones, through the following subsections:
 Elements of the EWMP Implementation Strategy (7.1)
 Stormwater control measures to be implemented by 2037 for final compliance (7.2)  Scheduling of stormwater control measures to achieve TMDL and EWMP milestones (7.3)  Non-stormwater control measures (7.4)
 Institutional control measures (7.5)

7.1 What are the Elements of the EWMP Implementation
Strategy?
The EWMP Implementation Strategy is expressed in terms of [1] the volumes30 of stormwater and nonstormwater to be managed by each jurisdiction to address Water Quality Priorities and [2] the control measures that will be implemented to achieve those volume reductions. The two primary elements of the Pollutant Reduction are as follows:
 Compliance Targets: for MS4 compliance determination purposes, the primary metric for EWMP implementation is the volume of stormwater managed by implemented control measures. The stormwater volume to be managed31 is considered the BMP performance goal for the EWMP. To

30 Volume is used rather than pollutant loading because volume reduction is more readily tracked and reported by MS4 agencies. As described in Section 6.2.3, the volume reductions are actually a water quality improvement target based on required pollutant reductions.
31 The reported volume is determined by tracking the amount of water that is be retained (infiltrated) by BMPs over the course of a 24-hour period under the critical 90th percentile storm condition. Additional volume would be treated by these BMPs, but that additional treatment is implicit to the reported Compliance Targets. For compliance purposes the volume in the Compliance Target can either be retained and/or treated to concentrations below RWLs. Both would result in compliance.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-2 Draft June 2015
support future compliance determination and adaptive management, the volume of stormwater to be managed is reported along with the capacities of control measures to be implemented by each jurisdiction in the EWMP Implementation Strategy.
 EWMP Implementation Strategy: the network of LID, green streets and regional BMPs that has reasonable assurance of achieving the Compliance Targets is referred to as the EWMP Implementation Strategy. The identified BMPs (and BMP preferences) will likely evolve over the course of adaptive management in response to “lessons learned.” As such, it is anticipated the BMP capacities within the various subcategories will be reported to the Regional Board but not tracked explicitly by the Regional Board for compliance determination. As BMPs are substituted over the course of EWMP implementation (e.g., replace green street capacity in a subwatershed with additional regional BMP capacity), the Group will show equivalency for achieving the corresponding Compliance Target.

Additionally, the EWMP Implementation Strategy includes the implementation of the MCMs, which are not only required by the Permit, but also address the Category 2 and 3 WBPCs identified in Table 3-7.

7.2 Which Stormwater Control Measures Correspond to
Final Compliance by 2037?
The EWMP will guide stormwater management in the ULAR watershed for the coming decades, and the LID, green streets and regional BMPs to be implemented by the EWMP have the potential to transform communities. The EWMP Implementation Strategy identifies the location and type of control measures to be implemented by each jurisdiction for final compliance by 2037, which includes addressing all Water Quality Priorities including the limiting pollutants zinc and E. coli (as described in Section 6.2.4).

The EWMP Implementation Strategy for final compliance is presented as follows:
 Summary of total capacity of control measures for each jurisdiction across the entire EWMP area: bar graphs are used to summarize the control measure capacities that comprise the EWMP Implementation Strategy. Shown in Figure 7-1 are the various subcategories of LID, green streets and regional BMPs for each jurisdiction across the entire EWMP area by 2037.  Detailed recipe for compliance including volumes of stormwater to be managed and control measure capacities: the EWMP Implementation Strategy is detailed for each subwatershed in the EWMP area (generally 1 to 2 square mile drainages). Shown in Figure 7-2 is a map of the “density” of control measure capacities to address metals and other Water Quality Priorities (through controlling zinc) and Figure 7-3 shows any additional capacity needed to address E. coli. The same results are shown as detailed tables in Appendix 7.A which present for each jurisdiction the volumes of stormwater to be managed in each subwatershed (Compliance Targets) and the control measures to achieve those volume reductions (EWMP Implementation

2 While the EWMP Implementation Strategy reports the total BMP capacity to be implemented, that capacity is not a compliance target because some BMP capacities are sized to reflect a BMP program rather than sized to achieve the required reduction. For example, the BMPs implemented by the LID ordinance and the residential LID program were sized to retain the 85th percentile, 24-hour storm but that volume may be larger than is needed to achieve zinc RWLs. If those BMPs were replaced by a different type of BMP (e.g., regional BMP), the total BMP capacity may be smaller but just as effective.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-3 Draft June 2015
Strategy). Note that separate Compliance Targets and EWMP Implementation Strategies are provided for Metals and Other Water Quality Priorities and E. coli.

Additionally, the EWMP Implementation Strategy includes the implementation of the MCMs, which are not only required by the Permit, but also address the Category 2 and 3 WBPCs identified in Table 3-7.

The network of LID, green streets and regional BMPs in the EWMP Implementation Strategy represents approximately 20 Rose Bowls of BMP capacity. Implementation of such a large network of control would represent a sea change in how stormwater will be managed in the LA River, and will require orders of magnitude increases in stormwater funding. Note that non-stormwater and institutional control measures are separately described below in Section 7.4 and 7.5, respectively. The next subsection describes the timeline/sequencing for implementing the EWMP Implementation Strategy.

The costs and financial strategy for the EWMP are presented in Section 9.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-4 Draft June 2015
Figure 7-1. ULAR EWMP Implementation Strategy for Final Compliance by 2037 The two panels show the total structural BMP capacity required for each ULAR EWMP jurisdiction to attain RWLs. The top panel groups the BMP types into LID, green streets and regional BMPs, while the bottom panel provides more resolution for the BMP sub-categories. Detailed BMP capacities for each jurisdiction by subwatershed are presented in Appendix 7.A. BMP capacities for each jurisdiction by assessment area are also presented in Appendix 7.C. Note that a different y-axis scale is used for City of Los Angeles. The bars in the bottom panel are also presented for each jurisdiction in Figure 7-5 through Figure 7-21. Page 506 of 563

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-5 Draft June 2015
Figure 7-2. EWMP Implementation Strategy by Subwatershed for Metals and Other Water Quality Priorities (except E. coli)
This map presents the EWMP Implementation Strategy for Metals and Other Water Quality Priorities as control measure “density” by subwatershed. The BMP density is higher in some areas [dark blue] because either [1] relatively high load reductions are required or [2] BMPs in those areas were relatively cost-effective (e.g., due to high soil infiltration rates).The BMP capacities are normalized by area (i.e., the BMP capacity for each subwatershed [in units of acre-feet] was divided by the subwatershed area [in units of acres] to express the BMP capacity in units of depth [feet or inches]). Note that while all jurisdictions in an assessment area/watershed are held to an equivalent % reduction, subwatersheds within a jurisdiction may have variable reductions based on cost-benefit optimization (another reason why some subwatersheds within a jurisdiction are dark blue while others are light blue). The tabular

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-6 Draft June 2015
version of this map is presented as a series of tables in in Appendix 7.A, and subwatershed index maps for each jurisdiction are presented in Appendix 7.B.

Figure 7-3. Additional Control Measures in EWMP Implementation Strategy to Address E. coli This map uses the same approach as Figure 7-2 to presents the additional capacity in the EWMP Implementation Strategy to address E. coli (beyond the control measures to address Metals and Other Water Quality Priorities). Note the BMP capacities are much less than in Figure 7-2 because the control measures for Metals and Other Water Quality Priorities retain much of the critical bacteria storm. Some subwatersheds are not shaded because zero additional capacity is required. The tabular version of this map is presented as a series of tables in in Appendix 7.A, and subwatershed index maps for each jurisdiction are presented in Appendix 7.B.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-7 Draft June 2015
Figure 7-4. Additional Control Measures in EWMP Implementation Strategy to Address E. coli The bars represent the total control measure capacity in the EWMP Implementation Strategy, and the percentages at the top of each bar report the percent increase in BMP capacity required by the RAA to control E. coli beyond the control measures for zinc. Note that the y-axis scale differ in each of the three panels and for the City of Los Angeles.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-8 Draft June 2015

7.3 How are Stormwater Control Measures Scheduled to
Achieve EWMP and TMDL Milestones?
As described in Section 3, the scheduling of LID, green streets and regional BMP implementation for the EWMP is based on the milestones of the applicable metals, toxics and bacteria TMDLs, as follows32, 33:
 By 2017, achieve a 31% milestone34 for the Los Angeles River Metals TMDL and a 31% milestone for the WBPCs identified in Tables 3-6 and 3-7;
 By 2024, achieve a 50% milestone for the Los Angeles River Metals TMDL and a 50% milestone for the WBPCs identified in Tables 3-6 and 3-7;
 By 2028, achieve final compliance (100% milestone) for the Los Angeles River Metals TMDL and a 100% milestone for WBPCs identified in Tables 3-6 and 3-7;  By 2032, Achieve final compliance for the Los Angeles / Long Beach Harbors Toxics TMDL; and  By 2037, achieve final compliance for the LA River Bacteria TMDL.

The scheduling of the EWMP Implementation Strategy is presented as the following components:
 Summary of control measure capacities by each jurisdiction by assessment area/watershed: the LID, green streets and regional BMP capacities that will be implemented over time to achieve milestones are shown in Figure 7-5 thru 7-21. Separate panels are shown for each jurisdiction, organized by LA River reaches and tributaries (recall that Figure 6-1 shows a map of the assessment areas).
 Detailed scheduling for each jurisdiction including volumes of stormwater to be managed and control measure capacities: detailed tables that present the scheduling by assessment area for each jurisdiction including volumes of stormwater (Compliance Targets) to be managed are presented in Appendix 7.C. Each jurisdiction has a standalone Implementation Strategy for the LA River reaches and tributaries to which it contributes runoff.

Additionally, the EWMP Implementation Strategy includes the implementation of the MCMs, which are not only required by the Permit, but also address the Category 2 and 3 WBPCs identified in Table 3-7.

The pace of implementation for the EWMP Implementation Strategy is rapid due to the compliance dates specified in the metals, toxics and bacteria TMDLs. Because the pace of implementation is directly proportional to required annual investments, the additional required resources to implement the EWMP will be significant. The costs and financial strategy are presented in Section 9.

32 For WBPCs that are not addressed in a Regional Board approved TMDL, attainment of the percentages may be demonstrated either as a reduction in exceedance frequency at time of EWMP approval or percent area meeting the RWL or in the case of the USEPA adopted TMDLs reduction from the baseline at the time of TMDL promulgation or percent area meeting the WQBEL or RWL.
33 Milestones for the San Gabriel River portion of South El Monte are described in Appendix 1.B. 34 The 31% milestone for 2017 was created as an EWMP milestone because the Permit requires milestones be developed if not specified in the Permit for the current Permit term. The Metals TMDL specifies a 25% milestone in 2012 and 50% milestone in 2024. The 31% milestone is the corresponding intermediate reduction, and is consistent with the 31% milestone specified by the Lower Los Angeles River WMP Group.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-9 Draft June 2015
Figure 7-5. City of Los Angeles: Scheduling of EWMP Implementation Strategy to Achieve EWMP / TMDL Milestones The bars represent the LID, green street and regional BMP capacity to achieve each EWMP/TMDL milestone. The top panel represents the BMPs to achieve final compliance in 2037; the bottom panel schedules them through 2037. These capacities are also presented in detail in Appendix 7.C. For the Metals TMDL, the 31% milestone was developed for the EWMP; the 50% milestone is specified by TMDL. Between 2026 and 2032, source control efforts to address toxics in sediments (indicated by red dot) will be implemented, if necessary. Note the y-axis scale differs in each panel.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-10 Draft June 2015
Figure 7-6. City of Los Angeles (continued): Scheduling of EWMP Implementation Strategy to Achieve EWMP / TMDL Milestones The bars represent the LID, green street and regional BMP capacity to achieve each EWMP/TMDL milestone. The top panel represents the BMPs to achieve final compliance in 2037; the bottom panel schedules them through 2037. These capacities are also presented in detail in Appendix 7.C. For the Metals TMDL, the 31% milestone was developed for the EWMP; the 50% milestone is specified by TMDL. Between 2026 and 2032, source control efforts to address toxics in sediments (indicated by red dot) will be implemented, if necessary. Note the y-axis scale differs in each panel.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-11 Draft June 2015
Figure 7-7. Uninc. LA County: Scheduling of EWMP Implementation Strategy to Achieve EWMP / TMDL Milestones The bars represent the LID, green street and regional BMP capacity to achieve each EWMP/TMDL milestone. The top panel represents the BMPs to achieve final compliance in 2037; the bottom panel schedules them through 2037. These capacities are also presented in detail in Appendix 7.C. For the Metals TMDL, the 31% milestone was developed for the EWMP; the 50% milestone is specified by TMDL. Between 2026 and 2032, source control efforts to address toxics in sediments (indicated by red dot) will be implemented, if necessary. Note the y-axis scale differs in each panel.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-12 Draft June 2015
Figure 7-8. Uninc. LA County (continued): Scheduling of EWMP Implementation Strategy to Achieve EWMP / TMDL Milestones The bars represent the LID, green street and regional BMP capacity to achieve each EWMP/TMDL milestone. The top panel represents the BMPs to achieve final compliance in 2037; the bottom panel schedules them through 2037. These capacities are also presented in detail in Appendix 7.C. For the Metals TMDL, the 31% milestone was developed for the EWMP; the 50% milestone is specified by TMDL. Between 2026 and 2032, source control efforts to address toxics in sediments (indicated by red dot) will be implemented, if necessary. Note the y-axis scale differs in each panel.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-13 Draft June 2015
Figure 7-9. Alhambra: Scheduling of EWMP Implementation Strategy to Achieve EWMP / TMDL Milestones The bars represent the LID, green street and regional BMP capacity to achieve each EWMP/TMDL milestone. The top panel represents the BMPs to achieve final compliance in 2037; the bottom panel schedules them through 2037. These capacities are also presented in detail in Appendix 7.C. For the Metals TMDL, the 31% milestone was developed for the EWMP; the 50% milestone is specified by TMDL. Between 2026 and 2032, source control efforts to address toxics in sediments (indicated by red dot) will be implemented, if necessary.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-14 Draft June 2015
Figure 7-10. Burbank: Scheduling of EWMP Implementation Strategy to Achieve EWMP / TMDL Milestones The bars represent the LID, green street and regional BMP capacity to achieve each EWMP/TMDL milestone. The top panel represents the BMPs to achieve final compliance in 2037; the bottom panel schedules them through 2037. These capacities are also presented in detail in Appendix 7.C. For the Metals TMDL, the 31% milestone was developed for the EWMP; the 50% milestone is specified by TMDL. Between 2026 and 2032, source control efforts to address toxics in sediments (indicated by red dot) will be implemented, if necessary.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-15 Draft June 2015
Figure 7-11. Calabasas: Scheduling of EWMP Implementation Strategy to Achieve EWMP / TMDL Milestones
The bars represent the LID, green street and regional BMP capacity to achieve each EWMP/TMDL milestone. The top panel represents the BMPs to achieve final compliance in 2037; the bottom panel schedules them through 2037. These capacities are also presented in detail in Appendix 7.C. For the Metals TMDL, the 31% milestone was developed for the EWMP; the 50% milestone is specified by TMDL. Between 2026 and 2032, source control efforts to address toxics in sediments (indicated by red dot) will be implemented, if necessary.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-16 Draft June 2015
Figure 7-12. Glendale: Scheduling of EWMP Implementation Strategy to Achieve EWMP / TMDL Milestones The bars represent the LID, green street and regional BMP capacity to achieve each EWMP/TMDL milestone. The top panel represents the BMPs to achieve final compliance in 2037; the bottom panel schedules them through 2037. These capacities are also presented in detail in Appendix 7.C. For the Metals TMDL, the 31% milestone was developed for the EWMP; the 50% milestone is specified by TMDL. Between 2026 and 2032, source control efforts to address toxics in sediments (indicated by red dot) will be implemented, if necessary. Note the y-axis scale differs in each panel.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-17 Draft June 2015
Figure 7-13. Hidden Hills: Scheduling of EWMP Implementation Strategy to Achieve EWMP / TMDL Milestones
The bars represent the LID, green street and regional BMP capacity to achieve each EWMP/TMDL milestone. The top panel represents the BMPs to achieve final compliance in 2037; the bottom panel schedules them through 2037. These capacities are also presented in detail in Appendix 7.C. For the Metals TMDL, the 31% milestone was developed for the EWMP; the 50% milestone is specified by TMDL. Between 2026 and 2032, source control efforts to address toxics in sediments (indicated by red dot) will be implemented, if necessary.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-18 Draft June 2015
Figure 7-14. La Canada Flintridge: Scheduling of EWMP Implementation Strategy for Milestones The bars represent the LID, green street and regional BMP capacity to achieve each EWMP/TMDL milestone. The top panel represents the BMPs to achieve final compliance in 2037; the bottom panel schedules them through 2037. These capacities are also presented in detail in Appendix 7.C. For the Metals TMDL, the 31% milestone was developed for the EWMP; the 50% milestone is specified by TMDL. Between 2026 and 2032, source control efforts to address toxics in sediments (indicated by red dot) will be implemented, if necessary.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-19 Draft June 2015
Figure 7-15. Montebello: Scheduling of EWMP Implementation Strategy to Achieve EWMP / TMDL Milestones
The bars represent the LID, green street and regional BMP capacity to achieve each EWMP/TMDL milestone. The top panel represents the BMPs to achieve final compliance in 2037; the bottom panel schedules them through 2037. These capacities are also presented in detail in Appendix 7.C. For the Metals TMDL, the 31% milestone was developed for the EWMP; the 50% milestone is specified by TMDL. Between 2026 and 2032, source control efforts to address toxics in sediments (indicated by red dot) will be implemented, if necessary.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-20 Draft June 2015
Figure 7-16. Monterey Park: Scheduling of EWMP Implementation Strategy to Achieve EWMP / TMDL Milestones The bars represent the LID, green street and regional BMP capacity to achieve each EWMP/TMDL milestone. The top panel represents the BMPs to achieve final compliance in 2037; the bottom panel schedules them through 2037. These capacities are also presented in detail in Appendix 7.C. For the Metals TMDL, the 31% milestone was developed for the EWMP; the 50% milestone is specified by TMDL. Between 2026 and 2032, source control efforts to address toxics in sediments (indicated by red dot) will be implemented, if necessary. Note the y-axis scale differs in each panel.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-21 Draft June 2015
Figure 7-17. Pasadena: Scheduling of EWMP Implementation Strategy to Achieve EWMP / TMDL Milestones The bars represent the LID, green street and regional BMP capacity to achieve each EWMP/TMDL milestone. The top panel represents the BMPs to achieve final compliance in 2037; the bottom panel schedules them through 2037. These capacities are also presented in detail in Appendix 7.C. For the Metals TMDL, the 31% milestone was developed for the EWMP; the 50% milestone is specified by TMDL. Between 2026 and 2032, source control efforts to address toxics in sediments (indicated by red dot) will be implemented, if necessary. Note the y-axis scale differs in each panel.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-22 Draft June 2015
Figure 7-18. Rosemead: Scheduling of EWMP Implementation Strategy to Achieve EWMP / TMDL Milestones
The bars represent the LID, green street and regional BMP capacity to achieve each EWMP/TMDL milestone. The top panel represents the BMPs to achieve final compliance in 2037; the bottom panel schedules them through 2037. These capacities are also presented in detail in Appendix 7.C. For the Metals TMDL, the 31% milestone was developed for the EWMP; the 50% milestone is specified by TMDL. Between 2026 and 2032, source control efforts to address toxics in sediments (indicated by red dot) will be implemented, if necessary.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-23 Draft June 2015
Figure 7-19. San Fernando: Scheduling of EWMP Implementation Strategy for EWMP / TMDL Milestones The bars represent the LID, green street and regional BMP capacity to achieve each EWMP/TMDL milestone. The top panel represents the BMPs to achieve final compliance in 2037; the bottom panel schedules them through 2037. These capacities are also presented in detail in Appendix 7.C. For the Metals TMDL, the 31% milestone was developed for the EWMP; the 50% milestone is specified by TMDL. Between 2026 and 2032, source control efforts to address toxics in sediments (indicated by red dot) will be implemented, if necessary.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-24 Draft June 2015
Figure 7-20. San Gabriel: Scheduling of EWMP Implementation Strategy for EWMP / TMDL Milestones The bars represent the LID, green street and regional BMP capacity to achieve each EWMP/TMDL milestone. The top panel represents the BMPs to achieve final compliance in 2037; the bottom panel schedules them through 2037. These capacities are also presented in detail in Appendix 7.C. For the Metals TMDL, the 31% milestone was developed for the EWMP; the 50% milestone is specified by TMDL. Between 2026 and 2032, source control efforts to address toxics in sediments (indicated by red dot) will be implemented, if necessary.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-25 Draft June 2015
Figure 7-21. San Marino: Scheduling of EWMP Implementation Strategy for EWMP / TMDL Milestones The bars represent the LID, green street and regional BMP capacity to achieve each EWMP/TMDL milestone. The top panel represents the BMPs to achieve final compliance in 2037; the bottom panel schedules them through 2037. These capacities are also presented in detail in Appendix 7.C. For the Metals TMDL, the 31% milestone was developed for the EWMP; the 50% milestone is specified by TMDL. Between 2026 and 2032, source control efforts to address toxics in sediments (indicated by red dot) will be implemented, if necessary.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-26 Draft June 2015
Figure 7-22. South El Monte: Scheduling of EWMP Implementation Strategy to Achieve EWMP / TMDL Milestones The bars represent the LID, green street and regional BMP capacity to achieve each EWMP/TMDL milestone. The top panels represents the BMPs to achieve final compliance in 2037 for Los Angeles River (left) and 2040 for San Gabriel River (right); the bottom panel shows the same control measured scheduled through 2037 (left) and 2040 (right). Note the y-axis scale differs in each panel. These capacities are also presented in detail in Appendix 7.C. For the LA River Metals TMDL (left), the 31% milestone was developed for the EWMP; the 50% milestone is specified by TMDL. Between 2026 and 2032, source control efforts to address toxics in sediments (indicated by red dot) will be implemented, if necessary.

For San Gabriel River TMDLs (right), the milestones are described in Appendix 1.B.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-27 Draft June 2015
Figure 7-23. South Pasadena: Scheduling of EWMP Implementation Strategy for EWMP / TMDL Milestones
The bars represent the LID, green street and regional BMP capacity to achieve each EWMP/TMDL milestone. The top panel represents the BMPs to achieve final compliance in 2037; the bottom panel schedules them through 2037. These capacities are also presented in detail in Appendix 7.C. For the Metals TMDL, the 31% milestone was developed for the EWMP; the 50% milestone is specified by TMDL. Between 2026 and 2032, source control efforts to address toxics in sediments (indicated by red dot) will be implemented, if necessary.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-28 Draft June 2015
Figure 7-24. Temple City: Scheduling of EWMP Implementation Strategy for EWMP / TMDL Milestones The bars represent the LID, green street and regional BMP capacity to achieve each EWMP/TMDL milestone. The top panel represents the BMPs to achieve final compliance in 2037; the bottom panel schedules them through 2037. These capacities are also presented in detail in Appendix 7.C. For the Metals TMDL, the 31% milestone was developed for the EWMP; the 50% milestone is specified by TMDL. Between 2026 and 2032, source control efforts to address toxics in sediments (indicated by red dot) will be implemented, if necessary.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-29 Draft June 2015

7.4 How will Non-stormwater be Addressed by the
EWMP?
The MS4 permit effectively prohibits non-stormwater discharges and the metals and bacteria TMDLs specify compliance dates for attainment of dry weather RWLs. The following subsections demonstrate35 the EWMP will eliminate non-stormwater discharges and describe dry weather strategies to address the bacteria and metals TMDLs as well as the remaining dry weather WBPCs identified in Tables 3-5, 3-6, and 3-7.

7.4.1 Elimination of Non-stormwater Discharges
The network of control measures in the EWMP Implementation Strategy will address both stormwater and non-stormwater discharges. As shown in Figure 7-25 and Figure 7-26, the EWMP Implementation Strategy achieves 100% elimination of non-stormwater flows by 2037. By 2028, most jurisdictions will have achieved greater than 80% reduction of non-stormwater flows. These volume reductions will address all pollutants including metals and bacteria. In addition, there are several components of the EWMP that provide an additional “margin of safety” that non-stormwater reductions will occur more rapidly than shown in Figures 7-22 and 7-23, as follows:

1. The non-stormwater screening, investigation and abatement programs being conducted under the CIMP for the ULAR EWMP Group will target “significant” outfalls and eliminate additional non-stormwater discharges. For example, during outfall monitoring conducted along Reach 2 and 4 of the LA River, the outfalls with top 10% of flow rates represented a majority of flow (more than 50%) from all outfalls along the reach (CREST, 2008). The nonstormwater programs provide additional assurance of addressing dry weather Water Quality Priorities.

2. The non-stormwater volumes in the non-stormwater simulation were based on existing median outdoor water use rates. Most water supply agencies including the City of Los Angeles Department of Water and Power have initiatives to significantly reduce outdoor water use in the coming years. Regional reductions in outdoor water provide additional assurance of addressing dry weather Water Quality Priorities.

Specific strategies for the metals and bacteria TMDLs are described in the following subsections.

Additionally, the EWMP Implementation Strategy includes the implementation of the MCMs, which are not only required by the Permit, but also address the Category 2 and 3 WBPCs identified in Table 3-7.

35 Recall that Section 6.3.3 describes the methodology of the dry weather RAA.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-30 Draft June 2015
Figure 7-25. Schedule for Eliminating Non-Stormwater Discharges in ULAR.

The figure shows the effect of the wet weather control measures in the EWMP Implementation Strategy on non-stormwater discharges in the Upper Los Angeles River watershed. Over time, the wet weather control measures will eliminate non-stormwater discharges. Note the y-axis differs by panel.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-31 Draft June 2015
Figure 7-26. Non-Stormwater Reductions by Wet Weather Control Measures in ULAR.

The figure shows the same reductions as Figure 7-25, except expressed as percent reduction from baseline. Over time, the wet weather control measures will eliminate non-stormwater discharges. The reductions are sufficient to achieve the dry weather milestones for the LA River Metals TMDL (75% attainment by 2020 and final compliance by 2024).

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-32 Draft June 2015

7.4.2 Dry Weather Strategy for Bacteria TMDL
The LA River Bacteria TMDL includes an innovative dry weather implementation process called a LRS.

The ULAR EWMP incorporates the LRS process as the dry weather strategy for addressing bacteria TMDL requirements. Because E. coli is the limiting dry weather pollutant, (Section 6.2.4), the LRS process will also address other dry weather Water Quality Priorities in the Upper LA River watershed.

As described in the Bacteria TMDL, each LA River segment and tributary is subject to a customized LRS that details the specific non-stormwater control measures to be implemented to achieve dry weather bacteria RWLs/WQBELs. Each LRS is based on outfall monitoring “snapshots”, Monte Carlo modeling and BMP design/feasibility considerations. The non-stormwater screening program under the CIMP for the ULAR EWMP Group is designed to collect the outfall monitoring data needed to develop Load Reduction Strategies. Through the LRS, two types of outfalls are identified for implementation actions, as follows:
 Priority Outfalls – the LRS process highlights the Priority Outfalls because they consistently have the highest loading rates of E. coli. As such, Priority Outfalls are the highest priority for source abatement and are subject to specific implementation actions in the LRS.  Outlier Outfalls – the LRS process highlights Outlier Outfalls because they have episodic discharges that can lead to exceedances of the wasteload allocation. Outlier Outfalls are subject to follow-up investigations during LRS implementation.

The Bacteria TMDL includes phasing of LA River segments and tributaries, meaning that LRSs will be developed over the course of the TMDL compliance schedule, as shown in Table 7-1. To date, the LRS for Segment B of the LA River has been completed by the ULAR EWMP Group, and the LRSs for Arroyo Seco and Rio Hondo are underway, as described in the following subsections. As future LRSs are completed according to the TMDL schedule and the ULAR EWMP is updated through the adaptive management process required by the Permit, the EWMP will incorporate the non-stormwater control measures identified for each LA River segment and tributary.

Table 7-1. Bacteria TMDL Schedule for LRS Submittal to Regional Board by ULAR EWMP Group LA River
Segment
Mainstem or Tributary TMDL Date for LRS Submittal
Segment B
Mainstem LA River Attached to this EWMP,
see Appendix 7.D.

Arroyo Seco and Rio Hondo March 2016
Segment A Compton Creek March 2018
Segment E
Mainstem LA River September 2017
Dry Canyon, McCoy Canyon,
Bell Creek and Aliso Canyon Wash September 2021
Segment C
Mainstem LA River September 2023
Tujunga Wash, Burbank Western
Channel and Verdugo Wash September 2023
Segment D
Mainstem LA River September 2023
Bull Creek September 2023

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-33 Draft June 2015

7.4.2.1 LRS for Segment B of the LA River
The ULAR EWMP Group’s LRS for Segment B of the LA River is attached to this EWMP as Appendix 7.D. The LRS identifies four Priority Outfalls and five Outlier Outfalls that will be subject to implementation actions and source investigations, respectively. The simulated effect of structural implementation actions at Priority Outfalls is shown in Figure 7-27. The drainage areas for these outfalls are shown in Figure 7-28. The LRS for the ULAR EWMP Group has identified specific structural control measures and has even developed specific conceptual designs for the Priority Outfalls, as summarized in Table 7-2. The LRS for Segment B provides a robust dry weather strategy for addressing bacteria TMDL requirements while simultaneously addressing other Water Quality Priorities.

Table 7-2. Control Measures identified by Load Reduction Strategy for Segment B of the LA River Nonstormwater Control
Measure Outfall ID Addressed Outfall Type Completion Schedule Lead Agency Humboldt Stormwater
Greenway Project R2-A
Priority
Outfalls
Already completed City of LA 1
Reuse and Removal
Urban Flow Systems R2-02 March 2019 City of LA 1
Infiltration wetland R2-04 March 2019 LA County 1
7 th Street Low Flow
Diversion R2-K Already completed City of LA 1
Source
Investigation and
abatement
R2-G
Outlier
Outfalls
March 2019 City of LA
R2-E March 2019 City of LA
R2-NEW-14 March 2019 LA County
R2-T March 2019 LA County
1 – Other ULAR agencies are responsible for supporting operations and maintenance.

Figure 7-27. Effect of Priority Outfall Actions on E. coli Loading to Segment B from ULAR EWMP Group

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-34 Draft June 2015
Figure 7-28. Drainage Areas for Priority and Outlier Outfalls in Segment B LRS by ULAR EWMP Group

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-35 Draft June 2015

7.4.2.2 LRS for Arroyo Seco and Rio Hondo
The ULAR EWMP Group has initiated the LRSs for Arroyo Seco and Rio Hondo, which are tributaries to Segment B. Both LRSs are due March 2016. For Rio Hondo, the Group is in process of collecting outfall monitoring snapshots. For Arroyo Seco, the City of Los Angeles has completed snapshots of outfalls within their jurisdictional area, and the Group has also begun collecting data from the jurisdictional areas upstream of the City of Los Angeles. The Arroyo Seco LRSs are not yet complete, and the ULAR EWMP Group may ultimately collaborate on a single LRS (rather than submitting two LRSs). The preliminary list of City of Los Angeles control measures for Arroyo Seco is shown in Table 7-3 and the drainage areas for the targeted outfalls are shown in Figure 7-29.

Table 7-3. Preliminary List of Control Measures identified by City of LA for Arroyo Seco LRS Nonstormwater Control
Measure
Outfall ID
Addressed Outfall Type Completion Schedule Lead Agency
Arroyo Seco Urban Runoff
Project No. 1 AS-15
Priority
Outfalls
September 2020 City of LA
Arroyo Seco Urban Runoff
Project No. 2 AS-21 September 2020 City of LA
Arroyo Seco Urban Runoff
Project No. 3 AS-17 OutlierOutfall
September 2020 City of LA
Note: subject to change once LRS is completed and submitted.

Figure 7-29. Drainage Areas for Preliminary Priority and Outlier Outfalls in City of LA Jurisdictional Area in Arroyo Seco Watershed

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-36 Draft June 2015

7.4.3 Dry Weather Strategy for Metals TMDL and Category 2/3 RWLs The final dry weather compliance date for the LA River Metals TMDL is January 11, 2024 (see Section 3). The EWMP Implementation Strategy clearly addresses the dry weather RWLs of the metals TMDL as well as all other dry weather Category 2 and 3 WBPCs identified in Table 3-7 because during dry weather, exceedances of metals RWLs are relatively rare, as described in Section 6.5.4. As such, existing MCMs and control measures have reasonable assurance of attaining dry weather metals RWLs (see Table 6-6) and represent the implementation actions required under this EWMP to comply with the TMDL requirements and receiving water limitations provisions of the Permit.

Additionally, the following components of the EWMP Implementation Strategy will further support protecting water quality during dry weather conditions:

1. For most ULAR jurisdictions, the wet weather control measures in the EWMP Implementation Strategy will achieve greater than 50% reduction in non-stormwater flows by 2024 (see Figure 7-24). This will result in a relatively large reduction in dry weather loading of all pollutants including metals, providing an additional margin of safety for achieving dry weather metals RWLs.

2. The additional reductions in non-stormwater flows and dry weather metals loading provided by bacteria TMDL Load Reduction Strategies, non-stormwater abatement programs and outdoor water use reductions (as described in the previous subsection 7.4.1) provide an additional margin of safety for achieving dry weather metals RWLs.

3. The non-stormwater volumes in the non-stormwater simulation were based on existing median outdoor water use rates. Most water supply agencies including the City of Los Angeles Department of Water and Power have initiatives to significantly reduce outdoor water use in the coming years. Regional reductions in outdoor water provide additional assurance of addressing dry weather Water Quality Priorities.

Combined, these components demonstrate the EWMP includes a robust non-stormwater control strategy for achieving dry weather metals and Category 2 and 3 RWLs.

7.5 Which Institutional Control Measures are included in the EWMP?
The MS4 Permit requires extensive programs for institutional control measures, referred to as MCMs.

The “default” MCMs in the Permit are an important element of the EWMP Implementation Strategy36 for the ULAR EWMP Group. See Section 5.6 for a comparison of the 2001 and 2012 MCM requirements. The MCMs in the 2012 Permit represent a significant increase in effort compared to the 2001 Permit. These default MCMs provide the foundation for the EWMP. Additionally, Category 2 and 3 WBPCs, which have very low exceedance frequencies, will be addressed by MCMs and associated control measures. However, the MCMs may need to be modified to specifically target low exceeding pollutants if exceedances are seen subsequent to full implementation of the MCMs identified in the MS4 Permit.

36 The RAA assumed a 5% reduction in pollutants due to implementation of default MCMs required in the Permit.

The MCMs in the 2012 Permit are significantly enhanced from those in the 2001 Permit, and thus a 5% reduction is a reasonable (likely conservatively low) estimate of MCM performance.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-37 Draft June 2015
In addition, several of the ULAR EWMP agencies have identified additional institutional control measures37 as a component of their EWMP Implementation Strategy. The additional institutional control measures to be implemented are detailed in Table 7-4 along with a schedule for completion.

As the EWMP is implemented, Group members may identify additional institutional control measures (for additional jurisdictions) that may offset the need for some of the structural control measures identified in the EWMP Implementation Strategy; if so, the EWMP will be updated during the adaptive management process (described in Section 8).

Table 7-4. Additional Institutional Control Measures to be Implemented by Select ULAR Agencies Agency
Additional
Institutional
Control Measures
to be Implemented Description
Schedule for
Completion
Burbank Enhanced street
sweeping program
Burbank upgraded the fleet of street sweepers to more
efficient sweepers as well as increased the number of street miles swept by including alleys as part of the sweeping routes. See Appendix 7D.

In Effect
Temple City Small Site LID
The Temple City LID Ordinance requires for residential and industrial projects below the MS4 Permit threshold, requiring projects with 500 square feet or more of soil disturbance to incorporate LID BMPs into the project design.

This ordinance will result in a significant reduction in stormwater pollution.

In Effect
• Temple City
• South
Pasadena
• Glendale
Train staff to
facilitate LID and
Green Streets
implementation
Conduct training for relevant staff in LID and Green Streets implementation prior to the onset of the programs. The
elements of the training follow the provisions listed in MS4 Permit §VI.D.7. Additionally, the agency will educate
governing bodies in LID and Green Streets implementation.

Ongoing
• Temple City
• South
Pasadena
• Glendale
Adopt Sewer System
Management Plan
(SSMP)
The agency is enrolled in the statewide Waste Discharge Requirements for Sanitary Sewer Systems, which required the development and implementation of a SSMP in mid2009. The goal of the SSMP is to reduce and prevent sanitary sewer overflows (SSOs), as well as mitigate any SSOs that do occur. This goal also addresses WQPs. Elements of the SSMP include:
• Sanitary sewer system operation and maintenance
program
• Design and performance provisions
• Overflow emergency response plan
• FOG Control Program
• System Evaluation and Capacity Assurance Plan
Following these SSMP elements will address WQPs.

Ongoing
• Temple City
• South
Pasadena
• Glendale
Prepare guidance
documents to aid
implementation of
MS4 Permit MCMs
Documents will be developed to address two issues: 1) the MS4 Permit introduces many new and enhanced MCM
provisions that do not have preexisting guidance
documentation and 2) the model Stormwater Quality
Management Program (SQMP) – which was required in the
prior LA MS4 Permit and served as a guide to permit
implementation – is now obsolete. Unlike the SQMP, the
Agencies are not bound to the guidance and forms provided.

They are provided as a resource to improve the effectiveness of the Jurisdictional Stormwater Management Plans.

June 2015

37 The RAA assumed a total 10% reduction in pollutants due to implementation of the default MCMs and the additional institutional control measures identified by the jurisdictions.

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Section 7  Detailed EWMP Implementation Strategy and Compliance Schedule Upper LA River EWMP 7-38 Draft June 2015
Table 7-4. Additional Institutional Control Measures to be Implemented by Select ULAR Agencies Agency
Additional
Institutional
Control Measures
to be Implemented Description
Schedule for
Completion
South Pasadena
Incentives for
irrigation reduction
practices
Provide incentives such as rebates for irrigation reduction (i.e. runoff reduction) practices such as xeriscaping and turf conversion.

South Pasadena is currently involved in this effort through the Metropolitan Water District’s water conservation rebate program.

Ongoing
South Pasadena
Encourage
retrofitting of
downspouts
(downspout
disconnect)
Encourage owners/operators of existing developments to
disconnect existing downspouts from the MS4.

Ongoing
South Pasadena
Refocused outreach
to target audiences
and water quality
priorities
Within the Public Information and Education Program,
elements such as material use/development and
advertisements will address WQPs. The development of this effort will be ongoing throughout the MS4 Permit term.

Ongoing

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Upper LA River EWMP 8-1 Draft June 2015
Section 8
Compliance Determination and Adaptive
Management Framework
At its core, the EWMP is a regulatory document to support compliance determination with the MS4 Permit, and over time the EWMP will be adapted to become more effective as new program elements are implemented, regulations change and additional information and data are gathered. This section discusses the anticipated approach to compliance determination and discusses key elements of adaptive management. Adaptive management is a critical component of the EWMP implementation process, as the EWMP looks forward 22 years (to 2037) and watershed conditions, stormwater science and water quality regulations will certainly change over the coming decades. Over time, monitoring data collected by the CIMP will provide information on water quality conditions and the effectiveness of control measures, which can be compared to predictions by the RAA. In addition, EWMP members will update their EWMP Implementation Strategy based on new identified opportunities (e.g., identifying a newly available public parcel for a regional project) and/or lessons learned during control measure implementation (e.g., preferring one type of control measure over another).

8.1 Compliance Determination
As described in Section 1.2, the EWMP is a regulatory document that supports compliance determination through an optional compliance pathway for the MS4 Permit Without an EWMP, compliance determination would be based on comparison of monitoring data collected by the CIMP to RWLs and/or WQBELs. By developing and implementing an approved EWMP, the ULAR EWMP Group is provided another pathway for compliance determination. However, it is important to note the EWMP Implementation Strategy is not a standalone compliance requirement; determination of compliance always starts with review of receiving water monitoring data. If RWLs are not achieved, then compliance determination considers outfall monitoring data. Furthermore, areas that are addressed by a regional project that retains the 85th percentile, 24-hour storm are individually compliant with all RWLs and WQBELs of the Permit. Finally, if RWLs and WQBELs are not achieved and runoff is not addressed through retention of the 85th percentile 24-hour storm, then compliance determination is based on whether the control Compliance Targets and/or control measures in the EWMP Implementation Strategy have been achieved/implemented per the compliance schedule. 38 As outlined in Table 8-1, compliance should be determined separately for each constituent and condition (wet or dry). While the limiting pollutant analysis determined the control measures that will address all pollutants, it is not necessary to fully control zinc and E. coli to address the other Water Quality Priorities. For example, exceedances of metals during dry weather are rare and thus MCMs and associated control measures have reasonable assurance of attaining metals RWLs during dry weather. Similarly, for Category 2 and 3 WBPC, which also have very low exceedance frequencies

38 See Section 7.1 for description of Compliance Targets, which are expressed in terms of the volume of stormwater runoff managed during a 24-hour period under the critical condition. Compliance Targets for each jurisdiction and assessment area / watershed are detailed in Appendix 7.A (final compliance) and Appendix 7.C (scheduling for milestones). For compliance with dry weather RWLs, the non-stormwater control measures described in Section 7.4 are used for compliance determination.

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Section 8  Compliance Determination and Adaptive Management Framework Upper LA River EWMP 8-2 Draft June 2015
(identified in Table 3-7), MCMs and associated control measures have reasonable assurance of attaining RWLs during dry weather. As such, if exceedances of metals during dry weather or exceedances of Category 3 WBPCs identified in Table 3-7 occur during EWMP implementation, then compliance determination should not be based on the status of implementation of zinc and E. coli control measures. Instead, compliance determination should be based on evaluation of whether the existing level of implementation for MCMs and control measures (as of June 2015) has been maintained and adapted, if necessary, to meet final limitations.

An important element of the current Permit provisions is that determination of compliance with final limits of Regional Board adopted TMDLs (see Table 3-1) does not consider whether the EWMP Implementation Strategy has been completed; instead compliance determination is solely based on review of receiving water and outfall monitoring data. However, given rigor by which the EWMPs have been developed, there is optimism that future iterations of the Permit will add compliance with final limits (not just interim) as a component of EWMP compliance determination (as discussed in the Permit Fact Sheet).

Table 8-1. EWMP Control Measures to be Assessed for Compliance Determination with ULAR EWMP if RWLs and WQBELs are not Attained per the Timelines Prescribed in the Permit and EWMP Weather
Condition Pollutant
Control Measures to be Evaluated for BMP-based
Compliance
Milestones and
Implementation
Schedule
Wet
weather
Copper and Zinc Control Measures detailed in Appendix 7A and 7C Table 3-1 and
Appendix 7C E. coli Control Measures detailed in Appendix 7A and 7C Toxics Control Measures detailed in Appendix 7A and 7C
Category 2 pollutants MCMs in 2012 MS4 Permit and modifications made during adaptive management, as needed.

See Table 3-5 and
Category 3 pollutants Table 3-7
Dry
weather
Copper and Zinc
MCMs in 2012 MS4 Permit and modifications made during
adaptive management, as needed. Also, Implementation
of non-stormwater abatement program in CIMP
See Table 3-1
E. coli Load Reduction Strategy control measures See Table 3-2 Category 2 pollutants MCMs in 2012 MS4 Permit and modifications made during adaptive management, as needed. Also, Implementation
of non-stormwater abatement program in CIMP
See Table 3-5 and
Category 3 pollutants Table 3-7

8.2 Adaptive Management Framework
The Permit specifies the adaptive management process will be revisited every two years to evaluate the EWMP and update the program as necessary. Part VI.C.8 of the Permit identifies the adaptive management process as follows:
i. Permittees shall implement an adaptive management process, every two years, adapting the EWMP to become more effective, based on, but not limited to a consideration of the following:
1) Progress toward achieving interim and/or final WQBELs and/or RWLs. 2) Achievement of interim milestones.
3) Re-evaluation of Water Quality Priorities and source assessment.

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Section 8  Compliance Determination and Adaptive Management Framework Upper LA River EWMP 8-3 Draft June 2015
4) Availability of new information other than the Permittees’ monitoring program 5) Regional Water Board recommendations; and
6) Recommendations through a public participation process ii. Based on the results of the adaptive management process, Permittees shall report any modifications necessary to improve the effectiveness of the EWMP in the Annual Report. iii. Permittees shall implement any modifications to the EWMP upon approval by the Regional Board or within 60 days of submittal if the Regional Board expresses no objections.

The EWMP adaptive management process will incorporate new monitoring data collected through implementation of the CIMP or other programs, experience gained from BMP implementation, and/or changes to the water quality standards (i.e., beneficial uses or WQBELs and/or RWLs). For example, the EWMP includes a robust adaptive management program that will continue to identify and prioritize the best locations, sizes, and types of BMPs for pollutant reduction. Over time, if additional parcels are identified that could provide cost-effective opportunities for implementing regional projects (e.g., school district properties), then regional projects would make up an even larger component of the EWMP. The adaptive management process will also define modifications necessary to improve the effectiveness of the EWMP in order to achieve compliance targets. Key factors to be considered during the adaptive management process are described below.

8.2.1 Updates to Water Quality Priorities
A key consideration of the adaptive management process of the Permit is part i.3, the re-evaluation of Water Quality Priorities. The ULAR EWMP Group envisions that the EWMP, CIMP, and special studies will lead to revisions to the Water Quality Priorities through Basin Planning in the coming years.

Examples of these revisions include the following:
 Updates to TMDL implementation schedules – the pace of control measure implementation required by TMDLs in the LA River watershed is rapid, far above corresponding funding that is available for stormwater programs. The 31% milestone for the LA River Metals TMDL is especially problematic given its short timeframe (2017). The timelines for design, construction and permitting of BMPs are typically longer than two years. While the Group plans to implement projects in the near-term, the TMDL schedules for near-term milestones could be adjusted to reflect realistic construction schedules while still ensuring that commitments are made to achieving continuous incremental improvements in water quality.  Revisions to Water Quality Objectives – through special studies and regulatory updates, RWLs (and water quality objectives) can be improved to incorporate the most recent scientific information and/or site-specific data. As an example, an updated RWL for copper in the LA River is in the process of being adopted by the Regional Board to reflect the findings of a sitespecific objective study. Similar studies could be conducted for the limiting pollutants zinc and bacteria. For zinc, a water effects ratio could be considered for the LA River and its tributaries.

For bacteria, federal regulations include a process for developing site-specific RWLs based on alternative indicators and/or risk assessment. The RWLs for other pollutants could also be updated as regulations are updated by the Regional Board and State Board to reflect the best available science and/or scientific studies are conducted to support Basin Plan Amendments.

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Section 8  Compliance Determination and Adaptive Management Framework Upper LA River EWMP 8-4 Draft June 2015
 Updates to beneficial uses– for some Water Quality Priorities, the designated beneficial uses in the Basin Plan could be updated based on up-to-date use information. As an example, the State Board is considering updates to statewide water quality objectives for bacteria, including an expanded application of the High Flow Suspension (HFS) to non-engineered channels. The Basin Plan currently only applies to the HFS to beneficial uses for engineered channels.

Currently, Arroyo Seco and Compton Creek are excluded from the HFS because they were previously determined to be non-engineered (even though they are concrete channel for most of their length). Through the statewide update, the HFS could be expanded to these waterbodies, which would reduce the amount of regional projects on private land that are currently included in the EWMP Implementation Strategy.  Revisions to WQP categories – for some Water Quality Priorities, the pollutants will benefit from additional monitoring data collected by the CIMP. New monitoring data may allow for the re-characterization of receiving water and discharge quality within the ULAR EWMP area. The monitoring data may show changes in constituents exceeding applicable water quality objectives, resulting in potential updates to the categories. For example, pollutants may be delisted as control measures are implemented, or some pollutants may be demonstrated to be from non-MS4 sources.

The ULAR EWMP Group looks forward to closely working with the Regional Board and stakeholders on these and other revisions to the Water Quality Priorities.

8.2.2 Updates based on Review of Monitoring Data
Monitoring data gathered from the CIMP or other monitoring programs (e.g., specific studies) on receiving water conditions and stormwater/non-stormwater quality will support adaptive management at multiple levels. This information will be tied into the EWMP as feedback for the water quality changes resulting from control measures implemented by the ULAR EWMP Group. For example, the data could show the required reductions are less than anticipated which would could eventually lead to reduced capacities of control measures in the EWMP Implementation Strategy.

An Integrated Monitoring Compliance Report will be provided as part of the Annual Report that summarizes all identified exceedances of (1) outfall-based stormwater monitoring data, (2) wet weather receiving water monitoring data, (3) dry weather receiving water data, and (4) nonstormwater outfall monitoring data against all applicable WQBELs, RWLs, non-stormwater action levels, and aquatic toxicity thresholds. An effectiveness assessment of stormwater and nonstormwater control measures will be conducted as to whether the quality of discharges is improving, staying the same or declining.

8.2.3 Updates to RAA Model Parameters
Over time, the parameters in the watershed and BMP models used for the RAA may be updated based on newly available data. For example, as additional control measures are implemented in LA County, new data may become available regarding performance of control measures for reduction pollutants.

In turn, the performance metrics in the RAA could be updated. Other types of data that could support RAA updates include soil infiltration data, revised catchment delineations, modified operations to impoundments / reservoirs, and major changes to the quality or volume of effluent discharges from publicly owned treatment works.

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Section 8  Compliance Determination and Adaptive Management Framework Upper LA River EWMP 8-5 Draft June 2015

8.2.4 Updates to Preferences for Control Measure Implementation Over the course of EWMP implementation, Group members have the flexibility to substitute different types of control measures based on lessons learned that affect preferences for implementing certain BMPs. As long as the Compliance Targets are achieved (i.e., specified volumes of stormwater are managed), the type of control measure implemented does not affect compliance determination. As the EWMP is implemented over time, it is expected that refined strategies will identify a different suite of opportunities or different BMP designs from that which was assumed for the RAA. It will, therefore, be important to track BMP implementation so adjustments can be made when checking progress towards achieving Compliance Targets. To illustrate how control measure preferences could be modified during adaptive management, an example is described below and illustrated in Figure 8-1.

In Figure 8-1, the “recipe for compliance” is split to emphasize that the Compliance Targets (on the left-hand side) are the primary BMP performance goals, whereas the control measures (on the righthand side) are subject to adaptive management. The objective is for each Group member to meet the Compliance Target (left-hand side) and management a certain amount of runoff in a 24-hour period with a suite of BMPs. The right-hand side represents the control measures identified by the RAA based on the assumptions described in Section 6. However, over time, the EWMP Implementation Strategy will be adjusted. In some cases, it may be possible to use alternative control measures or designs in such a way that the overall constructed size (and associated cost) of the suite of BMPs is reduced.

Three scenarios to consider as examples are provided below:
 Scenario 1: the EWMP Implementation Strategy currently identifies 2.12 acre-feet of storage necessary for green streets. Consider a hypothetical example scenario where a street-scale analysis reveals that an additional 3 acre-feet of high-efficiency green street opportunities exist in the subwatershed, bringing the total green street implementation to 5.12 acre-feet. The Scenario 1 row in Figure 8-1 demonstrates how this additional green street capacity can offset the need for other BMPs in the subwatershed; in this case, regional capacity on private parcels for bacteria compliance. It is important to realize, however, that a 1:1 exchange of BMP capacities between different types of control measures is not appropriate (e.g., in Scenario 1, the green street capacity increases by 3 acre-feet, but regional capacity on public land is reduced by only 2.5 acre-feet). Exchange of control measure capacity is not 1:1 because (1) green streets perform differently than regional BMPs, (2) the BMPs treat different land uses, and (3) the BMPs experience different infiltration rates. Adaptive management will therefore require some type of ”equivalency” demonstration to maintain reasonable assurance that the revised control measures will achieve the compliance goals on the left-hand side of the table.  Scenario 2: this scenario demonstrates an example where residential LID programs progress at five times the pace assumed in the RAA. In this case, the Group member was able to achieve an adoption rate of 5% of residential parcels per year versus the 1% assumed by the RAA. The additional residential LID offsets the remaining 0.42 acre-feet of capacity for bacteria compliance in lieu of constructing regional BMPs on private parcels, and also offsets LID on public parcels. Note the substitution of regional LID requires more total control measure capacity (because regional projects located at the outfall are more efficient for removing pollutants), but the total cost would likely be far lower.  Scenario 3: this scenario consider a situation where - instead of the previous two scenarios – a private parcel is acquired at the outlet of the subwatershed. Assuming redevelopment and residential LID will progress in the subwatershed regardless of other control measures, a

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Section 8  Compliance Determination and Adaptive Management Framework Upper LA River EWMP 8-6 Draft June 2015
regional project could be installed on the private parcel and optimized to satisfy the remaining compliance target runoff volume, eliminating the need for any other remaining BMPs in the subwatershed.

The above scenarios provide only a handful of examples where adaptive management would lead to adjustments of control measure capacities. It is anticipated that, over the course of implementation, agencies will continue to innovate, customize BMP configurations, and strategically locate BMP opportunities that will reduce the level of BMP implementation. It will be important to demonstrate equivalency as these adjustments are made to the EWMP Implementation Strategy.

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Section 8  Compliance Determination and Adaptive Management Framework Upper LA River EWMP 8-7 Draft June 2015

COMPLIANCE
TARGETS:

BMP PERFORMANCE
GOAL
EWMP IMPLEMENTATION PLAN:

APPROACH TO ACHIEVE COMPLIANCE TARGETS,

SUBJECT TO ADAPTIVE MANAGEMENT
(BMP capacity expressed in units of acre-feet)
For Metals
by 2028
For
Bacteria
by 2037
For Metals Attainment by 2028 For Bacteria
Attainment by 2037
24-hour Volume Retained (acre-ft)Additional 24-hour Volume to be Retained (acre-ft) % Load ReductionCritical Condition
Low-Impact Development Streets Regional BMPs
Total BMP Capacity (acre-ft)
Regional
BMPs
(private)
Total
BMP
Capacity
Ordinance
(acre-ft)
Planned LIDPublic LIDResidential LIDGreen StreetsVery High(public, owned)High(public, owned)Medium (public, non-owned)Private

4.83 2.92 37% 0.16 0.04 0.13 0.23 2.12 0 0 0 0 2.7 2.92 5.6 Scenario 1: 37% 0.16 0.04 0.13 0.23 5.12 0 0 0 0 5.7 0.42 6.1 Scenario 2: 37% 0.16 0.04 -- 1.15 5.12 0 0 0 0 6.5 -- 6.5 Scenario 3: 37% 0.16 0.04 -- 0.23 -- 0 0 0 5 5.4 -- 5.4 Figure 8-1. Hypothetical Alternative Control Measure Scenarios to Attain Compliance Targets Adaptive Management: Burden Transferred from Regional Projects to Newly Identified High-Efficiency Green Street Opportunities Adaptive Management: Remaining Capacities for Bacteria
and Public LID are offset by Residential LID
Adaptive Management: Regional BMP Located at Subwatershed Outlet Manages Remaining Runoff to Achieve Compliance Target
(Current Fixed Goal) (Flexible)

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Section 8  Compliance Determination and Adaptive Management Framework Upper LA River EWMP 8-8 Draft June 2015

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Upper LA River EWMP 9-1 Draft June 2015
Section 9
EWMP Implementation Costs and Financial
Strategy
The purpose of this section is to present costs for constructing, operating and maintaining the control measures in the EWMP Implementation Strategy, along with the financial strategy for addressing those costs. For the purposes of the EWMP, the financial strategy is defined as the strategic options available to the Group members for financing the program costs associated with the MS4 Permit. The section provides an overview of the following components of the EWMP financial strategy:
 Estimates of costs to construct, operate and maintain control measures (9.1);  Assessment of existing stormwater program costs and funding sources (9.2); and  Identification of financial strategies for financing program costs (9.3).

9.1 EWMP Implementation Costs
The purpose of this section is to present the order-of-magnitude cost estimates for the EWMP Implementation Strategy. The estimated program costs were developed using the methodology described in Section 6.3.3. The general approach for cost estimate is based on “cost functions” that describe cost as a function of BMP size parameters (volume, depth, area, etc.). Details on the cost function methodology is provided in the documentation for the WMMS model (http://dpw.lacounty.gov/wmd/wmms/res.aspx). The cost functions used for this EWMP are presented in Table 9-1, which have been updated from those in the original WMMS39. The cost functions are based on generic, modular cost functions developed specifically for LA County. The cost functions40 encompass planning, design, permits, construction, O&M, and post-construction inspection, where applicable. Cost estimates are applicable only for the modeled BMP configurations specified in Section 6 and Appendix 6.D. Note that costs do not account for inflation, interest, or timevalue of money.

The costs for structural BMPs provided here are considered to be planning level only (order of magnitude), and can be refined as EWMP implementations progresses with the use of actual BMP implementation costs. Costs for enhanced MCMs and other institutional BMPs have not been included here and are in addition to the Capital and O&M costs.

39 The O&M cost estimates were further refined based on interviews with municipal maintenance staff in Southern California (City of San Diego and Tetra Tech, 2011; Caltrans, City of La Mesa, City of Lemon Grove, City of San Diego, County of San Diego, and Unified Port of San Diego, 2013). Routine maintenance was assumed to occur annually, while intermittent maintenance activities were assume to occur every four years. Replacement costs were not considered under the assumption that systems will be properly maintained and functional throughout and beyond the implementation schedule.
40 While the cost functions in Section 6 were based on 20-year costs, this section separates the annual O&M costs from the capital costs to allow for cost estimates over time. For the RAA cost optimization, 20-year costs were used to ensure that O&M costs were considered when deeming a BMP scenario to be cost-effective.

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Section 9  EWMP Implementation Costs and Financial Strategy Upper LA River EWMP 9-2 Draft June 2015
Table 9-1. Summary of Annualized BMP Cost Estimation Formulas BMP
Category BMP Types
Formulas For Estimating Total Costs 1
Capital Costs Annual O&M
LID and
Green
Streets
Bioretention with Underdrain Cost = 17.688 (A) + 2.165 (Vt) + 2.64 (Vm) + 3.3 (Vu) Cost = 2.54 (A)
Bioretention without Underdrain Cost = 9.438 (A) + 2.165 (Vt) +

2.64 (Vm) Cost = 2.54 (A)
Residential LID Cost = 4.000 (A) --
Permeable Pavement with
Underdrain Cost = 33.594 (A) + 3.3 (Vu) Cost = 1.74 (A) Permeable Pavement without
Underdrain Cost = 25.344 (A) Cost = 1.74 (A)
Regional
BMPs
Pump Cost = 56,227*(Pump Capacitycfs) + $1,207,7362
Regional Project on Public Parcel Cost = 10.01 (A) + 2.296 (Vt) +

2.8 (Vm) Cost = 1.918 (A)
Regional Project on Private Parcel Cost = 139.01 (A) + 2.296 (Vt) + 2.8 (Vm) Cost = 1.918 (A)
1 – Formulas describe annualized life cycle costs including routine and intermittent O&M using the following variables: (A) is the area of the BMP footprint in square feet, (Vt) is the total volume of the BMP in cubic feet, (Vm) is the volume of the BMP soil media in cubic feet, and (Vu) is the volume of the BMP underdrain in cubic feet. 2 – The resolution of WMMS output precludes the certain estimation of pump station quantity and capacity. Note that incidental costs associated with pump station operation will likely be incurred during implementation.

9.1.1 EWMP Implementation Costs by Control Measure Type and EWMP/TMDL Milestones
The total estimated costs for all control measures in the EWMP Implementation Strategy (LID, Green Streets, and Regional) are shown in Table 9-2. The capital and O&M costs are reported for the same milestones detailed in the EWMP Implementation Strategy. The implementation cost schedule relies on initial capital costs to achieve the control measure capacities at the milestone year, and then recurring annual O&M costs are accumulated over the compliance time frame.

Table 9-2. Total Costs by Milestone for each ULAR EWMP Group member ($ millions)1 Agency Program
Present to 31%
Metals TMDL
Milestone (2017)
31% Metals TMDL
Milestone (2017)
to 50% Metals
TMDL Milestone
(2024)
50% Metals TMDL
Milestone (2024) to
Final Compliance
with Metals TMDL
(2028)
50% Metals TMDL
Milestone (2024) to
Final Compliance
with Bacteria TMDL
(2037)
Total at Final
Capital O&M/yr Capital O&M/yr Capital O&M/yr Capital O&M/yr Capital O&M/yr Alhambra
LID 0.08

1.19 0.36

3.17 0.73

6.52 0.00

7.18 1.17

7.18 Streets 2.73 7.48 19.67 0.00 29.87
Regional 7.45 9.14 0.17 0.00 16.77
Private 0.00 0.00 62.80 49.86 112.66
Subtotal 10.26 16.97 83.37 49.86 160.47
Burbank
LID 0.19

0.30 1.38

1.74 4.28

6.55 0.00

7.84 5.86

7.84 Streets 1.45 7.45 22.18 0.00 31.08
Regional 0.83 3.26 2.02 0.00 6.11
Private 0.00 0.00 104.42 98.59 203.01

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Section 9  EWMP Implementation Costs and Financial Strategy Upper LA River EWMP 9-3 Draft June 2015
Table 9-2. Total Costs by Milestone for each ULAR EWMP Group member ($ millions)1 Agency Program
Present to 31%
Metals TMDL
Milestone (2017)
31% Metals TMDL
Milestone (2017)
to 50% Metals
TMDL Milestone
(2024)
50% Metals TMDL
Milestone (2024) to
Final Compliance
with Metals TMDL
(2028)
50% Metals TMDL
Milestone (2024) to
Final Compliance
with Bacteria TMDL
(2037)
Total at Final
Capital O&M/yr Capital O&M/yr Capital O&M/yr Capital O&M/yr Capital O&M/yr Subtotal 2.47 12.09 132.90 98.59 246.06
Calabasas
LID 0.29

0.14 0.11

0.44 0.20

1.60 0.00

1.69 0.61

1.69 Streets 0.41 0.29 0.38 0.00 1.08
Regional 0.72 0.02 0.00 0.00 0.74
Private 0.00 19.85 84.72 6.57 111.13
Subtotal 1.43 20.28 85.29 6.57 113.57
Glendale
LID 0.00

0.01 0.16

0.93 2.83

8.36 0.00

10.97 2.99

10.97 Streets 0.06 5.18 49.50 0.00 54.75
Regional 0.00 2.25 5.94 0.00 8.19
Private 0.00 0.05 28.94 198.26 227.25
Subtotal 0.06 7.64 87.21 198.26 293.17
Hidden
Hills
LID 0.00

0.05 0.00

0.10 0.00

0.15 0.00

0.15 0.00

0.15 Streets 0.00 0.03 0.02 0.00 0.06
Regional 0.00 0.00 0.00 0.00 0.00
Private 3.52 3.76 3.78 0.00 11.06
Subtotal 3.52 3.79 3.80 0.00 11.12
La Canada
Flintridge
LID 0.00

0.05 0.13

0.29 0.14

1.06 0.00

1.61 0.27

1.61 Streets 0.39 1.82 3.30 0.00 5.50
Regional 0.00 0.12 0.00 0.00 0.12
Private 0.00 0.05 27.41 41.53 68.99
Subtotal 0.39 2.13 30.84 41.53 74.89
Los
Angeles
LID 4.32

9.25 13.67

30.91 59.58

95.68 0.00
118.07

77.58 118.07
Streets 42.88 98.43 280.91 0.00 422.22
Regional 29.45 61.55 60.99 0.00 151.99
Private 14.26 100.88 1,349.46 1,703.14 3,167.74
Subtotal 90.91 274.54 1,750.94 1,703.14 3,819.52
Montebello
LID 0.48

0.49 0.83

1.22 3.76

4.44 0.00

5.26 5.07

5.26 Streets 2.07 3.11 15.54 0.00 20.72
Regional 1.59 2.48 3.60 0.00 7.67
Private 0.00 0.00 40.42 62.33 102.75
Subtotal 4.14 6.42 63.32 62.33 136.21
Monterey
Park
LID 0.02

0.37 0.03

1.09 0.12

3.94 0.00

4.41 0.16

4.41 Streets 1.83 3.22 13.84 0.00 18.89
Regional 1.42 3.08 3.30 0.00 7.80
Private 0.00 0.00 64.32 36.05 100.38
Subtotal 3.26 6.33 81.57 36.05 127.22
Pasadena
LID 1.04

1.49 1.44

3.38 11.03

11.45 0.00

12.48 13.51

12.48 Streets 5.61 8.25 41.64 0.00 55.49

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Section 9  EWMP Implementation Costs and Financial Strategy Upper LA River EWMP 9-4 Draft June 2015
Table 9-2. Total Costs by Milestone for each ULAR EWMP Group member ($ millions)1 Agency Program
Present to 31%
Metals TMDL
Milestone (2017)
31% Metals TMDL
Milestone (2017)
to 50% Metals
TMDL Milestone
(2024)
50% Metals TMDL
Milestone (2024) to
Final Compliance
with Metals TMDL
(2028)
50% Metals TMDL
Milestone (2024) to
Final Compliance
with Bacteria TMDL
(2037)
Total at Final
Capital O&M/yr Capital O&M/yr Capital O&M/yr Capital O&M/yr Capital O&M/yr Regional 5.86 6.34 6.33 0.00 18.53
Private 0.00 0.00 69.00 78.84 147.84
Subtotal 12.51 16.03 127.99 78.84 235.37
Rosemead
LID 0.13

0.46 0.28

1.44 0.31

3.36 0.00

3.76 0.72

3.76 Streets 3.24 7.46 9.04 0.00 19.74
Regional 0.40 0.26 0.00 0.00 0.66
Private 0.00 0.00 59.20 29.80 88.99
Subtotal 3.77 8.00 68.54 29.80 110.11
San
Fernando
LID 0.01

0.11 0.02

0.24 0.57

0.47 0.00

0.80 0.60

0.80 Streets 0.00 0.00 0.02 0.00 0.02
Regional 0.98 1.13 1.52 0.00 3.63
Private 0.00 0.00 0.00 25.40 25.40
Subtotal 0.99 1.15 2.11 25.40 29.65
San Gabriel
LID 0.08

0.37 0.23

1.06 0.35

2.99 0.00

3.32 0.66

3.32 Streets 2.38 4.74 11.54 0.00 18.66
Regional 0.61 0.77 0.10 0.00 1.49
Private 0.00 0.00 34.38 25.21 59.59
Subtotal 3.07 5.75 46.37 25.21 80.40
San Marino
LID 0.00

0.33 0.09

1.47 0.21

2.99 0.00

3.19 0.30

3.19 Streets 0.75 3.09 11.21 0.00 15.05
Regional 2.10 6.65 0.00 0.00 8.75
Private 0.00 0.00 8.44 15.16 23.60
Subtotal 2.85 9.82 19.87 15.16 47.70
South El
Monte2
LID 0.27

0.22 0.58

0.79 0.41

1.41 0.00

1.77 1.25

1.77 Streets 0.69 1.89 1.27 0.00 3.85
Regional 0.95 0.58 0.00 0.00 1.53
Private 0.00 15.28 31.02 27.51 73.81
Subtotal 1.91 18.32 32.70 27.51 80.44
South
Pasadena
LID 0.00

0.03 0.04

0.71 0.35

1.91 0.00

2.10 0.39

2.10 Streets 0.03 1.31 8.42 0.00 9.76
Regional 0.23 4.65 1.49 0.00 6.37
Private 0.00 0.00 1.63 14.94 16.57
Subtotal 0.25 6.00 11.90 14.94 33.09
Temple
City
LID 0.00

0.00 0.29

0.92 0.58

3.33 0.00

3.47 0.88

3.47 Streets 0.00 6.53 16.41 0.00 22.94
Regional 0.00 0.57 1.29 0.00 1.85
Private 0.00 0.00 10.55 11.34 21.89
Subtotal 0.00 7.39 28.83 11.34 47.56

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Section 9  EWMP Implementation Costs and Financial Strategy Upper LA River EWMP 9-5 Draft June 2015
Table 9-2. Total Costs by Milestone for each ULAR EWMP Group member ($ millions)1 Agency Program
Present to 31%
Metals TMDL
Milestone (2017)
31% Metals TMDL
Milestone (2017)
to 50% Metals
TMDL Milestone
(2024)
50% Metals TMDL
Milestone (2024) to
Final Compliance
with Metals TMDL
(2028)
50% Metals TMDL
Milestone (2024) to
Final Compliance
with Bacteria TMDL
(2037)
Total at Final
Capital O&M/yr Capital O&M/yr Capital O&M/yr Capital O&M/yr Capital O&M/yr Uninc. LA
County
LID 0.98

2.14 2.03

5.36 12.74

20.72 0.00

22.77 15.76

22.77 Streets 7.57 11.66 82.50 0.00 101.73
Regional 8.46 13.05 20.25 0.00 41.76
Private 9.96 9.24 116.45 156.40 292.07
Subtotal 26.98 35.98 231.95 156.40 451.31
Total 168.78 17.01 458.65 55.27 2,889.50 176.91 2,580.94 210.84 6,097.87 210.84 1 O&M costs for each milestone includes cost from previous milestone (i.e. the costs are cumulative) 2 Cost estimates for the City of South El Monte include only those portions draining to Rio Hondo. Costs for the portions of the City of South El Monte that drain to the San Gabriel River are presented in Appendix 1B.

9.1.2 EWMP Costs by Tributary Area
The EWMP costs are presented for each tributary/assessment area in Table 9-3.

Table 9-3 Total Costs for each Subwatershed in the ULAR EWMP Area ($ millions) (Part 1) Agency
Aliso Wash Arroyo Seco Bell Creek Browns Canyon Wash Bull Creek Capital O&M/yr Capital O&M/yr Capital O&M/yr Capital O&M/yr Capital O&M/yr Alhambra 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Burbank 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Calabasas 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Glendale 0.00 0.00 0.24 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hidden Hills 0.00 0.00 0.00 0.00 0.45 0.01 0.00 0.00 0.00 0.00 La Canada Flintridge 0.00 0.00 52.41 1.21 0.00 0.00 0.00 0.00 0.00 0.00 Los Angeles 242.13 7.29 22.08 2.18 72.92 1.46 169.72 3.64 225.91 7.33 Montebello 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Monterey Park 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Pasadena 0.00 0.00 26.03 1.36 0.00 0.00 0.00 0.00 0.00 0.00 Rosemead 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 San Fernando 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 San Gabriel 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 San Marino 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 South El Monte 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 South Pasadena 0.00 0.00 2.97 0.33 0.00 0.00 0.00 0.00 0.00 0.00 Temple City 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Uninc. LA County 8.52 0.11 18.30 1.25 1.27 0.02 16.83 0.22 6.10 0.54 Total 250.65 7.40 122.03 6.33 74.64 1.49 186.55 3.86 232.01 7.87

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Section 9  EWMP Implementation Costs and Financial Strategy Upper LA River EWMP 9-6 Draft June 2015
Table 9-3 Total Costs for each Watershed in the ULAR EWMP Area ($ millions) (Part 2) Agency
Burbank Western
Channel Compton Creek Los Angeles River—Below Sepulveda Basin Los Angeles River—
Above Sepulveda
Basin
McCoy-Dry Canyon
Creek
Capital O&M/yr Capital O&M/yr Capital O&M/yr Capital O&M/yr Capital O&M/yr Alhambra 0.00 0.00 0.00 0.00 38.50 0.75 0.00 0.00 0.00 0.00 Burbank 150.35 5.12 0.00 0.00 95.71 2.73 0.00 0.00 0.00 0.00 Calabasas 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 113.57 1.69 Glendale 3.22 0.13 0.00 0.00 142.49 5.92 0.00 0.00 0.00 0.00 Hidden Hills 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 10.67 0.14 La Canada Flintridge 0.00 0.00 0.00 0.00 0.16 0.00 0.00 0.00 0.00 0.00 Los Angeles 83.69 2.27 291.60 16.32 1,222.66 38.34 727.71 20.55 177.79 3.03 Montebello 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Monterey Park 0.00 0.00 0.00 0.00 11.26 0.31 0.00 0.00 0.00 0.00 Pasadena 0.00 0.00 0.00 0.00 2.48 0.09 0.00 0.00 0.00 0.00 Rosemead 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 San Fernando 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 San Gabriel 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 San Marino 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 South El Monte 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 South Pasadena 0.00 0.00 0.00 0.00 23.65 1.14 0.00 0.00 0.00 0.00 Temple City 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Uninc. LA County 0.00 0.00 125.13 8.54 102.41 3.55 17.25 0.23 14.39 0.19 Total 237.27 7.52 416.73 24.86 1,639.32 52.82 744.97 20.77 316.42 5.05

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Section 9  EWMP Implementation Costs and Financial Strategy Upper LA River EWMP 9-7 Draft June 2015
Table 9-3 Total Costs for each Watershed in the ULAR EWMP Area ($ millions) (Part 3) Agency
Rio Hondo Tujunga Wash Verdugo Wash Total at Final
Capital O&M/yr Capital O&M/yr Capital O&M/yr Capital O&M/yr Alhambra 121.97 6.42 0.00 0.00 0.00 0.00 160.47 7.18
Burbank 0.00 0.00 0.00 0.00 0.00 0.00 246.06 7.84
Calabasas 0.00 0.00 0.00 0.00 0.00 0.00 113.57 1.69
Glendale 0.00 0.00 0.00 0.00 147.21 4.91 293.17 10.97
Hidden Hills 0.00 0.00 0.00 0.00 0.00 0.00 11.12 0.15
La Canada Flintridge 0.00 0.00 0.00 0.00 22.32 0.39 74.89 1.61 Los Angeles 0.00 0.00 564.58 15.38 18.72 0.29 3,819.52 118.07 Montebello 136.21 5.26 0.00 0.00 0.00 0.00 136.21 5.26
Monterey Park 115.96 4.10 0.00 0.00 0.00 0.00 127.22 4.41 Pasadena 206.86 11.03 0.00 0.00 0.00 0.00 235.37 12.48
Rosemead 110.11 3.76 0.00 0.00 0.00 0.00 110.11 3.76
San Fernando 0.00 0.00 29.65 0.80 0.00 0.00 29.65 0.80
San Gabriel 80.40 3.32 0.00 0.00 0.00 0.00 80.40 3.32
San Marino 47.70 3.19 0.00 0.00 0.00 0.00 47.70 3.19
South El Monte 80.44 1.77 0.00 0.00 0.00 0.00 80.44 1.77 South Pasadena 6.47 0.64 0.00 0.00 0.00 0.00 33.09 2.10 Temple City 47.56 3.47 0.00 0.00 0.00 0.00 47.56 3.47
Uninc. LA County 97.90 6.52 5.64 0.15 37.57 1.46 451.31 22.77 Total 1,051.58 49.48 599.87 16.33 225.83 7.06 6,097.87 210.84

9.1.3 Unit Capital Costs by Parcel
The EWMP costs will have a significant impact on each jurisdiction. In determining the impact to each jurisdiction, it is possible to conduct a high-level calculation of dividing the capital costs by the number of parcels in the watershed. The estimate number of parcels in the ULAR EWMP area is 770,655. At a total capital cost of $5.80 billion (through 2037), the calculated unit capital cost is $7,913 per parcel. It should be noted that this is a very coarse metric. Parcels vary in size dramatically throughout the cities and the county, and ultimately costs will likely be developed relevant to parcel size, parcel imperviousness, and possibly other factors.

9.2 Existing Stormwater Program Costs and Funding
Sources
Each jurisdiction in the ULAR EWMP area has existing recurring costs associated with stormwater activities. Table 9-4 is a summary listing of existing costs and associated revenue source based on the results of a survey of Group members. It is assumed that the recurring costs will continue, and costs to implement the EWMP will be in addition to those costs. The Financial Strategy is focused on developing a set of options to address the expected additional costs, and does not address funding requirements for existing stormwater programs.

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Section 9  EWMP Implementation Costs and Financial Strategy Upper LA River EWMP 9-8 Draft June 2015
Table 9-4. Existing Stormwater Program Costs for ULAR EWMP Group Jurisdiction
Existing
Utility
Funding Source Description of Costs
Total Costs
(Yes/No) ($)
Alhambra No General Fund Management, O&M and
Capital ~$980k/yr
Burbank No Various Funding
Sources
Street Sweeping,
Inspections, Connections,
TMDLs, and O&M
~$3.8M/yr
Glendale No General and
Enterprise Funds
Management, O&M and
Capital ~$750k/yr
Los Angeles Yes Stormwater Fund
O&M and Capital, Planning,
Enforcement and
Monitoring
~$30M/yr
Montebello No Water Fund Management and Catch
Basin ~$120k/yr
Monterey Park No General
Fund/Grants
O&M, Street Sweeping and
Trash Collection ~$5.3M/yr
South Pasadena No General Fund Management, O&M and
Capital ~$250k/yr
Temple City No General Fund Management, O&M and
Capital ~$90k/yr
Unincorporated LA
County Yes General Fund
Management, Outreach,
inspection, enforcement,
monitoring
~80M/yr
(County wide)

9.3 Financial Strategies
The costs to implement the EWMP will require orders of magnitude increases in stormwater program funding. The capital and operating costs for EWMP control measures are large and will span decades.

Expenditures for the EWMP Implementation Strategy will need to be coordinated with other regional efforts to improve habitat, promote greenways and increase access to the LA River and its tributaries.

In order to garner community support for financing the costs, it will likely be necessary to quantify the multi-benefits of the LID, green streets and regional projects including improved aesthetics, increase recreational opportunity, water supply augmentation and climate change resiliency. The financial strategy to fund the LID, green streets and regional projects in the EWMP will require a coordinated, regional approach. It will be important for each jurisdiction to have the opportunity to customize the financial strategy to the preferences of its community. As such, the financial strategy presented in this EWMP outlines a set of multiple approaches that allows each jurisdiction to consider and select the strategies that best fit their specific preferences. The detailed financial strategy for EWMP costs will be highly dependent and vary by jurisdiction.

The following are high-level alternatives that can be examined for each jurisdiction or the entire EWMP Group. The alternatives are categorized by type. Acknowledgement is given to Stormwater Funding Options – Providing Sustainable Water Quality Funding in Los Angeles County, a report authored by Ken Farfsing and Richard Watson dated May 21, 2014.

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Section 9  EWMP Implementation Costs and Financial Strategy Upper LA River EWMP 9-9 Draft June 2015

9.3.1 Grants
The financial strategies associated with grants available to the EWMP Group include the following:

Description
Apply for grants through the recently passed Prop 1 – 2014 Water Bond. Over $400M is available for stormwater capture, IRWMP and urban creek restoration projects.

Apply for other grants (state and federal) for stormwater improvement, beach water quality improvement, and green infrastructure projects. (e.g. Prop. 84, CBI, etc.)

9.3.2 Fees and Charges
The financial strategies associated with fees and charges available to the EWMP Group include the following:

Description
Use existing revenue streams for stormwater/water supply/flood control projects to support stormwater quality projects AB 2403 – Use new state law to pass rate increase for stormwater projects that have a water supply benefit and minimize the Proposition 218 process.

Use revenue generated from a Stormwater Impact Fee (or “In-Lieu” Fee) to comply with LID ordinances to fund mitigation bank for regional projects.

Increase solid waste management fees to cover the cost of enhanced street sweeping and other measures to reduce trash for compliance with TMDLs.

Consider adopting water conservation fees that would provide funding for reducing irrigated runoff in order to both conserve groundwater and reduce dry weather pollution.

Continue to pursue a county-wide stormwater parcel tax initiative (modified after the 2012 Clean Water Clean Beaches Initiative). This could be tied to AB 2403 too.

Consider assessments on car rentals since some of the pollution in our waterways is from cars driven on local streets.

9.3.3 Legislative and Policy
The financial strategies available to the EWMP Group that require legislative or policy changes include the following:

Description
Develop stormwater retention credit trading market to use private equity.

Ask the Metropolitan Water District (MWD) of Southern California to reevaluate their approach for managing the Local Resource Program (LRP) to fund stormwater capture and use projects that offset the use of imported water supplies.

Adopt SB 485 to allow Los Angeles County Sanitation District to manage stormwater including collection of stormwater fees
Pursue pollutant source control legislation patterned after SB 346 that either limits pollutants of concerns in products (e.g. copper in brake pads, or zinc in tires) or assesses a fee on those products that can be used by local governments to mitigate those pollutants.

Form Special Assessment Districts and fees tailored to the Watershed Management Groups.

Explore the use of Enhanced Infrastructure Finance Districts tailored to the Watershed Management Group, as outlined in recently adopted (2014) California legislation SB628.
2014 Water Resources Reform and Development Act of 2014 (WRRDA). Various funding opportunities should be explored.

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Section 9  EWMP Implementation Costs and Financial Strategy Upper LA River EWMP 9-10 Draft June 2015

9.3.4 Future Steps
The financial strategies mentioned herein are options for funding sources, some or all of which will need to be implemented to develop a comprehensive financial solution. Future steps include:
 Development of public support for financial strategies through outreach efforts  Creation of inter-jurisdiction EWMP financial working group  Development of a more formal Stormwater Program Financial Plan which would typically include the following components:
- Implementation of New Fee or Charge;
- Establishment of New Enterprise Fund;
- Cash and Debt Financing;
- Operating and Capital Reserves;
- Cash Flow Modeling.

The EWMP Group as a whole, as well as individual Group members are currently prioritizing and selecting the specific financing strategies that best fit their needs.

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Upper LA River EWMP 10-1 Draft June 2015
Section 10
References
Agency for Toxic Substances and Disease Registry (ATSDR). (1995). Toxicological Profile for Polycyclic Aromatic Hydrocarbons (PAHs). Agency for Toxic Substances and Disease Registry, United States Department of Health and Human Services, Atlanta, Georgia.

Bay Area Clean Water Agencies (BACWA). (2008). Bay Area Clean Water Agencies’ Draft Dioxin Issue Paper: Expert Panel Response and Recommendations. Prepared by Bierman, V. J., Jr., Grubbs, G. H., and Linn, K. J.

California Regional Water Quality Control Board (RWQCB) (1998). Dioxin in the Bay Environment - A Review of the Environmental Concerns, Regulatory History, Current Status, and Possible Regulatory Options". Prepared by Gervason, R. and Tang, L., February 1998.

California Regional Water Quality Control Board (RWQCB) (2005). Calleguas Creek Watershed Organochlorine Pesticides and PCBs TMDL Technical Report. Prepared by Larry Walker Associates.

California State Water Resources Control Board (SWRCB) (2011). Total Maximum Daily Loads for Chlorpyrifos and Diazinon in Lower Salinas River Watershed in Monterey County, California.

Curren J., S. Bush, S. Ha, M.K. Stenstrom, S. Lau, I.H. Suffet. (2011). Identification of subwatershed sources for chlorinated pesticides and polychlorinated biphenyls in the Ballona Creek watershed. Science of the Total Environment 409: 2525–2533 Central Coast Regional Water Quality Control Board (CCRWQCB). 2006. Phase 6: Regulatory Action, Final Project Report, Total Maximum Daily Load for Nutrients and Dissolved Oxygen in Chorro Creek, San Luis Obispo County, California. July.

Central Valley Regional Water Quality Control Board (CVRWQCB). 2010. Sacramento – San Joaquin Delta Estuary TMDL for Methylmercury Staff Report. April.

City of LA. 2009a. Los Angeles River Watershed Bacteria TMDL Source Assessment. July.

Community Conservation Solutions. 2013. The Green Solution Project. Upper LA River Watershed, Phase III. December.

CREST Consulting Team. 2010. Los Angeles River Watershed Bacteria TMDL – Technical Report Section 3: Numeric Targets. Prepared for CREST (Cleaner Rivers Through Effective Stakeholder-Led TMDLs
District of Columbia Department of Health. 2003. Total Maximum Daily Loads (TMDLs) for Organics and Metals in the Anacostia River.

Donigian, A.S., and J.T. Love, 2003. Sediment Calibration Procedures and Guidelines for Watershed Modeling. Aqua Terra Consultants, Mountain View, California.

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Section 10  References
Upper LA River EWMP 10-2 Draft June 2015
Donigian, A.S., Jr. 2000. HSPF Training Workshop Handbook and CD. Lecture #19: Calibration and Verification Issues. Prepared for and presented to the U.S. Environmental Protection Agency, Office of Water, Office of Science and Technology, Washington, DC.

Donigian, A.S., Jr., J.C. Imhoff, B.R. Bicknell, and J.L. Kittle, Jr. 1984. Application Guide for Hydrological Simulation Program – FORTRAN (HSPF). EPA-600 / 3-84-965. U.S. Environmental Protection Agency, Environmental Research Laboratory, Athens, GA.

Gunther, A.J., Davis J.A., and Phillips, D.J.H. (1987). An assessment of the loading of toxic contaminants to the San Francisco Bay Delta. Technical Report. San Francisco Estuary Institute, Richmond, CA, USA.

Karlsson, Ulrika. 2006. Environmental levels of thallium – Influence of redox properties and anthropogenic sources. Orebro University.

LARWQCB (Los Angeles Regional Water Quality Control Board). 2002. Amendment to the Water Quality Control Plan for the Los Angeles Region to Incorporate Implementation Provisions for the Region’s Bacteria Objectives and to Incorporate a Wet-Weather Total Maximum Daily Load for Bacteria at Santa Monica Bay Beaches. Resolution No. 2003-10. December 12, 2002.

LACDPW. 2005. Los Angeles County 1994-2005 Integrated Receiving Water Impacts Report – Final Report. August.

LARWQCB. 2007. Watershed Management Initiative Chapter. December.

LARWQCB. 2010. Proposed Amendments to the Water Quality Control Plan – Los Angeles Region for the Santa Monica Bay Nearshore and Offshore Debris TMDL. October.

LACDPW. 2012b. Unified Annual Stormwater Report for the Los Angeles County Municipal Stormwater Permit No. CAS004001, 2011 - 2012. December.

LACDPW. 2011. Unified Annual Stormwater Report for the Los Angeles County Municipal Stormwater Permit No. CAS004001, 2010 - 2011. October.

Los Angeles County Department of Public Works (LACDPW). 2002. Los Angeles County 1994-2000 Integrated Receiving Water Impacts Report. Los Angeles, CA.

Los Angeles Regional Water Quality Control Board (LARWQCB). 2003. Total Maximum Daily Loads for Nitrogen Compounds and Related Effects. July.

Los Angeles County Department of Public Works (LACDPW). (2005). Integrated receiving water report. Los Angeles County Department of Public Works. Final Report August 2005.

Lumb, A.M., R.B. McCammon, and J.L. Kittle, Jr. 1994. User’s Manual for an Expert System (HSPEXP) for Calibration of the Hydrological Simulation Program – FORTRAN. Water-Resources Investigation Report 94-4168. U.S. Geological Survey, Reston, VA.

Maryland Department of Environment (MDE). 1999. Total Maximum Daily Load (TMDL) Documentation for Chlordane in Back River.

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Section 10  References
Upper LA River EWMP 10-3 Draft June 2015
National Pesticide Information Center (NPIC). (2011). Pesticide Fact Sheets – Chlorpyrifos. Available at: http://npic.orst.edu/npicfact.htm.

National Pesticide Information Center (NPIC). (2011a). Pesticide Fact Sheets – Diazinon. Available at:
http://npic.orst.edu/npicfact.htm.

New Jersey Department of Environment Protection (NJDEP). (2008). Pollution Minimization Plans and PCB Source Trackdown in Camden City.

Sabin, D.L., K. Maruya, W. Lao, D. Diehl, D. Tsukada, K.D. Stolzenbach, and K.C. Schiff. 2011. Air-Water Exchange of Organochlorine Compounds in Southern California.

San Francisco Bay Regional Water Quality Control Board (SFBRWQCB). 2006. Mercury in San Francisco Bay – Proposed Basin Plan Amendment and Staff Report for Revised Total Maximum Daily Load (TMDL) and Proposed Mercury Water Quality Objectives. August 1.

Sabin, L. and Schiff, K. (2004). Atmospheric concentrations of PAH, pesticides and other semi-volatile organic compounds in the Los Angeles coastal region. In Hallock D, Weisberg SB (eds.), Southern California Coastal Water Research Project Annual Report 2003-04. Westminster, CA, USA, pp 61–72.

Shen, J., A. Parker, and J. Riverson. 2004. A New Approach for a Windows-based Watershed Modeling System Based on a Database-supporting Architecture. Environmental Modeling and Software, July 2004.

State of Washington, Department of Ecology (SWDE). 2013. Salmon Creek Watershed Low Dissolved Oxygen and pH Characterization Study. March.

State Water Resources Control Board (SWRCB). 2010. Final California 2010 Integrated Report (303(d) List/305(b) Report). April.

Stein, E.D., K. Ackerman, and K. Schiff. 2003. Watershed-based Sources of Contaminants to San Pedro Bay and Marina del Rey: Patterns and Trends. Technical Report #413. Prepared for the Los Angeles Contaminated Sediments Task Force. Southern California Coastal Water Research Project, Westminster, California.

Stein, E.D. and L.L. Tiefenthaler. (2004). Characterization of dry weather metals and bacteria in Ballona Creek. Tech Report #427. Southern California Coastal Water Research Project. Westminster, CA.

Stein, E. D., Tiefenthaler, L., Schiff K (2006). “Watershed-Based Sources of Polycyclic Aromatic Hydrocarbons in Urban Storm Water”, Environmental Toxicology and Chemistry, Vol. 25, No. 2, 373–385.

Suffet, I.H. and M.K. Stenstrom. (1997). A Study of Pollutants from the Ballona Creek Watershed and Marina del Rey During Wet Weather Flow. Report prepared for the Santa Monica Bay Restoration Commission.

TDC Environmental LLC (2001). Screening Evaluation of Dioxins Pollution Prevention Options.

Prepared for the San Francisco Bay Area Dioxins Project.

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Section 10  References
Upper LA River EWMP 10-4 Draft June 2015
Tetra Tech and USEPA (U.S. Environmental Protection Agency). 2002. The Loading Simulation Program in C++ (LSPC) Watershed Modeling System – User’s Manual. Tetra Tech, Fairfax, VA, and U.S. Environmental Protection Agency, Washington, DC.

Tetra Tech. 2010a. Los Angeles County Watershed Model Configuration and Calibration—Part I:

Hydrology. Prepared for County of Los Angeles Department of Public Works, Watershed Management Division, Los Angeles County, CA, by Tetra Tech, Pasadena, CA.

Tetra Tech. 2010b. Los Angeles County Watershed Model Configuration and Calibration—Part II:

Water Quality. Prepared for County of Los Angeles Department of Public Works, Watershed Management Division, Los Angeles County, CA, by Tetra Tech, Pasadena, CA.

Tetra Tech. 2011. Evaluation of Water Quality Design Storms. Prepared for County of Los Angeles Department of Public Works, Watershed Management Division, Los Angeles County, CA, by Tetra Tech, Pasadena, CA.

United States Environmental Protection Agency (USEPA). 1999. Preliminary Data Summary of Urban Storm Water Best Management Practices. August.

University of Florida. (2012). Mercury Spills. Available at:
http://www.ehs.ufl.edu/programs/ih/mercury/
USEPA (U.S. Environmental Protection Agency). 2003. Fact Sheet: Loading Simulation Program in C++.

USEPA, Watershed and Water Quality Modeling Technical Support Center, Athens, GA.

Available at: http://www.epa.gov/athens/wwqtsc/LSPC.pdf USEPA and California RWQCB (2005). Total Maximum Daily Loads for Toxic Pollutants in Ballona Creek Estuary.

USEPA. (2011). PCB TMDL Handbook. Report Number EPA 841-R-11-006.

USEPA. (2012). Santa Monica Bay Total Maximum Daily Loads for DDTs and PCBs. By USEPA Region 9.

USEPA (2012a). Los Angeles Area Lakes Total Maximum Daily Loads for Nitrogen, Phosphorus, Mercury, Trash, Organochlorine Pesticides and PCBs. By USEPA Region 9.

USEPA. (2013). Dioxins in San Francisco Bay: Questions and Answers. Available at:
http://www.epa.gov/region9/water/dioxin/sfbay.html. By USEPA Region 9.

USEPA. (2013a). Integrated Risk Information System (IRIS). beta-Hexachlorocyclohexane (beta-HCH) Quickview (CASRN 319-85-7).

USEPA (U.S. Environmental Protection Agency). 2009. SUSTAIN—A Framework for Placement of Best Management Practices in Urban Watersheds to Protect Water Quality. EPA/600/R-09/095.

U.S. Environmental Protection Agency, Office of Research and Development, Edison, NJ.

USEPA. 2004. Total Maximum Daily Load Development for the Lower St. Johns River, Florida – Fecal Coliforms, Iron, Lead, Silver, Selenium. April.

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Section 10  References
Upper LA River EWMP 10-5 Draft June 2015
Van Metre, P. C., B. J. Mahler, M. Scoggins, and P. A. Hamilton. 2006. Parking Lot Sealcoat: A Major Source of Polycyclic Aromatic Hydrocarbons (PAHs) in Urban and Suburban Environments.

USGS Fact Sheet 2005-3147.

Wisconsin Department of Natural Resources (DNR). (2002). Problems Associated with bis(2- ethylhexyl)phthalate Detections in Groundwater Monitoring Wells. Publication WA 1011. Rev. 2002. Available at: http://dnr.wi.gov/files/pdf/pubs/wa/wa1011.pdf Young, D.R., D.J. McDermott and T.H. Heesen. 1973. Aerial fallout of DDT in southern California.

Bulletin of Environmental Contamination and Toxicology 16:604-611.

Zou, R., Liu, Y., Riverson, J., Parker, A. and S. Carter. 2010. A nonlinearity interval mapping scheme for efficient waste load allocation simulation-optimization analysis. Water Resources Research, August 2010.

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City of Hemet
City Council Meeting

STAFF REPORT
Meeting: City Council Meeting - Sep 10 2024
Department: Finance
Submitted by: Mark Prestwich, City Manager
Tiffany Barnett, Acting Administrative Services Director; ☐ Receive and File ☐ Consent Calendar ☒ Business Item ☐ Public Hearing TITLE:

Consideration of Appointments to the Hemet Community Land Trust RECOMMENDED ACTION:

It is respectfully recommended that the City Council:

Discuss and appoint candidates to the Hemet Community Land Trust to fill vacancies due to board member and staff changes.

BACKGROUND:

On November 3, 2009, the Hemet Community Land Trust (HCLT) was established as a nonprofit public benefit corporation. The specific purpose of the HCLT was to lessen the burden of government by assisting the City to ensure that its residents are able to secure affordable housing by, among other things, developing, constructing, financing, managing, acquiring, owning, selling, leasing, renting, subsidizing, and monitoring affordable single and multi-family housing.

On May 3, 2010, the HCLT Bylaws were established to outline the powers and duties of the Trust..

After the dissolution of Redevelopment Agency (RDA) in February 2012, and then the later reduction of the Housing Division within the City in 2016, the HCLT rarely has had business to conduct and the updating of board members has not been maintained as elections occur and employees transition.

ANALYSIS:

HCLT Section 5.3(b)(i) of the bylaws provides direction regarding the appointment of directors:
“…thereafter, the board shall be selected as follows: (i) two of the authorized directors shall be appointed by the city (City Directors) by a majority vote of the members of the city council of the city. The appointment may be accomplished by the delivery of written notice from the city's mayor or city manager, which notice shall be filed in the minute book of the corporation. Such appointment shall be effective upon the future date specified in the notice, or upon receipt by the

23.D

corporation if no future date is specified. city directors shall only serve during their term of office as a city councilmember and upon the expiration of such term or upon the councilmember's seat on the council being otherwise deemed vacant under the law, the city director's seat on the board shall also be deemed vacant.”
The City Manager has the authority to deliver the written notice that formalizes the appointment of the City Directors. However, the City Manager does not have the authority to appoint the board members independently. The actual decision to appoint these directors must come from a majority vote of the City Council.

DISCUSSION:

The last meeting held with the HCLT was held on July 24, 2018 at which time the following individuals were appointed to the board:
 Linda Krupa, Council Member
 Michael Perciful, Council Member
 Bruce Wallis, Board Member
 Lorena Rocha, Treasurer
 Clay James, Interim Secretary
The Council needs to vote on the appointment of three (3) board members.

1. Council Member

2. Council Member

3. At-Large Board Member
Under the City Manager's authority within the bylaws, they can appoint the Treasurer and Secretary.

STRATEGIC PLAN INTEGRATION:

GOAL FIVE: ORGANIZATIONAL EFFECTIVENESS
To identify the work needed inside the City organization to effectively provide services to the community and ensure financial stability.

Objective 1: Operate in a financially sustainable manner.

Objective 2: Evaluate existing practices to ensure continuity with industry best practices.

Objective 3: Provide Council with policies that are consistent while lessening liabilities.

Objective 4: Increase employee retention by training and creating a positive workplace.

Objective 5: Streamline fire prevention coordination efforts.

FISCAL IMPACT:

There is no fiscal impact associated with this item.

ATTACHMENT(S):

Hemet Community Land Trust Art of Incorp
Hemet Community Land Trust ByLaws

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it 3.251the

ENDORSED- FILED
intheol?ceoftheSecretaryofSIat oflhesteleofCalitomia e
ARTICLES OF INCORPORATION NOV23 2509
OF

HEMETCOMMUNITYLAND TRUST
I.

The name of this corporationis:HEMETCOMMUNITYLANDTRUST.

II.

A; ' This » corporation is a nonpro?t public bene?t corporation and is not organizedfor the private gain of any person. It is organizedunderthe CaliforniaNonpro?t Public Bene?t Corpora?onLaw for charitablepurposes.

B. The speci?c purpose of this corporation is to lessen the burdens of government by assisting the City of Hornet,California (the “City‘’) to ensure that itsresidentsare ableto secure affordablehousing by, among other things, developing, oonstructing, ?nancing, managing, acquiring, owning, selling, leasing, renting, subsidizing,and monitoring affordable single- and multifamily housing,anqui?ng realproperty for affordablehousing,and conductingor performing any ancillary or related activityin ?zrtheranceof the foregoing. Subject to Article ‘ IV.3 of these Articles,this corporationshall be permitted to conduct other lawful activities permittedunder the California Nonpro?t Public Bene?t CorporationLaw. . C. This corporation is formed for the bene?t of, and to carry out the pumoses of, the City by helping the City ensure that its residents are able to secure decent and affordable housing and thereby lessen the burdens of government Within the meaning of Section l.501(c)(3)—l(d)(2)of the Treasury Regulations, \
III.

The name in the State of Californiaof this corporation’sinitialagent for serviceof processis:

ERIC S. VAIL
Burke,Williams& Sorensen,LLP
2280Market Street, Suite30Q
Riverside,California92501

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IV.

A. This corporationis organizedexclusivelyfor charitablepurposeswithin the meaning of Section501(c)(3) of the InternalRevenue Code, or the correspondingsection of any ?rmr'efederaltax code. ' '
B. Notwithstanding any otherprovisionof these am'cles, this corporationshall not carry on any other activitiesnot permittedto be carriedon (i) by a corporationexempt from federalincome tax under Section501(c)(3) of the InternalRevenue Code, or the corresponding section of any fumre federaltax code, or (ii) by a amputation,contributionsto whichare deductible under Section 170(c)(2) of the InternalRevenue Code, or the correspondingsectionof any more federaltax code.

C. No substantialpart of the activitiesof this corporationshall consist of carryingon propaganda,or otherwiseattemptingto in?uence legislation,and this corporationshall not participateor intervene in any politicalcampaign(includingthe publishingor distributionof statements)on behalf of or in oppositionto any candidate for public o?iee. v.”
A. The property of this corporation is irrevocably dedicated to charitable purposesandno part of the net earnings or assets ofthis corporationshallinure to the bene?t of (or be distributableto) any directoror officer of this corporationor otherprivate person,except that this corporation shall be authorized and empowered to pay reasonablecompensationfor services renderedandto makepayments anddistributionsin furtheranceofits charitable purposes.

B. Upon the dissolutionor Windingup of this corporation,its assets remaining after payment, or provisionfor payment, of all debts and liabilitiesof this corporationshallbe distributedto the City for charitablepurposes. In the alternative,the City may designatea nonpro?t fund,foundationor corporationwhichis organized'andoperatedexclusivelyfor charitablepurposes and which has establishedits tax exempt’status under Section 501(c)(3) of the hrtemalRevenue Code, or the corresponding section of any We federaltaxcode,to receive such assets. In the event that the City does not accept any asset of this corporationon dissolutionor designate a recipient,then any such asset shall be distributedto a nonpro?tfund; foundation or corporation which is organizedand operatedexclusively for charitablepurposesand whichhas establishedits tax exempt status under Section 501(c)(3) of the InternalRevenue Code, or the corresponding sectionof any future federaltax code.

Eric S. Vail, lncorporator
Dated:November3, 2009.

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STATE OF CALIFORNIA .

DEPARTMENTor FINANCIAL INSTITUTIONS

CERTIFICATEOF APPROVALOFNAME
Pursuant to Section 3903 of the FinancialCode.I,WILLIAMS. HARAF.

Commissionerof FinancialInstitutionsof the Stateof California,dohereby approve the '
name ‘HEMETCOMMUNITYLANDTRUSTQ‘ as set forth Inthe attached Ai?cles of Incorporation of ‘HemetCommunity Land Trust.

Given undermyhandand of?cialsealthis 19111day of November,2009‘inthe City-and County of San Francisco, State of California.

WILLIAMS, HARAF CWf Financialinstitutions
P RICK,c.CARROLL
‘
Strategic Support Manager

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BYLAWS OF

HEMETCOMMUNITYLANDTRUST
ARTICLE1

NAME OF CORPORATION
The name of this corporation is Hemet CommunityLand Trust (the “Corporation”). '
'
ARTICLE 2

OFFICES
Section 2.1, PRINCIPAL OFFICE
The principal of?ce for the transactionof the business of the Corporationshall be ?xed and located in the city of Hemet, California. The Boardof Directors(the “Board”) may change the principalof?ce fromone locationto another,and this section shallbe amendedaccordingly.

Section 2.2 OTHER OFFICES
The Board may at any time establish branch of?ces, either Withinor outside the State of California,in order to advance the proper purposes of the Corporation.

ARTICLE 3

OBJECTIWES ANDPURPOSES
The Corporationhas been formed under the CaliforniaNonpro?t Public Bene?t Corporation Law for charitablepurposes. No substantialpart of the activities of the - ~ Corporation shall consistof carrying on propaganda,or otherwiseattempting to in?uence legislation, and the Corporationshall not participateor intervene in any political campaignon behalf of (or in oppositionto) any candidateforpublic of?ce. The Corporation shall not, except to an insubstantialdegree, engage in any activities or exercise any powers that are not in furtherance ofthe charitablepurposes described in its Articlesof Incorporation.

The speci?c purpose of thiscorporationisto lessenthe burdens of government by assisting the City of Hemet,California (the “City”) to ensure that its residents are able to secure decent and affordable housing and conductorperformany ancillary or related activity in ?lrtherance of the foregoing. The Corporationshall be permitted to conduct other law?il activitiespermitted under the CaliforniaNonpro?t PublicBene?t Corporation Law.

HemetTrustElN 274468089 1
RN “MG-806345“ v3

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ARTICLE 4
DEDICATION "OFASSETS
The propertiesand assets of this Corporationare irrevocably dedicated to charitablepurposes. No part ofthe net earnings, properties, or assets of this Corporation, on dissolutionor otherwise,shallinure to the bene?t of any private person or individual, or any Director or Of?cer of this Corporation. On liquidationor dissolution,all properties and assets remainingafter payment, orprovisionfor payment, of all debts and liabilitiesof this Corporationshall be distributed to the City for public purposes. In the alternative,the City may designatea nonpro?t ?md, foundationor corporationwhich is organized and operated exclusivelyfor charitable purposes and which has establishedits tax exempt status under Section501(c)(3) of the InternalRevenue‘Codetoreceive such assets. In the event that the City does not accept any asset of this corporationon dissolution or designate a recipient,then any such asset shall be distributed to a nonpro?t 'fund,foundation or corporationwhich is organized and operated exclusively for charitablepurposes and which has established its tax exemptstatus under Section 501(c)(3) of the internalRevenueCode.

ARTICLE 5

DIRECTORS
Section 5.1 POWERS
(a) GeneralCorporate Powers. The Corporationshall haveall general corporate powers provided for in Section 5410 CaliforniaCorporations Code and otherwiseof the CaliforniaNonpro?t Public Bene?t CorporationLaw (California CorporationsCode section 5110 et seq.) The business and affairs of the Corporation shall be managed, and all corporate powers shall be exercised by or under the directionof the Board. '
’
(b) Speci?c Powers. Without prejudice to theirgeneral powers, the Board shall have the power to:
(i) Selectand remove the of?cers of the Corporation(the “Of?cers"); prescribeany powers and duties for them that are consistent with the law, with the Articles of Incorporation,and with these Bylaws; and ?x their compensation,if any.
(ii) Change the principal executive of?ce or the principal business of?ce in the State of Californiafrom one location to another; cause the Corporationto be quali?ed to do businessin any other state, territory, dependency,or country, and conduct business within or outside the State of California;and designate any place within or outside the State of Californiafor the holding of any meeting.

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. (iii) Adopt, make, and use a corporate seal and alterthe formof the seal.
(iv) Borrow money and incur indebtednesson behalf of the Corporationand cause to be executed and delivered for the Corporation‘s purposes, in the Corporate name, promissorynotes, bonds,debentures, deeds of trust, mortgages, pledges, hypothecations,andother evidencesof debt,
‘
Section 5.2 NUMBER OF DIRECTORS
Except for the Initial Board (as defined in Section 5.3), the authorizednumberof directors of the Corporation (the ”Directors”) shall be seven (7).

Section 5.3 APPOINTMENT AND TERMOF OFFICE OF DIRECTORS
_ (a) Pursuant to CorporationsCode section5134, the incorporator appointed Jim Foreman.and Jerry Franchville (the “Initial City Directors”), and Susan York, (the “initial At—LargeDirectors) to serve as the initial Directors of the Corporation (collectively the “Initial Board"). The Initial Board shall prepare the Corporationto begin operationsby attending to such matters as electing of?cers of the Corporation, submitting the Corporation’s applicationsfor recognitionoftax—exempt status and any other applicable?lings or registrations, and opening bank accounts.

The Directdrs of the Initial Board shall served for the following initial'terrns.One (1) of theinitial City—Directorsand one (1) of the InitialAt~LargeDirectors, as determinedby the incorporator, shall serve for a term of one (1) year. One (1) of the Initial City—Directors and two (2) of the Initial At-Large Directors,as determinedby the incorporator,shall serve for a term of two (2) years. The ?nal two (2) InitialAt—Large Directors, if appointedby the incorporator,shall serve for a term of (3) years. (b) Thereafter, the Boardshall be selected as follows:
(i) Two (2) of the authorizedDirectorsshall be appointed by the City (the “City Directors”) by a'majority vote of the members of theCity Council of the City. The appointmentmay be accomplishedby the delivery of written notice from the City’s Mayor or City Manager, which notice shall be ?led inthe minute book of the Corporation. Such appointment shall be effective upon the future date speci?ed in the notice, or upon receipt by the Corporation if no future date is speci?ed. City Directorsshall only serve during their term of of?ce as a City Councilmemberand upon the expirationof such termor upon the Councilmember’sseat on the Council being otherwisedeemed vacant under the law, the City Director’s seat on the Board shall also be deemedvacant.
_
(ii) Until at least one hundredindividualsreside in
propertiesowned or managedby the Corporation,?ve (5) of the authorizedDirectors shall be elected by theBoard and shall be residents of the City, or persons owning, operating,or managing a lawful business within the City, who are not employeesof the Hcmczrmstsm274468089 3
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City or residents of housing located on land owned or managed by the Corporation(the “At—LargeDirectors”). Preferencewill be given to the election of At-Large Directors having experience with the development, operationor management of affordablehousing projects, or experience generally with property management, real estate development, ?nance, city government, redevelOpment,residential building and construction,or who are withinthe professionsof law, architecture, planning,real estate, banking,insurance, accounting, or similarprofessions,or the owning, operationor management of a local business. Once Resident Directorsare elected pursuant to Section 5.3(b)(iil), the number of At—LargeDirectors shallbe reduced to three (3). (iii) Once at least one hundred individualsreside in
propertiesowned,managed, or monitoredby the Corporation,two (2) of the authorized Directors shall be residents of housing locatedon land owned,managed, or monitored by the Corporation (the “Resident Directors”). The ResidentDirectorsshall be selected by the Board from individualsrecommendedby the residentsof housing located on land owned,managed, or monitored by the Corporationpursuant to a procedure establishedby the Board. The recommendationprocess describedin this Section_5.3(b)(iii) does not create any memberswithin the meaning of Section 5310 ct seq., of the California Nonpro?t Public Bene?t CorporationLaw. The Board shall amend this Section

5.3(b)(ii.i)if necessary to avoidthe creation of memberships. Resident Directorsshall only serve while they remain residents of propertiesowned, managed, or monitored by the Corporation.
(c) All Directors shall serve terms of three (3) years. Directors may . serve three consecutive terms.
(d) TheChair of the Boardshall be selectedby a majority vote of the Directors following the appointment or electionof Directors at eachannual meeting.

Section 5.4 QUALIFICATIONSOF BOARD MEMBERS
Subject to specificeligibility requirementsstatedin Section5.3, any person 18 yearsof age or oldermay serve as a Director. ’
Section 5.5 VACANCIES
(a) Events Causing Vacancy. Avacancy on the Board shall be deemed to exist at the occurrence of any of the following; (i) The death, resignation, or removal of any Director or upon the Director not longer meeting the eligibilityrequirementsfor their seat as providedin Section 5.3. .
(ii) The declarationby resolutionof the Board of a vacancyin the of?ce of a Director who has been declared of unsound mind by court. (iii) The failure of the Board,at any meeting of the Board at which any Director(s) is to be appointedor elected, to appoint or elect the Heme:Trust ElN274468089 4
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Director(s) to be appointedor elected. at such meeting pursuant to the provisions of Section 5.3(b), '
(iv) Removal of a Director, as provided in subdivision(c) of this Section, upon the adoptionof a Resolution of Removal by a majority of the Directorsthen in of?ce.
(v) ' The increase of the authorizednumber of Directors. (b) Resignation. Exceptas provided in this paragraph,any Director may resign, which resignation shall be effective on giving written notice to the Chair of the Board, the Executive Director, or the Secretary, unlessthe notice speci?es a later time for the resignation to become effective.No Director may resign when the Corporation would then be lE? without a duly elected Director or Directorsin charge of its a?airs. (c) Removal.
. (i) Any City Director may be removed without cause, by the City. The removal may be accomplishedby the delivery of written notice from the City’s Mayor or City Manager, which notice shall be ?led in the minute book of the Corporation. Such removal shall be effective upon the future date speci?ed in the notice, or upon receipt by the Corporationif no future date is speci?ed. A City Director may only be removed by the majority ofthe Directors then in office with cause. .
(ii) Any Resident Director may be removed without cause by the majority of the Directorsthen in office upon the written request of the residents of housing located on land owned,managed, or monitored by the Corporation. The Board shall establishpolicies and proceduresgoverning such requests by residents. Any Resident Director may be removed with cause by a majority of the Directorsthen in office.
(iii) Any At-Large Directormay be removed by the Board,with or without cause, upon the majority vote of the Directors then in o?ice at a special meeting called for that purpose,or at a regular meeting. (iv) :Forthe purpose of subdivision (c) of Section 55 of these By—Laws,“cause” shall mean any of the following:
i
(A) Fraudulentor dishonest acts or gross abuse
of authorityor discretion with reference to the Corporation,as determined by a majority of the Board.
(B) A breach or violation of the standard of care
for Directors providedin Section 5230 et seq., of the CaliforniaCorporationsCode,as determined by a majority of the Directors.

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(C) A materialbreach of the Corporations
Con?ict of Interest Code, as determinedby a majority of the Directors. (D) Any Directorwho does not attend three
successive Board meetings, withoutexcuse, . Excuse means: -

1. A majority of the Directors present at the ‘ meeting, excuse the Director’s absence, '

2. The Directorrequests a leave of absence for
a limitedperiod of time,and the leave is approved by the Directors at a regular or specialmeeting. if such leave is granted, the number of Board membersWillbe reduced by
one in determining whether a quorum is or is not present.

3. The Director suffers from an illness or
disabilitywhich prevents himor her from attending
meetings and the Board by resolution waives the automatic removal procedure of this subsection (ii).
(d) Filling of Vacancies. Any vacancy caused by the death, resignation, or removal of a Director shall be ?lled in accordance with the provisions of Section 5.3(b).

Section 5.6 RALPH M. BROWN ACT
To the extentrequired by law, all meetings of the Board, including,without limitation,regular, adjourned regular, special, and adjourned specialmeetingsshall be called, noticed, held and conductedin accordancewith theprovisionsof the RalphM.

Brown Act (commencing with Section 54950of the CaliforniaGovernmentCode), or any successor legislation hereinafterenacted (the “Brown Act”).

Section 5.7 PLACE OF MEETING
Meetings of the Board shall be held at the principalof?ce of the Corporation unless a different place is designated in the notice of such meeting Section5.8 ANNUAL MEETING
The Board shall hold an annual meeting for purposes of electingDirectorsand Of?cers,designating committees,and transacting regular business. The date of the annual meeting shall be the ?rst Tuesday of each year unis otherwisedesignatedby theBoard.

The date, hour and place of the meetingsshall be ?xedby resolution of the Board . To the extent permittedby the Brown Act, such meetings may be held by telephone conference.

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Section 5.9 SPECIAL MEETINGS
. Specialmeetings of the Board may be called in accordancewiththeprovisions of Section 54956of theCalifornia GovernmentCode. To the extent permitted by the Brown Act, such meetings may be held by telephone conference.

Section 5.10 WAIVER OF NOTICE
The transactionsof any meetingof the Board, however called and noticedand wherever held,shall be as valid as though taken at a meeting duly held afterregular call and notice if (a) a quorum is present and (b) either before or alter the meeting, each of the Directorsnot present signs a written waiver of notice, a consent to holding of the meeting, or an approval of the minutes. The waiver of notice or consent need not specify the'purposeofthe meeting. All waivers, consents, and approvalsshall be ?ledwith the corporate recordsor made a part of the minutes of the meeting. Notice of a meeting shall alsobe deemed given to any Directorwho attends the meeting without protesting before or at its commencement about lack of adequate notice
Section 5.11 ACTION WITHOUTMEETING
Any actionrequired or permittedto be taken by the Boardmay be takenwithout a meeting, if allmembers of the Boardindividually or collectivelyconsent in writing to such action. Suchwritten consent or consents shall be ?led with the minutes of the proceedings of the Board. Such action by written consent shall have the same force and effect as the unanimousvote of such Directors,
SectionSJZ QUORUM
A majorityof the Board shall constitute a quorum for the transaction of business, except to adjourn as providedin Section 5.13. Every actor decision done or made by a majority of theDirectors present at a meeting held at which a quorum is presentshallbe regarded as the act of the Board, subjectto the provisions of these Bylaws and the CaliforniaNonpro?t PublicBene?t CorporationLaw. A meeting at which a quorum is initiallypresent may continue to transact business,notwi?rstandingthe withdrawalofany Director,if any action takenis approvedby at least a majority of the quorum requiredfor the meeting
Section 5.13ADJOURNMENT
A majority of the Directorspresent, Whetheror not constimting a quorum, may adjourn any meeting to another time and place.

Section 5.14 Norton or ADJOURNMENT
Notice of the timeand place of holding an adjourned meetingneed not be given, unless the meeting is adjourned for more than twenty~four (24) hours, in whichcase notice of the time and place shall be given beforethe time of the adjourned meeting to the Heme!Trust BIN274468089 7
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Directors who were not present at the time of the adjournment. Such noticemay be waived in the same manner as set forth under Section5.10.

Section 5.15 COMPENSATION OF DIRECTORS
Directors and members of committeesmay receive reimbursementof business and travel expenses directly related to the operationor business of the Corporationas may be determinedby resolutionof the Board to bejust and reasonable.Directors shall not otherwisebe compensated.

Section 5.16 RESTRICTION ON INTERESTED DIRECTORS
Not more than forty~nine percent (49%) of the persons serving on the Board at any time maybe interestedpersons. An interestedperson is (a) any person compensated by the Corporation forservicesrendered to it other than those performedas a Director withinthe previous twelve (12) months, whether as a full—timeor part-timeemployee, independent contractor, or otherwise;(b) any shareholder,employee or of?cer of any corporation, or partner or employee of any partnership,which has rendered compensated servicesto the Corporation within the previous twelve (12) months; and (c) any brother, sister, ancestor, descendant,spouse,brother~in—law,sister—in-law,mother~in~law,or father in—lawof any person described in (a) or (b) hereof. Any violation of the provisions of this paragraph shall not, however, affect the validity or enforceability of any transaction entered into by the corporation.

ARTICLE 6
COMMlTTEES
Section 6.1 COMMITTEES or DIRECTORS
The Board may, by resolutionadoptedby a majority of the Directorsthen in , of?ce, designate one or more committeesconsistingof two or more Directorsto serve at the pleasure of the Board. Any member of any committee may be removed,with or without cause, at any timeby theBoard. Any committee,to the extent providedin the resolutionof the Board,shall have all or a portion of the authority of theBoard, except that nocommittee, regardless of the Board resolution,may:
(:1) Fill vacancies on the Board or on any committee;
(b) Amend or repeal the Articlesof Incorporationor Bylawsoradopt new Bylaws;_
(c) Amend or repeal any resolutionof the Board;
(d) Designate any other committeeof the Board or appointthe members of any committee;
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(e) Except as providedin Section5233 of the CaliforniaNonpro?t PublicBene?tCorporation Law, approve any transaction (i) to which the Corporation is a party, and as to which one or more Directors has a material?nancialinterest,or (ii) between die Corporation and any corporationor entityin whichone or more of its Directors has amaterial ?nancial interest.

Section 6.2 AUDIT COMMITTEE
The Board shall establishan audit committeeas and when required by Section ‘ 1258603)of the California GovennnentCode.

Section 6.3 ADVISORY COMMITTEES
The Boardmay appointone or more advisorycommitteesconsisting of Directors and/or non—Directorsfor the purpose of advising the Board. Any advice rendered by such an advisory committee shall not be binding on the Board.

Section 6.4 MEETING AND ACTION OF COMIVIITTEES
The Board may adopt rulesfor any committeenot inconsistent with the provisions of these Bylaws.

ARTICLE 7

OFFICERS
Section 7.1 OFFICERS
The Corporation shall have the following Of?cers: Chair of the Board,Executive Director , Secretary, Treasurer, and General Counsel, and such other Of?cers as the Board may designate by resolutionand appoint pursuant to Section 7.3. Of?cers need not be Directors. One person may hold two or more of?ces, except those of Executive Director and Secretary,and ExecutiveDirector and Treasurer. O?icers, Except for the Chair of the Board, may receive such reasonable compensation,if any, fortheir services, and such reimbursement for expenses,as may be ?xed and determinedby the Board The Board (or a committee ofthe Board) shall reviewand approve the compensation, including bene?ts, ifany, of any paid staff.

Section 7.2 ELECTION OF OFFICERS
The Of?cers of the Corporation,except the Chairof the Board, Treasurer, Secretary, and General Counsel and except those appointedin accordance with the provisions of Section 7.3 of this Article, shall be chosen annually by the Board. Except as provided,below, each Of?cer shall serve at the pleasureof the Board, subjectto the rights, if any, of any Of?cer under a contract of employment.

The Treasurer of the Corporationshall be the then serving Finance Director for the City of Hemet. The Secretary of the Corporation shall be the then serving City Clerk HamelTmstBIN274468089 9
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for the City of Hemet. The GeneralCounsel of the Corporation shall be theCity Attorney of the City or the GeneralCounsel of the City RedevelopmentAgency. The Treasurer and Secretary may be removed by the City or by the Board for cause as providedin subdivision(c)(iv)of Section 5.5. of these By-Laws Section 7.3 SUBORDINATE OFFICERS
The Boardmay appoint,and may authorize the Executive Director or any other Of?cer to appointany other Of?cers that the businessof the Corporationmay require, each of whom shall have the title,hold of?ce for the period, have the authority,and performthe dutiesspeci?ed by the Bylaws or determinedfrom time to time by the Board.

Section 7.4 REMOVAL OF OFFICERS
Subject to rights, if any, under any contract of employment,any Of?cermay be removed, with or without cause, by the Board, at any regular or specialmeeting of the Board, or, except in the case of an Of?cer chosen by the Board,by an Of?cer on whom such power of removal hasbeen conferred by the Board.

Section 7.5 RESIGNATIONOF OFFICERS
Any Officer may resign at any time by giving written notice to the Board, the Executive Director, or the Secretary of the Corporation. Any resignationshall take effect at the date of receipt of that noticeor at any later time speci?ed in that notice. Unless otherwisespeci?ed in that notice,the acceptance of the resignation shall not be necessary to make it effective. Any resignationshall be without prejudice to the rights, if any, of the Corporation under any contract to which the Of?cer is a party.

Section 7.6 VACANCIES IN OFFICE
A vacancy in any Of?ce because of death, resignation,removal, disquali?cation, or any other cause shall be ?lled only in the manner prescribed in these Bylawsfor regular appointmentsto that Of?ce.
. Section 7.7 RESPONSIBILITIES OF OFFICERS
(3) ExecutiveDirector. The Executive Director shall be the chief executiveof?cer of the Corporation. He or she shall have such otherpowersand duties as may be prescribed by the Board or these Bylaws. The Executive Director shall be responsibleto the Board, shall see that the Board is advised on all signi?cant matters of the Corporation's business, and shallsee that all orders and resolutions of the Board are carried into effect. The ExecutiveDirectdr shall be empowered to act, speak for, or otherwise represent the Corporationbetween meetings of theBoard within the boundaries of policies and purposes establishedby the Board and as set forth in the Articlesof Incorporationand these Bylaws. The Executive Director shall be responsiblefor keeping the Board informed at all times of staff performance as related to program objectives, and for implementingany personnel policies adopted by the Board. The Home!Trust am274463039 10
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Chair of the Board shall be empowered to act in the stead of the ExecutiveDirector. during absences or the Executive Director an at such times as the position is vacant. (b) ' Secretary. The Secretary shall attend to the following:
(i) Book of Minutes. The Secretary shall keepor cause to be kept, at the principalexecutive of?ce or such other place as the Board may direct, a book of minutes of all meetingsand actions'of Directorsand committees of Directors,with the time andplace of holdingregular and special meetings,and if special, how authorized,the notice given,the names of thosepresent at such meetings, and the proceedingsofsuch meetings.
(ii) Notices and Other Duties. The Secretary shall give, or cause to be given, notice of all meetings of the Board requiredby the Bylaws to be given. The Secretary shall have such other powers and perform such other duties as may be prescribed by the Board or the Bylaws. »
1c) Treasurer. The Treasurer shall be the chief ?nancial of?cer of the Corporation and shall attend to the following:
(iii) Books of Account. The Treasurer shall keep andmaintain, or cause to be kept and maintained, adequate and correct books and records of accounts of the propertiesand business transactionsof the Corporation, including accounts of its assets,liabilities,receipts, disbursements,gains, losses, capital,andothermatters customarily includedin ?nancialstatements. The books of account shall be open to inspection by any Director at all reasonabletimes.
(iv) Deposit and Disbursementof Money and Valuables.The Treasurershall deposit, or cause to be deposited, all money and other valuablesin the name and to the credit of the Corporationwith such depositorsas may be designated by the Board;shalldisburse,or cause to p be disbursed,funds of the Corporation as may be ordered by the Board; shall renderto the ExecutiveDirector and Directors,wheneverthey request it, an account of all ?nancial transactionsandof the?nancial condition of the Corporation; and shall have other powers and perform such other dutiesas may be prescribedby theBoardor the Bylaws. . (v) BM. If required by the Board, the Treasurershallgive the Corporation a bond in the amount and with the surety speci?ed by the Boardfor the faithful performance of the duties of his or her of?ce and for restoration to the Corporation of all its books, papers, vouchers,money, and other property of every kind in his or her possessionor under his or her control on his or her death, resignation, retirement,or removal from of?ce. '
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((1) GeneralCounsel. The GeneralCounselshallbe chiefly
responsiblefor advisingthe Board and the of?cers of the Corporationwith regard to applicationof federal,state, and local laws,regulations, and ordinancesto operations,transactionsand projects of the Corporation,and for reviewing the form and content of resolutions, amendmentsto articles and by—laws,and contracts and other transactional documentsrelated to the Corporation. The General Counselshall have authority to interpretthe Corporation’sCon?ict of Interest Code for the Board and shalladdress questionsof parliamentary - procedure. Nomithstanding the foregoing, the Boardmay, from time to time, as it deems appropriate,retain special legal counselon such terms as the Board ?nds reasonable, to represent the Corporationin transactions or in matters of litigation.

ARTICLE 8

RECORDS AND REPORTS
Section 8.1 MAINTENANCE OF ARTICLES ANDBYLAWS
The Corporation shall keepat its principal executive of?ce the original or a copy of its Articles of Incorporationand Bylaws as amended to date, Section 8.2 MAINTENANCEOF OTHER CORPORATERECORDS
The accounting books,records, and minutes of the proceedings of the Board and any committee(s) of the Board shall be kept at suchplace or places designated by the Board, or, in the absence ofsuch designation, at the principal of?ce of the Corporation.

The minutes shall be kept in writtenor typed form, and theaccounting books and records shall be kept in either written or typed form or in any otherform capable of being converted into Written,typed, or printed form.

Section 8.3 INSPECTION BY DIRECTORS AND CITY
Every Director and any authorized representative of the City shall havethe absolute right at any reasonabletime to inspect all books,records,anddocumentsof every kind and the physical properties of the Corporationand each of its subsidiary corporations. This inspectionby a Director may be made in person or by an agent or attorney, andthe right of inspectionincludes the right to copy and make extracts of documents. '
Section 8.4 ANNUAL STATENLENT OF CERTAIN TRANSACTIONS

AND INDEMNIFICATION
As soon as reasonablypracticable after theclose of the ?scal year, the Corporation shall prepare and mail or deliver to each Director and the City an annual statement that includes(i) the ?nancial statements of the Corporationaccompanied by any report thereon of independent accountants, or, if there is no such report, the certi?cate of an authorizedof?cer of the Corporationthat such statements were prepared Heme!Trust ElN 274468089 12
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without auditfrom the books and records of the Corporationand (ii) the amount and circumstances of any transaction or indemni?cation of the following kind:
(a) Any transaction(s) inwhich the Corporationwas a party, and in which any Director or Of?cer of the Corporation had a direct or indirect ?nancial interest.
(b) Any indemni?cations or advances aggregating more than Ten ThousandDollars($10,000) paid during the ?scal year to any Officer or Director of the Corporationpursuant to Article9 hereof, unless such indemni?cation has alreadybeen approved pursuant to Section 9.1.

ARTICLE 9

INDEMNIFICATION OF DIRECTORS ANDOFFICERS
Section 9.1
i RIGHT TO INDEMNIFICATION
This Corporation shall indemnify any personwho was or is a party, or is threatenedto be made a party, to anyaction or proceedingby reason of the fact that such person is or was an Officer, Director, or agent of this Corporation,or is or was serving at the request of the Corporation as a director,of?cer, employee, or agent of anotherforeign or domestic corporation, partnership,joint venture, or other enterprise, against expenses, judgment, ?nes, settlements, and other amountsactually and reasonably incurred in connectionwith such proceeding, to the fullestextent permittedunder the California Nonpro?t PublicBene?t Corporation Law.
. In determining whether indemni?cation is availableto the Director, Of?cer or agent of this Corporationunder California law, the‘deterrninationas to whether the applicable standard of conduct set forth in Section 5238 of the CaliforniaNonpro?t Public Bene?t Corporation Law has been met shall be made by a majority vote of a quorum of Directorswho are not partiesto the proceeding. The indemni?cation provided herein shall not be deemed exclusive of any other rights to which those indemni?ed may be entitled, and shall continue as to a person who has ceased to be an agent andshall inure to the bene?t of the heirs, executors, and administrators of such a person.

Section 9.2. INSURANCE
This Corporationshall have the power and shall use its best effortsto purchase and maintaininsurance on behalf of any Director,Of?cer, or agent of the Corporation, against any liabilityasserted against or incurred by theDirector,Of?cer, or agent in any such capacityor arising out of the Director's, Of?cer's, or agent's status as such, whether or not the Corporationwould have the powerto indemnify the agent against such liability under Section9.1 of these Bylaws; provided,however, that the Corporation shall have no power to purchaseand maintain such insurance to indemnify any Director, Of?cer, or agent of the Corporationfor any self~dealing transactiondescribed in Section 5233 of the CaliforniaNonpro?t PublicBene?t CorporationLaw.

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ARTICLE 10

CONTRACTS ANDLOANS WITH DIRECTORS ANDOFFICERS
Section 10.1 CONTRACTSWITH DIRECTORS ANDOFFICERS
(a) No Directoror Of?cer of this Corporation,nor any other corporation,?rm, association, or other entity in which one or more of this Corporation's Directors or Of?cers are directorsor havea material?nancialinterest,shall be interested, directly or indirectly, in any contract or other transactionwith this Corporation,unless (i) the materialfactsregarding such Director's or Of?cer‘s?nancial interest in such contract . or transaction and/orregarding such common directorship,officership, or ?nancial interest are fully disclosed'in goodfaith and are noted in the minutes,or are known to all members of the Boardprior to considerationby the Board of such contract or transaction; (ii) such contract or transactionis authorized in good faith by a majority ofthe Board by a vote su?ticientfor that purposewithout countingthe vote or votes of such interested Director(s); (iii) prior to authorizing or approvingthe transaction, the Board considers and in good faithdeterminesafter reasonable investigationunder the circumstances that the Corporation could not obtaina more advantageous arrangement with reasonable effort under the circumstances; and (iv) this Corporation enters into the transaction for its own bene?t, and the transaction is fair and reasonable to this Corporationat the time the transaction is entered into.
(b) The provisionsof this Section do not apply to a transaction which is part of.a charitable program of the Corporationif it: (i) [5 approvedor authorizedby theCorporationin good faith andwithout unjusti?ed favoritism; and (ii) results in a bene?t to one or more Directors or Of?cers or their familiesbecausethey are in the class of persons intendedto be bene?tedby the charitableprogram of the Corporation.

Section 10.2 LOANS TO DIRECTORS AND OFFICERS
TheCorporation shall not make any loan of money or property to or guarantee the obligationof any Director or Of?cer, unless approvedby the Attorney General of the State of California;provided,however, that the Corporationmay advance money to a Director or Of?cer of the Corporationforexpensesreasonablyanticipatedto be incurred in the performance of the duties of such Director or Of?cer, providedthat in the absence of such advance suchDirector or Of?cer would be entitled to be reimbursedfor such expenses by the Corporation.

ARTICLE 11
‘ FISCAL YEAR
The ?scal year of the Corporation shall be the ?scal year, commencing July 1 and ending on June 30.

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ARTICLE 12

CITY REVIEW AND APPROVAL
Section 12.1 CITY APPROVAL OF PROJECTS
Prior to approvalof any proposedproject(a “Proj ect") by the Corporation,the Corporationshallcirculate a notice to the City Directorsprovidinga descriptionof the Project. At least one City Directormust inform the Corporationin writingthathe or she approvesthe Project, the Corporationmay, if it chooses,undertakeandcomplete the Project. The Corporationshallnot undertake a Project withoutthe writtenapprovalof at least oneCity Director. For purposes of this Section 12.1, “Project” is limitedto: (i) any acquisitionor sale ofreal property, (ii) any mortgage of property, (iii) any agreement with a property ownerxor manager to monitor affordable.housing compliance,(iv) any revisionto the resale fermulaof any residence on the Corporation’sproperty, and (v) any new constructionproject or substantialrehabilitationproject in which the interest of the I
Corporation or expense to the Corporationis or may reasonably exceed $10,000. .

Section 12.2 CITY REVIEWOF ANNUALBUDGET
Upon writtenrequest of the City Manager of the City, the annual budget of the Corporationshall be delivered to the City Manager for review before the budget is adoptedby the Corporation The City Manager shall have no legal autho?ty to act for the Corporation,but theBoard shall in.good faith review anyrecormnendations made by the City Manager regarding the annual budget to be adopted by the Corporation.

ARTICLE 13

CONSTRUCTIONAND DEFINITIONS
Unlessthe context requires othervvise,the generalprovisions,rules of construction,and definitionsin the CaliforniaNonpro?t PublicBene?t CorporationLaw - shall govern the constructionof these Bylaws. Without limiting the generalityof the above, the masculinegender includesthe feminine and neuter, the singular number includes the plural,and the pluralnumberincludesthe singular.

ARTICLE 14

AMENDMENTS
Section 14.1 ARTICLES
TheArticles of hcorporation of the Corporationmay be amendedby a majority vote of the Directorsthen in of?ce, providedthat all City Directors consent inwriting to any such amendment.

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Section 14.2 BYLAWS
Bylaws may be adopted, amended, or repealedby a majorityvote of the Directors then in of?ce, providedthat all City Directors consent inwriting to any such action.

ARTICLE 15

MEMBERS
Pursuant to CorporationsCode section5310, this Corporationshall not have voting membersWithinthe meaning of the CaliforniaNonpro?t Public Bene?t CorporationLaw. The Board may admit nonv'otingmembersof one or more classes having such rights and obligations as the Board shall deem appropriate ?'om time to time.

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CERTIFICATE OF SECRETARY
I, the undersigned, thedolyelectedSecretary of HemetCommunity LandTrust, a California nonpro?t publicbene?t corporation(the “Corporation”), do herebycertify:

Thatthe foregoingBylaws consistingof seventeen (17) pages (includingthis page) wereadopted as theBylaws ofthe Corporationby the Boardof the Corporation on May 3, 2010 and do now constitute theBylaws of the Corporation.

IN WITNESS WHEREOF, I havehereunto subso?bed my namethis 3rd day of May, 2010. W
SarahMcComas, Secretary
Ham'rmst Em 274468029 17

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Hemet LandTrust
5 Year Estimated Capital & Administrative Budget
1’ A = I NSF~MFFunds'
LowMod Funds
HOMEFunds
TOTAL
% of fundsfor MF
%of fundsfor SFR
Subsidy for MF
Subsidy for SFR

ANNUALUNIT PRODUCNON
Rental
Homeownership
TOTAL

CUMMULATNEUNIT PORTFOLIO
Rentai
Homeownership
TOTAL
ADMIN)
I I I B I 1 l I
5 1,000,000
3 500,000 5 1,000,000 5 1,000,000 3 1,000,000 5
s
' - 5 250,000 $ 250,000 5 250,000 5
5 1,500,000 5 1,250,000 5 1,250,000 5 1,250,000 5 1,250,000 10mg 100% 50% 50°» 50%
0% 0% 50% 50% 50%
$150,000 $157,500 $165,375 $173,544 $102,325
$50,000 $52,500 555,125 557,531 $00,775
140
10 s 4 4 3
0 0 11 11 10
10 s 14 14
10 18 22 25 29
0 0 11 22 32 W m m «was. 1,“ r m
10 1a 33 47 01
RENUE
City Start Up Funding 5 20,000 I I
LeaseRevenues(MF) $ 25013 44315 543 s 033 s 719 i
LeaseRevenue$(SFR) S 45 «[3 6,805 $ 13,282 $ 19,452
TOTAL $1 ‘ 20,2505" 440 $ 7,3403 13,914$ 20,170

EXPENSES
LandTrustConsulfant 5 10,000 5 3,oDo|$‘ 3,000 5 3,000 5 3,000 LegalExpenses S 6,000 3 2,500.5 2,500 5 2,500 $ 2,500
TOTAL 5 16,000 5 5,500 $ 5,500 5 5,500‘ 5 5,500
cumumvE BA_LANCE 3 4,250 5 (5,05215 1,045 5 0,414 5 14,070

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