Hemet City Council
September 10, 2024

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Order R8-2024-0001 (NPDES No. CAS618000) Page 318 of 320 Attachment F
Santa Ana Regional MS4 Permit
VI. STANDARD PROVISIONS – ENFORCEMENT
A. The Santa Ana Water Board is authorized to enforce the terms of this permit under several provisions of the Water Code, including, but not limited to, sections 13268, 13385, 13386, and 13387.

B. The CWA provides that any person who violates section 301, 302, 306, 307, 308, 318 or 405 of the CWA, or any permit condition or limitation implementing any such sections in a permit issued under section 402, or any requirement imposed in a pretreatment program approved under sections 402(a)(3) or 402(b)(8) of the CWA is subject to a civil penalty not to exceed $25,000 per day for each violation. The CWA provides that any person who negligently violates sections 301, 302, 306, 307, 308, 318, or 405 of the CWA, or any condition or limitation implementing any of such sections in a permit issued under section 402 of the CWA, or any requirement imposed in a pretreatment program approved under section 402(a)(3) or 402(b)(8) of the CWA, is subject to criminal penalties of $2,500 to $25,000 per day of violation, or imprisonment of not more than one (1) year, or both. In the case of a second or subsequent conviction for a negligent violation, a person shall be subject to criminal penalties of not more than $50,000 per day of violation, or by imprisonment of not more than two (2) years, or both. Any person who knowingly violates such sections, or such conditions or limitations is subject to criminal penalties of $5,000 to $50,000 per day of violation, or imprisonment for not more than three (3) years, or both. In the case of a second or subsequent conviction for a known violation, a person shall be subject to criminal penalties of not more than $100,000 per day of violation, or imprisonment of not more than six (6) years, or both. Any person who knowingly violates section 301, 302, 303, 306, 307, 308, 318 or 405 of the CWA, or any permit condition or limitation implementing any of such sections in a permit issued under section 402 of the CWA, and who knows at that time that he thereby places another person in imminent danger of death or serious bodily injury, shall, upon conviction, be subject to a fine of not more than $250,000 or imprisonment of not more than 15 years, or both. In the case of a second or subsequent conviction for a known endangerment violation, a person shall be subject to a fine of not more than $500,000 or imprisonment of not more than 30 years, or both. An organization, as defined in section 309(c)(3)(B)(iii) of the CWA, shall, upon conviction of violating the imminent danger provision, be subject to a fine of not more than $1,000,000 and can be fined up to $2,000,000 for second or subsequent convictions. (40 CFR § 122.41(a)(2), Wat. Code §§ 13385,13387)
C. Any person may be assessed an administrative penalty for violating section 301, 302, 306, 307, 308, 318 or 405 of the CWA, or any permit condition or limitation implementing any of such sections in a permit issued under section 402 of the CWA. Administrative penalties for Class I violations are not to exceed $10,000

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Order R8-2024-0001 (NPDES No. CAS618000) Page 319 of 320 Attachment F
Santa Ana Regional MS4 Permit
per violation, with the maximum amount of any Class I penalty assessed not to exceed $25,000. Penalties for Class II violations are not to exceed $10,000 per day for each day during which the violation continues, with the maximum amount of any Class II penalty not to exceed $125,000. (40 CFR § 122.41(a)(3)) D. The CWA provides that any person who falsifies, tampers with, or knowingly renders inaccurate any monitoring device or method required to be maintained under this permit shall, upon conviction, be punished by a fine of not more than $10,000, or by imprisonment for not more than two (2) years, or both. If a conviction of a person is for a violation committed after a first conviction of such person under this paragraph, punishment is a fine of not more than $20,000 per day of violation, or by imprisonment of not more than four (4) years, or both. (40 CFR § 122.41(j)(5))
E. The CWA provides that any person who knowingly makes any false statement, representation, or certification in any record or other document submitted or required to be maintained under this Order, including monitoring reports or reports of compliance or noncompliance shall, upon conviction, be punished by a fine of not more than $10,000 per violation, or by imprisonment for not more than six months per violation, or by both. (40 CFR § 122.41(k)(2)) VII. ADDITIONAL STANDARD CONDITIONS APPLICABLE TO SPECIFIC CATEGORIES OF NPDES PERMITS [40 CFR SECTION 122.42]
A. Municipal separate storm sewer systems. The operator of a large or medium MS4 or a municipal separate storm sewer that has been designated by the Santa Ana Water Board or USEPA under 40 CFR section 122.26(a)(1)(v) shall submit an annual report by the anniversary of the date of the issuance of the permit for such MS4. All reports submitted in compliance with 40 CFR section 122.42(c) shall be submitted electronically by the owner, operator, or the duly authorized representative of the MS4 to the initial recipient, as defined in defined in Standard Provisions – Reporting Part V.J of this Attachment F, in compliance with 40 CFR section 122.42 and 40 CFR part 3 (including, in all cases, subpart D to part 3), section 122.22, and 40 CFR part 127. The report shall include (40 CFR § 122.42(c)):

1. The status of implementing the components of the stormwater management program that are established as permit conditions (40 CFR § 122.42(c)(1));

2. Proposed changes to the stormwater management programs that are established as permit conditions. Such proposed changes shall be consistent with 40 CFR section 122.26(d)(2)(iii) (40 CFR § 122.42(c)(2)); and

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Order R8-2024-0001 (NPDES No. CAS618000) Page 320 of 320 Attachment F
Santa Ana Regional MS4 Permit

3. Revisions, if necessary, to the assessment of controls and the fiscal analysis reported in the permit application under 40 CFR section 122.26(d)(2)(iv) and (d)(2)(v) (40 CFR § 122.42(c)(3));

4. A summary of data, including monitoring data, that is accumulated throughout the reporting year (40 CFR § 122.42(c)(4));

5. Annual expenditures and budget for year following each annual report (40 CFR § 122.42(c)(5));

6. A summary describing the number and nature of enforcement actions, inspections, and public education programs (40 CFR § 122.42(c)(6)); and

7. Identification of water quality improvements or degradation (40 CFR § 122.42(c)(7)).

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445 E. Florida Ave., Hemet, Ca 92543 | 951-765-2360 | FAX (951) 765-3878 July 1, 2024
Santa Ana Regional Water Quality Control Board
Attn: Adam Fischer
3737 Main Street, Suite 500
Riverside, CA 92501
RE: City of Hemet Comments on the State of California, California Regional Water Quality Control Board Santa Ana Region Tentative Order R8-2024-0001 Dear Mr. Fischer,
The City of Hemet has reviewed the Regional Water Quality Control Board’s Tentative Order R8- 2024-0001. In reviewing the Tentative Order, the City of Hemet has the following comments/concerns related to the Order:

III.PERMITTEE RESPONSIBILITIES
This section references the need to establish an account in the SMARTS database. The City of Hemet understands this system is not set up to accept the requirements of the NPDES Electronic Reporting rule for the data that you are requesting, and asks that the Board delay this requirement until such a time when the system has the capability to handle effectively process this data.

VIII.NEW DEVELOPMENT (INCLUDING SIGNIFICANT REDEVELOPMENT) Subsection B.2. reads as follows: “The requirements of this section VIII apply to initial project applications received by the Permittees on or after the effective date of this Order. The requirements apply to Permittees’ projects where design has been initiated on the effective date of this Order and thereafter.” This language is confusing as it seems to specify two different requirements, one being on or after the effective date of this order and the second being where project design has been initiated. The City requests that the order either utilize one criterion or clearly define “where design has been initiated”. The City prefers that only one criterion be specified. The current language leaves it unclear as to when these requirements apply.

Subsection B.5.a.iii reads as follows: “If any part of the project is subject to a prior WQMP and there are deficiencies in the related pollution controls, the project must be required to correct the deficiencies.” The City is not clear on what type of assessment is required to determine deficiencies. For example, if a project that was built in 2008 under previous permit requirements and is analyzed for deficiencies based upon the current Tentative Order requirements, then the project will always be deficient. The City of Hemet requests clarifying language that a redevelopment project that does not remove or replace more than 50% of the existing impervious surface over an entire development be subject to assess deficiencies based upon the permit requirements at the time the project was developed. In addition, clarification that it is based upon the WQMP requirements at that time and not the current tentative order requirements.

Public Works Department – Engineering Division

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City of Hemet Comments on the State of California, California Regional Water Quality Control Board Santa Ana Region Tentative Order R8-2024-0001
3777 Industrial Ave, Hemet, Ca 92545 | 951-765-3712| FAX (951) 765-3712 Subsection B.5.i reads as follows: “Improvement of existing street, road, highway, and freeways affecting 5,000 square feet or more of paved surface used for the transportation of vehicles. This category excludes routine maintenance projects associated with operations and maintenance activities that are conducted on existing lines and facilities and within existing right-of-way or easements.” The City is not clear if a WQMP would be required for sidewalks constructed for gap closure and compliant ADA ramps exceeding 5,000 sq. ft.. If a WQMP were required for this type of project, BMPs would be required to be implemented for older areas of town that are connecting sidewalks with no existing storm drain or adequate right-of-way needed to implement these types of BMPs. Most areas in already developed portions of the City do not have additional right-ofway available to implement BMPs, and even the use of street trees would pose issues related to Americans with Disabilities Act (ADA) requirements where sidewalk is limited. Most older areas in the City of Hemet do not have a storm drain system to connect any BMPs into. The City of Hemet anticipates additional funding needs for BMP implementation since these sidewalk and ADA projects are not typically developer led. . The City of Hemet requests that clear exemptions be included in the tentative order for projects located in already developed/older areas of the City intended to close sidewalk gaps and to comply with ADA requirements.

Subsection C.5. states that projects that are ineligible to use the “Green Streets” Guidance, “including the addition or replacement of impervious surfaces as part of transportation improvements in the planned, ultimate right-of-way” require a WQMP. However, redevelopment provides the exemption of routine maintenance projects on existing lines and facilities within existing right-of-way. The City believes that the replacement of impervious surfaces, as part of transportation improvements defined here, should be excluded from having to prepare a WQMP AND from “Green Street” guidance standards. In short, existing streets and their maintenance should be excluded from these requirements.

Subsection C.14.: The City disagrees with the requirement to have WQMPs include descriptions of covenants, conditions, restrictions, easements, and does not believe this is realistic. These documents are not done until the HOA is formed, which is not during the engineering plan check phase. CC&R’s should be included after the approval of the WQMP, and a letter stating the items that will be included after formation of the HOA can be provided for approval.

Subsection C.20.: The City believes that the requirement to “identify missing, damaged or deficient source control during construction”, would only apply to redevelopment projects that have existing source control to identify. New development projects will not have any existing source control, and during construction, all BMPs are tied to the General Construction Permit.

However, this language implies the requirements apply to all projects. The City requests that this language specify the application only to redevelopment projects that have existing source control.

Subsection L. Hydrologic Conditions of Concern: Mitigating for increased runoff should be a metric for addressing Hydrologic Conditions of Concern in terms of flow, as meeting a time of concentration and volume mitigation is virtually impossible. For sites that do not meet the minimum infiltration rate for utilizing infiltration based BMPs, there is no viable method for meeting the volume mitigation. When developments increase impervious area, volume is increased, and the only way to mitigate this increase in volume is to infiltrate it into the soil. Otherwise, it must be released via other BMPs that do not retain and infiltrate the volume. Additionally, meeting a time of concentration when utilizing detention based BMPs such as bioretention basins is not feasible as due to the retention, the time of concentration will always increase. The City of Hemet requests that addressing Hydrologic Conditions of Concern can be met in terms of flow mitigation for sites in which infiltration is not feasible, and remove the time of concentration requirement as meeting time of concentration when retaining flows is not feasible.

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City of Hemet Comments on the State of California, California Regional Water Quality Control Board Santa Ana Region Tentative Order R8-2024-0001
3777 Industrial Ave, Hemet, Ca 92545 | 951-765-3712| FAX (951) 765-3712 Attachment A: Impervious Surface: This definition, as currently written, would essentially require any type of project/permit, including mass/rough grading permits, to have an approved WQMP.

Currently projects are still considered in construction when mass/rough graded, and they have an active General Construction Permit until such a time that it is stabilized. The City requests that this definition be revised so that mass/rough grading permits, that occur prior to precise grading permits and building permits, do not require a WQMP.

Attachment C: Monitoring and Reporting: The requirements in the tentative order for monitoring BMPs and outfalls imposes a huge financial burden on the City of Hemet. In order to address the requirements of the tentative order related to monitoring and trash, the City will have to hire staff and purchase equipment as follows:
i. Hire an Environmental Compliance Specialist – to manage the lab results and reporting, reporting and logging of trash, monitoring the outfalls for compliance with the permit, public outreach, biannual out-of-compliance facility reporting, etc. ii. Hire Consultants for Post Construction Structural BMP Inspections, including lab testing iii. Hire a Lead Maintenance Worker – trash collection
iv. Hire a Maintenance Worker II – trash collection
v. Purchase a GapVax Truck for trash collection at outfalls In addition to the aforementioned staff and equipment, the City will also have to pay for the implementation of trash capture devices, SMARTS reporting, municipal facilities inspections, additional inspections for private, industrial, and commercial development, as well as other tasks required to comply with the tentative order. The City has projected these costs to the City of Hemet at approximately $2,860,000 for initial implementation and approximately $1,900,000 for annual operating expenses.

Currently the City’s NPDES program has an annual operating budget of approximately $316,000.

Therefore, the annual operating expenses are projected to increase by more than 500%, without an additional revenue source to cover these expenses. The City of Hemet is a disadvantaged community that does not have an additional $1,500,000 for additional operating expenses within the next several years. This is a massive burden for the City to attempt to come up with without an additional revenue source, and cannot be justified within the City’s current operating budget.

Additionally, the City of Hemet chose Track 1 for the Trash Monitoring program because this track did not require monitoring. Per Section 2.7 (page 20) of the Final Staff Report for the Amendment to the Water Quality Control Plan for the Ocean Waters of California to Control Trash and Part 1 Trash Provisions of the Water Quality Control Plan for Inland Surface Waters, Enclosed Bays, and Estuaries of California, “MS4 permittees complying under Track 1 (by installing, maintaining, and operating a network of full capture systems in the priority land uses) would not have minimum monitoring requirements.” The trash monitoring requirements for Track 1 MS4 permittees is in direct conflict with this staff report. The City requests that this be revised to honor the intended requirements of this staff report.

Proposition 218: Although the order claims that Proposition 218 is an “adequate authority to levy fees to cover the costs of complying with the order”, merely complying with Proposition 218 does not guarantee that the rate payers will in fact not protest to what will likely be a steep increase in fees. Further, the City’s compliance with Proposition 218 is costly and time-consuming, with no guaranteed result. Therefore, the Order does not in fact provide adequate authority as to how the City will pay for compliance with the tentative order.

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City of Hemet Comments on the State of California, California Regional Water Quality Control Board Santa Ana Region Tentative Order R8-2024-0001
3777 Industrial Ave, Hemet, Ca 92545 | 951-765-3712| FAX (951) 765-3712 Sincerely,
Jilleen Ferris, P.E.

Deputy Public Works Director/Assistant City Engineer
City of Hemet

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Santa Ana Regional Water Quality Control Board

AGENDA ANNOUNCEMENT

REGIONAL BOARD MEETING
Friday, September 13, 2024 at 9:00 a.m.

City of Cypress
5275 Orange Avenue
Cypress, CA 90630
And via Video and Teleconference (Gov. Code, § 11123.2) Live Video Webcast
NOTICE:

This meeting will occur with both a physical meeting location and an option to participate by Zoom. A majority of the Board members will be physically present at the noticed meeting location. One or more Board members may participate remotely.

A computer is not required to participate in the meeting; the public will also have the option to dial into the meeting by phone. Additional information regarding virtual meeting participation is available on the Santa Ana Water Board’s website:
https://www.waterboards.ca.gov/santaana/board_info/remote_meeting/index.html Video and Teleconference Option:

For those who only wish to watch the meeting, the webcast remains available at https://cal-span.org/ and should be used UNLESS you intend to comment.

For those who wish to comment on an agenda item by Zoom, please complete the Zoom virtual speaker card available here:
https://us02web.zoom.us/webinar/register/WN_gcVRtwwLRCiJXuNAcN4CMg You must submit a virtual speaker card no later than 5:00 p.m. on Wednesday, September 11, 2024. If you do not submit a virtual speaker card by the deadline, please do so as soon as you can. Virtual speaker cards received after the deadline from remote participants will be accommodated where possible, but virtual participation in the meeting cannot be guaranteed.

Members of the public cannot participate in the Zoom meeting until receiving an email with the password. After you submit the online registration form, you will receive an email with the Zoom weblink and phone numbers to participate in the meeting. If you do not receive a confirmation email with the Zoom information after filling out the online

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Regional Board Meeting
SARWQCB – Region 8 - 2 - September 13, 2024
registration form, please email [email protected] or call 951-782- 3285. If you need assistance during the Board meeting, please email [email protected].

In-person Option:

For those who wish to comment on an agenda item in-person at the physical meeting location, it is highly recommended that you complete a speaker card in advance.

Please complete the Forms virtual speaker card available here:
https://forms.office.com/g/e7DYgDhayB.

You may also fill out a virtual speaker card using the QR Code available at the physical meeting location. At the meeting location, you will see a printed QR Code. To use the QR Code, open your phone’s camera, point the camera at the QR code, and your phone will display a link to forms.office.com. Click on the link, and you will be directed to the virtual speaker card website, where you can sign up to speak on an agenda item.

Please note that commenters will generally be taken in the order of the receipt of the virtual speaker cards. Further note that the Board Chair has the discretion to specify the order of commenters.

ORDER OF AGENDA
Agenda items are numbered for identification purposes only and may not necessarily be considered in this order.

Item 1. Introductions and Declaration of Quorum
Item 2. Public Forum
Any person may address the Santa Ana Water Board on any matter within the Board’s jurisdiction, provided that the matter does not appear elsewhere on the agenda, has not been scheduled to appear on a future agenda, and is not otherwise pending before the Board.

Item 3. State Water Resources Control Board Liaison Report The State Water Board will provide an update on State Water Board activities. {Jayne Joy, 951-782-3284, [email protected]} Item 4. Racial Equity
The Santa Ana Water Board staff will provide an update on the Racial Equity activities. {Jayne Joy, 951-782-3284, [email protected]} Item 5. Regional Board Meeting Minutes of July 26, 2024 The Santa Ana Water Board will consider approval of the Minutes of the Regional Board meeting of July 26, 2024. (Action item)
{Jessica Baenre, 951-782-3285, [email protected]}

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Regional Board Meeting
SARWQCB – Region 8 - 3 - September 13, 2024
Item 6. Consideration of the Consent Calendar
Items below, marked with an asterisk, are expected to be routine and non-controversial.

The Board will be asked to consider these items at one time without discussion. If any interested person, Board Member, or staff requests that an item be removed from the consent calendar, it will be taken up in the order shown.

Item *7. Revising Waste Discharge Requirements Order R8-2024-0042 for Minor Ranch LLC, Menifee Valley Specific Plan Project, Riverside County The Santa Ana Water Board will consider the adoption of the revised Waste Discharge Requirements Order R8-2024-0042 for Menifee Valley Specific Plan Project in Riverside County. The revision includes modifying compensatory mitigation requirements to grant the Discharger a 12-month extension to complete the purchase of mitigation credits and allow the Discharger to begin the Project construction through a valid credit reservation agreement with the mitigation bank.

Order Number R8-2024-0060
{Hossein Shahrokhnia, 951-782-4998, [email protected]} Item 8. Executive Officer’s Report
{Jayne Joy, 951-782-3284, [email protected]} Item 9. Board Member and Executive Officer Communications Santa Ana Water Board Members and the Executive Officer may discuss meetings, communications, correspondence, or other items of general interest, relating to matters within the Board’s jurisdiction. There will be no voting or formal action taken.

Item 10. Workshop on the Regional NPDES Permit and Waste Discharge Requirements for Discharges of Pollutants in Runoff from the Municipal Separate Storm Sewer Systems (MS4s) in the Counties of Orange, Riverside, and San Bernardino (NPDES No. CAS618000)
On March 1, 2024, staff of the Santa Ana Water Board announced the release of a Draft Regional MS4 Permit (Permit) for regulating discharges of pollutants in runoff from MS4s in Orange, Riverside, and San Bernardino Counties on a regionwide basis (Permit) to solicit feedback from permittees and other stakeholders. The comment period ended on July 3, 2024. Santa Ana Water Board staff will present an overview of comments received on the Permit and discuss the anticipated schedule for the public hearing to consider adoption of the Permit. There will also be an opportunity for feedback on the Permit from permittees, other stakeholders, and the public. The Board will not take any action at the workshop.

Order Number R8-2024-0001
{Adam Fischer, 951-320-6363, [email protected]}

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Regional Board Meeting
SARWQCB – Region 8 - 4 - September 13, 2024
Closed Session
At any time during the regular session, the Santa Ana Water Board may adjourn to a closed session to:
a. consider evidence received in an adjudicatory hearing and deliberate on a decision to be reached based on that evidence (Gov. Code, § 11126, subd. (c)(3));
b. consider the appointment, employment, evaluation of performance, or dismissal of a public employee or to hear complaints or charges brought against a public employee (Gov. Code, § 11126, subd. (a)(1)); c. discuss significant exposure to litigation (Gov. Code, § 11126, subd. (e)(2)(B)(i));
d. discuss whether to initiate litigation (Gov. Code, § 11126, subd. (e)(2)(C)(i)); and
e. discuss pending litigation in the following matters (Gov. Code, § 11126, subd. (e)(2)(A)):
(1) In re: Santa Ana Region MS4 Permit – Orange County et al., Commission on State Mandates Test Claim No. 09-TC-03
[Regarding a test claim filed by Orange County, Orange County Flood Control District, and several cities within Orange County alleging that portions of Order No. R8-2009-0030 created unfunded state mandates].
(2) In re: Santa Ana Region MS4 Permit – Riverside County et al., Commission on State Mandates Test Claim No. 10-TC-07
[Regarding a test claim filed by Riverside County, Riverside County Flood Control and Water Conservation District, and several cities within Riverside County alleging that portions of Order No. R8-2010-0033 created unfunded state mandates]. (3) In re: Santa Ana Region MS4 Permit – San Bernardino County et al., Commission on State Mandates Test Claim No. 10-TC-10 [Regarding a test claim filed by San Bernardino County, San Bernardino County Flood Control District, and several cities within San Bernardino County alleging that portions of Order No.

R8-2010-0036 created unfunded state mandates].
(4) In re: Water Code Section 13383(a) MS4 Trash Orders, Commission on State Mandates Test Claim Nos. 17-TC-07 to 17-TC-28 [Regarding 22 different test claims filed by various MS4 permittees within the Santa Ana Region alleging that portions of the Water Code section 13383(a) MS4 Trash Orders issued to each created unfunded state mandates].
{Lori Okun, 916-323-1667, [email protected]} Adjournment
To the regular Board meeting scheduled for October 25, 2024 at 9:00 a.m. Please follow our website for further updates:
https://www.waterboards.ca.gov/santaana/board_info/board_meeting_schedule.html

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Regional Board Meeting
SARWQCB – Region 8 - 5 - September 13, 2024
NOTICES:

Any person who requires reasonable accommodation to participate in this Santa Ana Water Board meeting should contact Jessica Baenre at 951-782-3285 or at [email protected], no later than seven business days prior to the meeting.

If you need interpreter services, contact Jessica Baenre at least seven business days prior to the date of the Board meeting at [email protected].

Any person interested in obtaining information and/or providing input regarding pending applications for Water Quality Certification under section 401 of the federal Clean Water Act, may contact us by email at [email protected].

Changes and postponements that may occur to this agenda will be placed on our website and automatically forwarded to those who subscribe to our electronic mailing list. Anyone wishing to subscribe to our electronic agenda mailing list, may do so as follows: go to Santa Ana Water Board website, select “Subscribe” from the homepage.

Those who are not subscribers should visit our website prior to the Board meeting date to view any changes to the agenda. Supporting documents for agenda items are now posted on our website at least 10 days prior to the scheduled meeting. To view or download the documentation, go to Santa Ana Water Board website and select “Regional Board” then “Agendas” from the homepage.

Any person aggrieved by an action of the Santa Ana Water Board may petition the State Water Board to review the action in accordance with Water Code section 13320 and California Code of Regulations, title 23, section 2050 et seq. The State Water Board must receive the petition by 5:00 p.m., 30 days after the date of the action, except that if the thirtieth day falls on a Saturday, Sunday, or state holiday, the petition must be received by the State Water Board by 5:00 p.m. on the next business day. Copies of the law and regulations applicable to filing petitions will be provided upon request.

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595 S. San Jacinto Ave. | San Jacinto, CA 92583 | Ph 951-487-7330 | Fax 951-654-3728 | www.sanjacintoca.gov Phil Ayala
Mayor
Valerie Vandever
Mayor Pro Tem
Alonso Ledezma
Councilmember
Brian Hawkins
Councilmember
Crystal Ruiz
Councilmember
Robert Johnson
City Manager
July 03, 2024
Santa Ana Regional Water Quality Control Board
Attention: Adam Fischer
3737 Main Street, Suite 500
Riverside, CA 92501
Submitted via email [email protected] Subject: Proposed Order R8-2024-0001, National Pollutant Discharge Elimination System (NPDES) Permit and Waste Discharge Requirements for Discharges of Pollutants in Runoff from the Municipal Separate Storm Sewer Systems (MS4) in the Counties of Orange, Riverside, and San Bernardino within the Santa Ana Region
Dear Mr. Fischer:

The City of San Jacinto (City) appreciates this opportunity to provide written comments on the Proposed Order R8-2024-0001, National Pollutant Discharge Elimination System Permit (NPDES Permit) and Waste Discharge Requirements (WDRs) for Discharges of Pollutants in Runoff from the Municipal Separate Storm Sewer Systems (MS4s) in the Counties of Orange, Riverside, and San Bernardino within the Santa Ana Region (Tentative Order or TO). In addition to the issues discussed in this letter, the City of San Jacinto endorses the comments made by the Tri County Group in a separate letter.

The City of San Jacinto has always been invested in the San Jacinto Watershed and maintaining its beneficial uses. We are one of a few cities to benefit from the geographical location of the San Jacinto River through trails and regional parks that provide views of the River. Nestled against the Lakeview Mountains (commonly known as North Mountain) and the foothills of Mount San Jacinto, the San Jacinto Valley is abundant with scenic vistas and natural resources including a 10,000 acre San Jacinto Wildlife Area, Mystic Lake, and Potrero Creek Conservation Unit, and the Historic De Anza Trail along the San Jacinto River. The River is a key element of the City’s “Live, Play, Work” mission statement.

As such, we appreciate efforts being made to improve the river and the entire watershed. We know that Santa Ana Regional Water Quality Control Board (Regional Board) is striving to protect and enhance the river and other local waterbodies. We aim to be a partner in that effort and work fervently with the Regional Board, other agencies, and private organizations to help accomplish that goal. However, the Tentative Order, while it contains many worthwhile initiatives and provisions, lacks a holistic perspective that considers current efforts, funding, and the unintended impacts on communities. Existing programs and initiatives administered by stakeholders are improving the watershed; it is heading in the right direction. The Tentative Order disregards the progress made and requires drastic and financially infeasible changes.

To feasibly improve the watershed and recognize the progress that has already occurred, the City respectfully submits comments requesting revisions of the new development requirements, highlighting the funding infeasibility of many of the TO requirements, seek exclusion from the Lake Elsinore/Canyon Lake TMDL, requests permission to use the current municipal inspection program, asks for revisions to the findings, and seeks amendment to the Trash Control section to align with the Statewide Trash Amendment language. The City of San Jacinto submits the following comments with additional detail on the City’s various requests and concerns.

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Comment #1 – Request for Revisions Regarding New Development (Including Significant Redevelopment) to Clarify Applicable Projects
The New Development requirements in the Tentative Order have significant changes that will greatly impact development in the City. In addition to the Tri County Group comments, the City wishes to highlight two City specific concerns: 1. requiring a Water Quality Management Plan (WQMP) for roadway projects will causing significant impacts on the City’s ability to repair and rehabilitate roads and 2. the definition of Impervious Surface found in the glossary is prohibitively restrictive.

Comment #1a – Requiring WQMPs for Roadway Projects Will Causing Significant Impacts on the City’s Ability to Repair and Rehabilitate Roads
The current MS4 Permit requires that Permittees prepare a Transportation Project Guidance (TPG) which mandates post construction BMPs where feasible. Transportation improvement projects have specific goals – usually safety, compliance with other Statewide requirements and to reduce road congestion through infrastructure improvements and encouraging alternative modes of transportation. These projects frequently get CEQA approvals through understanding that both water and air quality are improved through the reduction of pollutants associated with stop and go traffic. The inclusion of “Improvement of existing street, road, highway, and freeways affecting 5,000 square feet or more of paved surface used for the transportation of vehicles” into the priority projects category triggers the requirement to prepare a WQMP.

Preparing a WQMP will drastically affect the feasibility of roadway improvement projects. First, roadway improvement projects are inherently limited in space. Second, construction and maintenance costs are at an all-time high; given the funding constraints, adding a WQMP is cost prohibitive to even the simplest of projects. Implementing WQMPs require space and funding that is not available on roadway improvement projects.

Many of the City’s roads are in poor condition and their improvement is one of the highest priorities of the City of San Jacinto residents. The pavement condition within the Southern California Association of Governments (SCAG) regions is currently at 69, whereas San Jacinto is at 60.1. At the same time, the City has many residents who have limited access to transportation options and often relying on alternative modes of transportation, such as walking, in areas where the streets lack sidewalks. With current costs and requirements, if the City of San Jacinto would need to dedicate an estimated $19.5 million toward this effort to achieve parity with the region. San Jacinto’s total annual street improvement budget is only $2 Million, and is mainly comprised of Measure A and RMRA funding. The City’s total annual General Fund budget is only $36 Million; the City simply does not have the resources to add additional requirements to street improvement projects. The City agrees that it is important to include water quality infrastructure where feasible, but requiring all projects to incorporate a WQMP will impair the City’s goal to improve roads.

Adding costs to prepare and implement WQMPs to roadway improvement projects would further deteriorate the City’s ability to serve its residents and improve pavement conditions. It is vital to explicitly exclude projects that do not widen a roadway from the requirement to prepare a WQMP. Most of our roadway improvement projects are in older neighborhoods that have private property to the curb without easements. Additionally, the City expects any added catch basins to require pumps as there is insufficient fall between areas to have the water drain naturally.

Furthermore, requiring the City to add BMPs to roads will result in substantial costs. Most public improvements made by private developers, including funding mechanisms like Community Facility Districts (CFDs), agree to maintain facilities post-construction. CFD laws prohibit the City from adding new facilities to a CFD without an annexation or change to the CFD structure. Requiring BMPs on existing roadways for a road repair or rehabilitation would likely require the City to annex the road to complete the work. This would create significant ongoing maintenance costs and would further deplete the City's limited General Funds. Given the City's General Fund Budget of approximately $36 million, with 62% earmarked for Public Safety, only 38% remains for all other governmental functions. Although Development Impact Fees (DIF) may be available to help construct BMPs, these funds are restricted and cannot be used for ongoing maintenance of facilities.

Therefore, the City would like the Regional Board to understand the prohibitive costs for the ongoing maintenance of BMPs on roads that are currently maintained by private parties.

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The Tentative Order acknowledges that requiring WQMPs for these projects can be excessive as it contains language allowing for the use of USEPA “Green Streets” Guidance. Removing the WQMP requirement for these types of projects and encouraging the use of the “Green Streets” Guidance will both maintain the concurring City goals of improving roads and environmental goals.

Comment #1b – the Definition of Impervious Surface Found in the Glossary is Prohibitively Restrictive The definition of Impervious Surface found in the glossary includes virtually any surface that is “cleared, graded, graveled, paved….” This essentially requires any surface on a construction site to be considered impervious regardless of its future condition. Newly developed parks, landscapes, and gardens that would be great infiltration areas are considered impervious if they are cleared or graded during the project. This inaccurately and unfairly increases the size of post construction BMP treatment which affects the space and funding available to the development project.

In addition, projects intended to improve the environment through alternative modes of transportation are adversely affected by this change of definition. For example, if the City needed to significantly redevelop or create sidewalks or walking trails to encourage more walking it would be required to implement post construction BMPs. Again, space and funding will affect the ultimate feasibility of beneficial environmental projects.

Additionally, in most cases, land acquisition would be necessary for the construction of BMPs. In established residential neighborhoods, it is unlikely that any resident would willingly give up or sell portions of their land adjacent to the roadway (typically front yards) so that the City can remove their landscaping to install a BMP, such as a detention basin. Is it expected that the City will need to use Eminent Domain to condemn a homeowner's yard to comply with the Regional Board's requirements? Moreover, these facilities will need to be substantial, likely requiring the acquisition of one or more full lots to complete the facilities. How does the Regional Board expect cities to displace and then relocate these residents? This approach conflicts with state requirements to provide additional housing throughout the state. Demolishing and displacing existing residences to construct BMPs for an existing roadway is impractical.

Recommendation: Exclude roadway projects from the priority projects list and encourage the use of the USEPA Green Streets Guidance for more projects. Change the definition of Impervious Surface to only those surfaces that are actually impervious in the final, built out state (i.e. concrete, asphalt, hardscape, etc.).

Comment 2: The Increased Requirements Under the TO are Infeasible to Fund The City of San Jacinto is considered a Disadvantaged Community (DAC) and has many neighborhoods that meet the criteria. Compliance with the Tentative Order requires expansion of existing programs and completion of new projects and initiatives with significant financial impacts. These requirements include, but are not limited to, increases to inspection frequencies, training, reporting requirements, and monitoring. This type of work is not funded through grants or other funding options and would have to come from the City’s limited General Fund. Given the City’s currently overwhelmed staffing resources, the City would need to add staff to complete the tasks required under the TO. The City does not have the funding for additional staffing nor can we predict future budgeting. This will result in major financial impacts to our local communities.

Within the City of San Jacinto, 30% of the City’s population, over 16,000 residents, live in designated Senate Bill 535 Disadvantaged Communities. They suffer higher pollutant burdens ranging from the 75th percentile all the way up to the 99th percentile statewide. These communities are economically disadvantaged, and many have faced historical disinvestment which means they lack the same infrastructure found in newer, more affluent communities.

Compliance with the Tentative Order will come at significant cost. This cost will add an additional financial burden to an already adversely affected group. In addition, increased costs associated with roadway projects will reduce the funding

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available for projects outlined in the Riverside PACT and other transportation projects that have, at their core, an environmental improvement interest.

Other branches of the State have suggested that the Regional Board consider costs. In March 2018, the California State Auditor released Report 2017‑118 entitled State and Regional Water Boards - They Must Do More to Ensure That Local Jurisdictions’ Costs to Reduce Storm Water Pollution Are Necessary and Appropriate. 1 Among the many recommendations
found therein, the State Auditor stated:

We would expect that in developing pollutant control plans, regional boards would adequately consider the costs local jurisdictions would incur to comply with the pollutant control plans and would determine the overall cost of storm water management to those jurisdictions so as to make sure that such costs are not prohibitive (p. 1).

Although the Fact Sheet contains a section entitled ‘Economic Considerations’, this section does not adequately consider current costs. This section estimates the cost of MS4 Programs based on requirements and data from 1999 to 2005. It does not sufficiently account for inflation or the requirements and projects found in the Tentative Order. The costs associated with compliance with the Tentative Order are prohibitive and would have significant, adverse impacts on already disadvantaged communities.

As previously noted, the City faces significant legal and financial constraints in funding the construction and ongoing maintenance of BMPs. CFDs and DIFs which are typical funding mechanisms, are either restricted or cannot be applied to such uses. With limited General Funds and the prohibition on using DIFs or CFDs for ongoing maintenance, the financial infeasibility of complying with the Tentative Order is evident. How does the Regional Board propose cities like San Jacinto fund these requirements without access to these traditional funding sources? The Regional Board must consider these constraints and provide realistic funding solutions or exemptions to ensure compliance is achievable without overwhelming the City’s financial resources.

Acquiring land for BMPs in residential areas is impractical and conflicts with state housing requirements. The process would not only be financially prohibitive but would also involve significant legal and ethical challenges, including potential displacement of residents. How does the Regional Board expect cities to acquire the necessary land without resorting to Eminent Domain and displacing residents? How does the Regional Board expect cities to acquire the necessary land in Disadvantaged Communities? The Regional Board needs to reassess these requirements to avoid creating additional housing and social issues, and consider alternative, less disruptive solutions.

The City’s existing drainage issues and the need for extensive storm drain infrastructure highlight the financial and operational burdens of the Tentative Order. Installing and maintaining new water capture facilities require significant funding, which is currently unavailable. The operational costs, including energy and maintenance for pump systems, add to the financial strain. How does the Regional Board intend to support cities financially and logistically in managing these additional infrastructure requirements? The Regional Board should take these challenges into account and provide feasible alternatives or support to manage these additional infrastructure requirements.The Tentative Order clearly places an unsustainable burden on the City of San Jacinto. It is crucial for the Regional Board to reconsider these requirements and seek a balanced approach that acknowledges the financial and logistical challenges faced by municipalities like San Jacinto. What specific measures will the Regional Board take to ensure that disadvantaged communities are not disproportionately impacted by these new requirements?
Recommendation: That the Regional Board perform an in-depth analysis of the financial implications of the Tentative Order using modern cost estimates.

Comment #3 – The City Requests Special Exclusion from the Lake Elsinore/Canyon Lake TMDL 1 https://information.auditor.ca.gov/reports/2017-118/index.html

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The City discharges to Mystic Lake and has not discharged to Canyon Lake in over 25 years. Despite this, the City of San Jacinto has been a party to the Lake Elsinore/Canyon Lake (LE/CL) Nutrient TMDLs for many years and has been an active participant in the LE/CL TMDL Task Force administered by SAWPA. The City believes it should be exempt from the LE/CL TMDLs because it has not discharged into the Canyon Lake for decades.

The Proposed Revisions to the Lake Elsinore and Canyon Lake Nutrient TMDLs TMDL Technical Report (Final Draft) describes the hydrology of Mystic Lake in detail. It states:

Mystic Lake is a large depression area in the San Jacinto River watershed that captures all runoff from the upper watershed. Mystic Lake has a storage capacity of approximately 17,000 AF, which is sufficient to retain all runoff from the upper watershed in most years. However, in those years when Mystic Lake’s storage volume is filled, the lake may overflow, sending large volumes (> 1,000 AF) of water to downstream Canyon Lake. Mystic Lake overflows are known to have occurred in the 1993-1994, 1995- 1996, and 1998-1999 water years but not in subsequent wet years when flow gauge data showed no overflows occurred (e.g., 2004-2005 wet season). The storage capacity of Mystic Lake is changing. United States Geological Survey (USGS) topographic surveys by Dr. D.M. Morton in 2004 and 2014 have shown that the depression that forms Mystic Lake is subsiding at an average rate of ~1 inch/year (in/yr).

Interpretation of these topographic surveys suggests a storage capacity increased by approximately 200- acre feet/year (AFY) from 2004 to 2014. In setting WLAs, the 2004 TMDLs assumed overflows of Mystic Lake would occur in 16 percent of hydrologic years. 2
The currently proposed TMDL revision fails to mention Mystic Lake and instead improperly includes a revised estimate of overflow frequency and volume for use in developing allocations for external loads that considers the rate of subsidence and relevant hydrological conditions. These facts about the watershed and Mystic Lake are not clearly presented in the Tentative Order. These facts impact the implementation requirements for the City of San Jacinto because it indicates that the City should be excluded from the TMDL.

It is our understanding that other Cities are being considered for removal from their applicability to the TMDL because of similar drainage considerations. Furthermore, other Cities in similar situations are excluded from other TMDLs. Given the specific hydrological data of Mystic Lake and resulting impact on San Jacinto River and Canyon Lake, the City of San Jacinto requests the Regional Board to exclude the City from the Lake Elsinore/Canyon Lake TMDL or explain in the Fact Sheet why exclusion is not warranted.

Recommendation: Include Mystic Lake in the considerations supporting the LE/CL Nutrient TMDL and exclude the City from the TMDL.

Comment #4 – The Proposed Municipal Inspections Lack the Necessary Discretion For smaller permittees, changes to the inspection programs, even those considered minor, will cause unintended burdens.

Section XIII of the Tentative Order, providing for municipal inspections of construction, industrial, and commercial sites, does not recognize or allow for the continuation of the inspection programs that have been developed and refined over the past two permit terms. Instead, the TO includes prescriptive language specifying the approach that must be used for the prioritization of facilities/sites and the inspection frequencies. Why does the Tentative Order not recognize the effectiveness and refinement of existing inspection programs that have been in place for 5-10 years? Although an alternative approach is partially allowed for Industrial facilities and allowed for Commercial facilities, it is not allowed for Construction facilities or as a baseline condition of the TO. Instead, each Permittee must submit a written document proposing an alternative prioritization approach and/or inspection frequency and submit it to the Regional 2 Proposed Revisions to the Lake Elsinore and Canyon Lake Nutrient TMDLs TMDL Technical Report (Final Draft)”, December 2023, Page 12

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Board EO for approval. This creates an unnecessary burden on the Permittees to require a justification of the current inspection programs, which have been in place for the past 5-10 years.

Why is an alternative approach allowed for industrial and commercial facilities but not for construction sites, and what is the rationale behind this inconsistency?
Additionally, the Fact Sheet and TO have differing stances on the City’s discretion on inspection frequency. Section XV of the Fact Sheet states:

The Order provides the Permittees substantial discretion to amend their protocol and select the type of inspections and the related level of effort that are suitable to the individual characteristics of a site. This is intended to encourage Permittees to use their experience and observations to evaluate a site’s risk to water quality.

Despite this language in the fact sheet, the TO does not allow for discretion. Discretion is necessary for the City to use the inspection protocols that it has already implemented. In addition, the Fact Sheet does not include any rationale or justification as to why the current prioritization and inspection approaches are not acceptable. What specific issues or deficiencies have been identified in the current prioritization and inspection approaches that justify the need for the proposed changes in the TO? The proposed edits seek to incorporate the flexibility and discretion noted within the Fact Sheet into the TO.

Recommendation: Permittees should be allowed to utilize a current municipal inspection program or approach for the prioritization and frequency of inspections of construction, industrial, and commercial sites Comment #5 – The Tentative Order Findings are Incomplete Since 1990, the Permittees have been implementing programs that have been developed and refined over the past two permit terms. The Findings, as presented in this TO, do not acknowledge, reflect or consider most of these efforts. The Permittees are requesting a more complete Findings with:
• Clear representation of the watershed
• Explanation of current conditions including acknowledgement of the Report of Waste Discharge Reports (ROWDs) and Annual Reports through summarizing accomplishments in the watersheds.

Requested additional Findings:
• Recognize limitations on Regulated Sources and Activities • Reflect the limitations faced by Permittees in regulating urban runoff • Reflect the lack of permittee responsibility for the sources of certain pollutants in MS4s Recommendation: Revise the Findings to acknowledge watershed improvements, limits on Regulated Sources and Activities, and lack of control available to the Permittees relating to certain pollutants and urban runoff.

Comment #6 – The Tentative Order Trash Control Measures Should Mirror State Requirements The Trash Control Requirements within the Tentative Order must be consistent with the Amendments to the Water Quality Control Plan for Inland Surface Waters, Enclosed Bays, and Estuaries (ISWEBE Plan)3(“Statewide Trash Amendments”).

As was presented in the required Statewide Trash Amendments, the Track 1 compliance track was specifically designed to allow permittees to install certified FCS in lieu of performing monitoring. Language from the Statewide Trash Amendments, supporting this interpretation include, but is not limited to, the following:
3 https://www.waterboards.ca.gov/water_issues/programs/trash_control/docs/trash_appendix_e_121615.pdf

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"Track 1 – Demonstrate installation, operation, and maintenance of full capture systems and provide mapped location and drainage area served by full capture systems”
“MS4 permittees complying under Track 1 (by installing, maintaining, and operating a network of full capture systems in the priority land uses) would not have minimum monitoring requirements. Instead, permittees would need to provide an annual report to the applicable Water Board demonstrating installation, operation, and maintenance of full capture systems.”
Why does the Tentative Order include additional requirements that exceed those specified in the Statewide Trash Amendments? How does the Regional Board justify the need for these additional requirements when Track 1 compliance was designed to eliminate the need for minimum monitoring by installing full capture systems? Recommendation: The TO should closely acknowledge and reflect the Statewide Trash Amendment language. No additional requirements should be included.

The City of San Jacinto recognizes and appreciates the diligent work performed by the Regional Board in improving water quality and enhancing beneficial uses in the San Jacinto watershed. We hope that the Regional Board will consider the above comments and continue to work closely with Permittees to refine the Tentative Order into a feasible, practical, and effective Permit. By addressing the concerns raised—such as the financial infeasibility of certain requirements, the need for special exclusions based on unique hydrological conditions, the impracticality of some inspection protocols, and the necessity to align trash control measures with established Statewide Trash Amendments—the Regional Board can ensure that the Tentative Order supports sustainable environmental goals without imposing undue burdens on disadvantaged communities. We are committed to being proactive partners in achieving these shared objectives and look forward to continued collaboration with the Regional Board and other stakeholders.

Respectfully,
_____________________________
Robert A. Johnson
City Manager
City of San Jacinto
Cc:

Adam Fischer [email protected]
Jayne Joy [email protected]

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County Administrative Center ● Fifth Floor ● 4080 Lemon Street ● Riverside, California 92501 Internet – Http://www.countyofriverside.us
Board of Supervisors
District 1 Kevin Jeffries
951-955-1010
District 2 Karen Spiegel
951-955-1020
District 3 Chuck Washington
951-955-1030
District 4 V. Manuel Perez
951-955-1040
District 5 Yxstian Gutierrez
951-955-1050
July 2, 2024
Mr. Adam P. Fischer
Chief, Municipal Stormwater Unit
Santa Ana Regional Water Quality Control Board (RWQB)
3737 Main Street, Suite 500
Riverside, CA 92501
Submitted via email [email protected] Re: Proposed Order No. R8-2024-0001
Dear Mr. Fischer:

On behalf of the County of Riverside Board of Supervisors, which also serves as the Riverside County Flood Control and Water Conservation District, thank you for the opportunity to provide comments on the Santa Ana Water Board’s Tentative Orders (TO), proposed order R8-2024-0001.

The Board of Supervisors supports the joint comments submitted by the Riverside County Flood Control and Water Conservation District, Orange County Public Works, and the San Bernardino County Flood Control District, on behalf of the 60 municipal stormwater permittees as part of the Tri-County Group (TCG) and additionally wishes to make these summary policy level comments.

Our County is committed to paving the way for resilient, ready, and connected communities. Our ask today, is to support a TO that gives us the flexibility to succeed and helps us deliver needed infrastructure improvements and housing for our residents.

As the 4th largest County in California, and 10th largest County in the nation, we must address multiple state and federal mandates, including developing over 40,647 housing units in the unincorporated areas, building the infrastructure to serve our disadvantaged communities and allow for population growth, expanding mental health services, building resilience towards climate change, ensuring public safety, and much, much more. Over 40% of the Santa Ana Watershed contains disadvantaged or severely disadvantaged communities that require significant and challenging investments in infrastructure just to meet basic safety and quality of life needs for residents.

With limited funding and multiple, sometimes conflicting, mandates, our teams have become skilled at addressing as many mandates as possible with each available dollar. We work closely with our various departments to identify and focus on projects that can achieve multiple goals and provide real and powerful benefits whenever possible. We have the most success when regulations give us the flexibility to look long term, develop partnerships and find creative ways to solve problems. Here are a few examples of programs that are already underway in your region:

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Proposed Order No. R8-2024-0001
County of Riverside – Comments

 Santa Ana River Bottom Collaborative – We have formed a multi-agency collaborative to address water quality protection, recreational, public access, educational usage, and wildlife habitat management within the river. This multi-million-dollar investment has put permanent rangers and social service teams in the Santa Ana River to eliminate prohibited activities, provide housing for unhoused river bottom campers, promote improved habitat quality, and reduce the risks of fires to our communities.

 Temescal Floodplain Buyout and Restoration Program – In a similar vein, we have invested over $8 million, and committed an additional $20 million, for the purchase, protection, and restoration of the Temescal Wash floodplain from Lake Elsinore to the City of Corona. This investment is not only preserving the floodplain, but also removing illegal dumping, structures, trash, and other pollutants that had historically impaired these waterway properties.  Investments in Sanitary Sewers – In partnership with local sewer agencies, we are investing over $30 million to deliver mainline sewer systems to the unincorporated communities of Woodcrest, Lakeland Village, Good Hope and Mead Valley. This first step will ultimately allow residents in these disadvantaged communities to convert troubled septic systems to sewers. This will not only benefit our disadvantaged community residents, but also help Goldenstar Creek, Canyon Lake, and other bacteria and nutrient-impaired waterbodies.
 Reclaimed Water Systems – We are investing over $25 million in reclaimed water systems in the Cities of Eastvale, Norco and Corona to not only enhance the reliability of local water supplies, but to also promote the conversion of large public and commercial irrigation systems to reclaimed water irrigation programs that will help eliminate sources of irrigation runoff to municipal separate storm sewer systems (MS4s).

These are just some examples of the long term, meaningful, multiple-purpose investments that we are proudly making to improve our communities and water quality. These programs allow us to comply with multiple state and federal regulatory mandates in a manner that controls the overall cost of housing and services. We believe these efforts are also in the spirit of the Maximum Extent Practical standards that Congress envisioned for MS4 stormwater permits.

Unfortunately, we believe that some provisions in the current draft TO will force the County to redirect our limited resources from powerful multi-benefit programs to technical and administrative programs that, while they may increase reporting, cost, and complexity of compliance, do not provide real, measurable improvements to water quality. Permittee staff have estimated the costs of compliance with the TO at potentially billions across all three counties.

Further, unless permittees can have a clear path to compliance, permittees would be exposed to subjective enforcement or costly third-party suits seeking civil penalties, large attorney’s fees, and injunctive relief.

To this end, much work remains to be done.

We ask that the RWQCB staff take the following actions to ensure the next draft TO will allow Riverside County to both find success and manage the cost of living and housing for our residents. 1) The TO should maintain the flexibility provided in the 2010 Permit for public works projects and provide exemptions for public safety projects. The TO will significantly impact our ability to serve disadvantaged communities. These communities were often subdivided when the County was in its agricultural infancy, with no plan for paved streets, flood control, water and sewer. To this day, these communities have narrow unmaintained streets with no sidewalks, curbs or gutters, lack basic flood protection and are dependent on septic systems and water wells.

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Proposed Order No. R8-2024-0001
County of Riverside – Comments

Delivery of basic infrastructure and public safety measures to these communities is a top priority of the Board of Supervisors, especially considering the many natural disasters our County has faced.

The TO does not fully recognize the challenges of these real-world communities we are trying to help. The expanded TO requirements will place the County in the untenable position of having to minimize or forego infrastructure and safety improvements or having to condemn property, possibly including homes, for water quality features. This could dislocate residents from the very disadvantaged communities we are trying to help. We need exemptions for basic safety projects (e.g., streetlights, sidewalks, flood control and roads). We also need to maintain the 2010 Permit Transportation Project Guideline provisions, which were drafted in recognition of these challenges.
2) The TO must support our state mandated goals for affordable housing. As noted above, the County is expected to deliver 40,647 units of housing pursuant to the state’s Regional Housing Needs Assessment, in order to improve housing affordability as a key statewide goal. Further, the state is promoting the construction of Accessory Dwelling Units (second homes) and residential lot subdivisions to diversify housing opportunities as part of their affordable housing programs. The TO’s proposed revisions to the Water Quality Management Plan and hydromodification management, including removal of important exemptions (e.g. 1-acre exemption), which will make these low-income and affordable housing projects more complex and expensive counter to the state’s housing goals and without commensurate benefit. We ask the RWQCB maintain the provisions identified in the 2010 MS4 Permit for new development, or at minimum, to address the detailed comments on these programs provided in the TCG comments. 3) The Watershed Management Plan (WMP) Reasonable Assurance Analysis (RAA) is too rigid and costly. The RWQCB, has discretion to require alternatives to an RAA. The Permittees need the flexibility to propose programs that are cost effective, achievable, recognize the limits of current technology, and allow us to propose paths to compliance that leverage the type of multiple benefit programs described at the introduction of this letter. Such an approach will allow us to supplement the permit baseline programs described above with the type of creative, collaborative, multi-benefit programs that accelerate real environmental benefits to our communities while also controlling the costs of living and housing. 4) The RWQCB must complete updates to the Lake Elsinore/Canyon Lake Nutrients TMDL (“LE/CL TMDL”) and the Middle Santa Ana Bacteria TMDL (“MSAR TMDL”) prior to adopting the TO. The RWQCB has committed to make several critical updates to these TMDLs but has not adopted them. These updates are foundational to the new MS4 Permit, and if the TMDLs are not updated the TO will unnecessarily expose permittees to potential enforcement and lawsuits until the TMDLs are updated. The RWQCB must complete the process of updating the TMDLs before adopting the new TO.

Further, we are specifically concerned that the TO ignores the Basin Plan and existing MS4 permit language that directs MS4 Permittees to address “controllable sources” of bacteria for the MSAR TMDL. The TO requires regulation of all sources of bacteria – which include natural sources of bacteria that heavily contribute to bacterial exceedances. This would require Permittees to eliminate all dry weather flows from MS4 outfalls to the river at great cost and possibly in direct opposition with state and federal Endangered Species Act requirements.

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Proposed Order No. R8-2024-0001
County of Riverside – Comments

5) The significant revamp of development, inspection and monitoring programs should be abandoned in favor of working with permittees to ensure that existing programs are implemented properly. The TO includes significant expansions of baseline programs to address perceived deficiencies in implementation noted by RWQCB staff. However, the significant revisions do little to improve water quality. Further, the revisions complicate compliance and unnecessarily increase costs to the Permittees, our disadvantaged communities, and efforts to provide affordable housing. Revisions to the development, inspection and monitoring programs should be driven by the Permittees through the WMP process. This will also allow the Permittees to balance available resources between backstop safety net programs like inspection programs with opportunities to pursue multi-benefit collaborations that can truly achieve powerful environmental outcomes for our communities.

Thank you for considering these comments. The Board of Supervisors reserves the right to make additional comments in writing, or before the Santa Ana Water Board, on subsequent drafts of this important permit. Thank you for your consideration. Should you have any questions, please do not hesitate to contact Carolina Herrera, Director of Legislative Advocacy & Governmental Affairs at the County of Riverside Executive Office (951) 955-1180 or [email protected].

Sincerely,
Supervisor Chuck Washington
Chair, County of Riverside Board of Supervisors
cc: Honorable Members, County of Riverside Legislative Delegation

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WT0122151000SAC.SCO June 2015
DRAFT
Enhanced Watershed
Management Program (EWMP)
for the Upper Los Angeles River EWMP Group

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Upper LA River EWMP i Draft June 2015
Table of Contents
Executive Summary....................................................................................................................................................... ES-1 ES.1 Elements of the EWMP................................................................................................................................... ES-1 ES.1.1 Water Quality Priorities ................................................................................................................................ ES-2 ES.1.2 Watershed Control Measures ..................................................................................................................... ES-2 ES.1.3 Reasonable Assurance Analysis................................................................................................................. ES-5 ES.1.4 Detailed EWMP Implementation Strategy and Compliance Schedule...................................... ES-6 ES.1.5 Adaptive Management Framework.......................................................................................................... ES-9 ES.1.6 EWMP Implementation Costs and Financial Strategy ..................................................................... ES-9 Section 1 Introduction.................................................................................................................................................. 1-1

1.1 What Areas are Covered by this EWMP? ..................................................................................................1-2

1.2 Which Regulations are Motivating the EWMP? .....................................................................................1-5

1.2.1 Major Elements of the 2012 MS4 Permit ................................................................................1-5

1.2.2 Role of EWMP for Permit Implementation.............................................................................1-6

1.2.3 Applicable TMDLs and Implementation Schedules............................................................1-7

1.3 EWMP Overview............................................................................................................................................... 1-10 Section 2 Legal Authority ............................................................................................................................................ 2-1

2.1 Permit Section VI.A.2.a......................................................................................................................................2-1

2.2 Permit Section VI.A.2.b......................................................................................................................................2-2 Section 3 Priorities for Water Quality Compliance............................................................................................ 3-1

3.1 Water Quality Characterization (Step 1) ..................................................................................................3-5

3.2 Water Body Pollutant Classification (Step 2) .........................................................................................3-7

3.3 Source Assessment (Step 3) ...........................................................................................................................3-8

3.4 Prioritization (Step 4) .......................................................................................................................................3-8

3.5 Numeric Milestones and Compliance Schedule .....................................................................................3-9 Section 4 Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts ................................................................................................................................................................ 4-1

4.1 What are the Benefits of Regional Projects? ...........................................................................................4-1

4.2 What Types of Regional Projects are Included in the EWMP? ........................................................4-2

4.3 What is the Role of Regional Projects in the EWMP? ..........................................................................4-3

4.4 How were Regional BMPs Selected for the EWMP?.............................................................................4-5

4.5 Which Signature Regional Projects are included in the EWMP?....................................................4-9

4.5.1 North Hollywood Park.................................................................................................................. 4-12

4.5.2 Almansor Park.................................................................................................................................. 4-17

4.5.3 Fremont Park.................................................................................................................................... 4-22

4.5.4 Roosevelt Park ................................................................................................................................. 4-27

4.5.5 Sierra Vista Park.............................................................................................................................. 4-31

4.5.6 San Fernando Regional Park...................................................................................................... 4-36

4.5.7 Lacy Park ............................................................................................................................................ 4-41

4.5.8 Lower Arroyo Park......................................................................................................................... 4-46

4.6 How is the EWMP Integrated with Previous, Ongoing and Future Water Quality Planning Efforts? .................................................................................................................................................................. 4-50

4.6.1 Previous Water Quality Planning Efforts ............................................................................. 4-50

4.6.2 Los Angeles River Restoration and Revitalization Efforts............................................ 4-51

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Table of Contents (Continued)
Upper LA River EWMP ii Draft June 2015

4.6.3 Stormwater Capture Master Plan (City of Los Angeles Department of Water and Power)................................................................................................................................................. 4-53 Section 5 Overview of EWMP Control Measures: Green Infrastructure and Institutional BMPs...... 5-1

5.1 What Types of Green Infrastructure Control Measures are included in the EWMP? ...........5-1

5.2 What is the Role of Green Infrastructure in the EWMP? ...................................................................5-2

5.3 How are Green Streets integrated into the EWMP? .............................................................................5-5

5.4 How is Low Impact Development integrated into the EWMP?.......................................................5-8

5.4.1 LID Ordinance (Redevelopment)................................................................................................5-8

5.4.2 Residential LID....................................................................................................................................5-9

5.4.3 LID on Public Parcels (retrofits).............................................................................................. 5-10

5.4.4 Existing and Planned BMPs........................................................................................................ 5-10

5.5 What are Some Example Green Infrastructure Projects that Support the EWMP? ............ 5-10

5.5.1 Plans to Address Dry- and Wet-Weather Urban Runoff for Downtown Los Angeles, Subwatersheds R2-02 and R2-J................................................................................................ 5-11

5.5.2 Plans to Address Dry- and Wet-Weather Urban Runoff for Downtown Los Angeles, Subwatershed R2-G....................................................................................................................... 5-12

5.5.3 Brandon Street and Green Street Road Improvement Project................................... 5-13

5.5.4 Arroyo Seco Urban Runoff Project No. 1 .............................................................................. 5-14

5.5.5 Arroyo Seco Urban Runoff Project No. 2 .............................................................................. 5-15

5.5.6 Arroyo Seco Urban Runoff Project No. 3 .............................................................................. 5-16

5.5.7 Arroyo Seco Urban Runoff Project No. 4 .............................................................................. 5-17

5.5.8 Arroyo Seco Urban Runoff Project No. 5 .............................................................................. 5-18

5.5.9 Residential Neighborhood “Pilot-to-Scale” Landscape Transformation Project 5-19

5.6 How are Institutional Control Measures incorporated into the EWMP?................................. 5-20 Section 6 Reasonable Assurance Analysis (RAA) ............................................................................................... 6-1

6.1 Modeling System..................................................................................................................................................6-1

6.1.1 LSPC.........................................................................................................................................................6-2

6.1.2 SUSTAIN.................................................................................................................................................6-3

6.2 Baseline Critical Conditions and Required Pollutant Reductions..................................................6-4

6.2.1 Assessment areas...............................................................................................................................6-4

6.2.2 Calibration ............................................................................................................................................6-4

6.2.3 Non-stormwater (dry weather) simulations.........................................................................6-7

6.2.4 Water Quality Targets................................................................................................................... 6-10

6.2.5 Critical Conditions and Required Reductions .................................................................... 6-12

6.2.6 Limiting Pollutant Analysis ........................................................................................................ 6-15

6.2.7 Required Interim and Final Pollutant Reductions ........................................................... 6-18

6.3 Representation of EWMP Control Measures........................................................................................ 6-20

6.3.1 BMP Opportunities......................................................................................................................... 6-20

6.3.2 BMP Configuration......................................................................................................................... 6-22

6.3.3 Cost Functions.................................................................................................................................. 6-23

6.4 BMP Selection .................................................................................................................................................... 6-24

6.4.1 Selection of Control Measures for Final Wet Weather Compliance ......................... 6-24

6.4.2 Selection of Control Measures for Interim Wet Weather Compliance.................... 6-28 Section 7 Detailed EWMP Implementation Strategy and Compliance Schedule..................................... 7-1

7.1 What are the Elements of the EWMP Implementation Strategy? ..................................................7-1

7.2 Which Stormwater Control Measures Correspond to Final Compliance by 2037? ...............7-2

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Table of Contents (Continued)
Upper LA River EWMP iii Draft June 2015

7.3 How are Stormwater Control Measures Scheduled to Achieve EWMP and TMDL Milestones?.............................................................................................................................................................7-8

7.4 How will Non-stormwater be Addressed by the EWMP?............................................................... 7-29

7.4.1 Elimination of Non-stormwater Discharges ....................................................................... 7-29

7.4.2 Dry Weather Strategy for Bacteria TMDL............................................................................ 7-32

7.4.3 Dry Weather Strategy for Metals TMDL and Category 2/3 RWLs ............................ 7-36

7.5 Which Institutional Control Measures are included in the EWMP?........................................... 7-36 Section 8 Compliance Determination and Adaptive Management Framework...................................... 8-1

8.1 Compliance Determination.............................................................................................................................8-1

8.2 Adaptive Management Framework.............................................................................................................8-2

8.2.1 Updates to Water Quality Priorities ..........................................................................................8-3

8.2.2 Updates based on Review of Monitoring Data......................................................................8-4

8.2.3 Updates to RAA Model Parameters............................................................................................8-4

8.2.4 Updates to Preferences for Control Measure Implementation .....................................8-5 Section 9 EWMP Implementation Costs and Financial Strategy ................................................................... 9-1

9.1 EWMP Implementation Costs ........................................................................................................................9-1

9.1.1 EWMP Implementation Costs by Control Measure Type and EWMP/TMDL Milestones .............................................................................................................................................9-2

9.1.2 EWMP Costs by Tributary Area...................................................................................................9-5

9.1.3 Unit Capital Costs by Parcel ..........................................................................................................9-7

9.2 Existing Stormwater Program Costs and Funding Sources..............................................................9-7

9.3 Financial Strategies ............................................................................................................................................9-8

9.3.1 Grants......................................................................................................................................................9-9

9.3.2 Fees and Charges ...............................................................................................................................9-9

9.3.3 Legislative and Policy ......................................................................................................................9-9

9.3.4 Future Steps ...................................................................................................................................... 9-10 Section 10 References..................................................................................................................................................10-1 List of Figures
Figure 1-1. Conceptual Schematic of Regional (left) and Distributed (right) BMP Approaches .........................1-2 Figure 1-2. Upper Los Angeles River EWMP Area and Jurisdictions that Comprise the ULAR EWMP Group ...................................................................................................................................................................................1-3 Figure 3-1. Monitoring Site Locations for Data Utilized in the Water Quality Priorities Process.......................3-6 Figure 4-1. Examples of Types of Regional Projects to be used for EWMP Implementation ...............................4-4 Figure 4-2. Regional Projects included in the ULAR EWMP Implementation Strategy...........................................4-6 Figure 4-3. Relative Capacities of Different Control Measure Categories to be implemented by the ULAR EWMP by 2028. ...............................................................................................................................................................4-7 Figure 4-4. Regional Project Opportunities in the ULAR Watershed Considered by the RAA.............................4-8 Figure 4-5. Summary Facts: North Hollywood Park Signature Project....................................................................... 4-13 Figure 4-6. North Hollywood Park Subsurface Infiltration Drainage Area................................................................ 4-14 Figure 4-7. North Hollywood Park Subsurface Infiltration Site Location .................................................................. 4-15 Figure 4-8. North Hollywood Park Subsurface Infiltration Concept ............................................................................ 4-16 Figure 4-9. Summary Facts: Almansor Park Signature Project....................................................................................... 4-18 Figure 4-10. Almansor Park Surface and Subsurface Drainage Area ........................................................................... 4-19 Figure 4-11. Almansor Park Surface and Subsurface Infiltration Site ......................................................................... 4-20 Figure 4-12. Almansor Park Infiltration Concept.................................................................................................................. 4-21

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Table of Contents (Continued)
Upper LA River EWMP iv Draft June 2015
Figure 4-13. Summary Facts: Fremont Park Signature Project ...................................................................................... 4-23 Figure 4-14. Fremont Park Subsurface Infiltration Drainage Area............................................................................... 4-24 Figure 4-15. Fremont Park Subsurface Infiltration Site Location.................................................................................. 4-25 Figure 4-16. Fremont Park Subsurface Infiltration Concept............................................................................................ 4-26 Figure 4-17. Summary Facts: Roosevelt Park Signature Project.................................................................................... 4-28 Figure 4-18. Roosevelt Park Subsurface Infiltration Drainage Area............................................................................. 4-29 Figure 4-19. Roosevelt Park Subsurface Infiltration Concept ......................................................................................... 4-30 Figure 4-20. Summary Facts: Sierra Vista Park Signature Project ................................................................................ 4-32 Figure 4-21. Sierra Vista Park Drainage Area ......................................................................................................................... 4-33 Figure 4-22. Sierra Vista Park Site Location............................................................................................................................ 4-34 Figure 4-23. Sierra Vista Park Subsurface Infiltration Concept...................................................................................... 4-35 Figure 4-24. Summary Facts: San Fernando Park Signature Project............................................................................ 4-37 Figure 4.25. San Fernando Regional Park Subsurface Infiltration Drainage Area.................................................. 4-38 Figure 4.26. San Fernando Regional Park Subsurface Infiltration Site Location .................................................... 4-39 Figure 4-27. San Fernando Park Subsurface Infiltration Concept................................................................................. 4-40 Figure 4-28. Summary Facts: Lacy Park Signature Project............................................................................................... 4-42 Figure 4-29. Lacy Park Drainage Area........................................................................................................................................ 4-43 Figure 4-30. Lacy Park Site Location .......................................................................................................................................... 4-44 Figure 4-31. Lacy Park Subsurface Infiltration Concept .................................................................................................... 4-45 Figure 4-32. Summary Facts: Lower Arroyo Park Signature Project........................................................................... 4-47 Figure 4-33. Lower Arroyo Park Subsurface Infiltration Drainage Area.................................................................... 4-48 Figure 4-34. Lower Arroyo Park Subsurface Infiltration Site Location....................................................................... 4-49 Figure 4-35. Lower Arroyo Park Subsurface Infiltration Concept................................................................................. 4-50 Figure 4-36. LA River ARBOR / Restoration Areas and Nearby Areas where Regional Projects on Private Land are a Component of the EWMP Implementation Strategy............................................................. 4-54 Figure 4-37. Concept for Strathern Park, future site of a stormwater capture and infiltration project that is integrated into ULAR EWMP.................................................................................................................................. 4-55 Figure 5-1. Conceptual schematic of LID implemented at the site scale........................................................................5-1 Figure 5-2. Conceptual schematic of green street....................................................................................................................5-2 Figure 5-3. Relative Capacity of LID, Green Streets and Regional Control Measures to be implemented by the ULAR EWMP by 2028...................................................................................................................................................5-4 Figure 5-4. Green Street Screened Opportunities in the Upper Los Angeles River EWMP Area ........................5-6 Figure 5-5. Percent of Required Green Street Implementation in the Upper Los Angeles River EWMP Area Relative to Total Available Capacity ......................................................................................................................5-7 Figure 6-1. ULAR EWMP Area and 1,129 Subwatersheds Represented by WMMS. .................................................6-3 Figure 6-2. SUSTAIN Model Interface Illustrating BMP Opportunities in Watershed Settings. ..........................6-4 Figure 6-3. Hydrology and Water Quality Calibration Stations for ULAR RAA...........................................................6-7 Figure 6-4. Example Monte Carlo Model Output for a Bacteria TMDL Load Reduction Strategy .......................6-8 Figure 6-5. Outdoor Water Use Estimates from Literature Review.............................................................................. 6-10 Figure 6-6. Illustration of How Metals Exceedance Volume is Calculated for Critical Condition Determination............................................................................................................................................................... 6-13 Figure 6-7. RAA Process for Establishing Critical Conditions and Addressing Water Quality Priorities..... 6-16 Figure 6-8. Example BMP Solutions for a Selected Subwatershed and Advantage of Cost-Benefit Optimization.................................................................................................................................................................. 6-25 Figure 6-9. Example Cost Optimization Curves for a Watershed: Arroyo Seco ....................................................... 6-26 Figure 6-10. Illustration of how the EWMP Implementation Strategy is Extracted from a Cost Optimization Curve..................................................................................................................................................... 6-27 Figure 6-11. Illustration of Gradually Phasing from Average to Critical Conditions for Interim Milestones....................................................................................................................................................................... 6-29 Figure 7-1. ULAR EWMP Implementation Strategy for Final Compliance by 2037..................................................7-4

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Table of Contents (Continued)
Upper LA River EWMP v Draft June 2015
Figure 7-2. EWMP Implementation Strategy by Subwatershed for Metals and Other Water Quality Priorities (except E. coli).............................................................................................................................................7-5 Figure 7-3. Additional Control Measures in EWMP Implementation Strategy to Address E. coli.......................7-6 Figure 7-4. Additional Control Measures in EWMP Implementation Strategy to Address E. coli.......................7-7 Figure 7-5. City of Los Angeles: Scheduling of EWMP Implementation Strategy to Achieve EWMP / TMDL Milestones............................................................................................................................................................7-9 Figure 7-6. City of Los Angeles (continued): Scheduling of EWMP Implementation Strategy to Achieve EWMP / TMDL Milestones ...................................................................................................................................... 7-10 Figure 7-7. Uninc. LA County: Scheduling of EWMP Implementation Strategy to Achieve EWMP / TMDL Milestones....................................................................................................................................................................... 7-11 Figure 7-8. Uninc. LA County (continued): Scheduling of EWMP Implementation Strategy to Achieve EWMP / TMDL Milestones ...................................................................................................................................... 7-12 Figure 7-9. Alhambra: Scheduling of EWMP Implementation Strategy to Achieve EWMP / TMDL Milestones....................................................................................................................................................................... 7-13 Figure 7-10. Burbank: Scheduling of EWMP Implementation Strategy to Achieve EWMP / TMDL Milestones....................................................................................................................................................................... 7-14 Figure 7-11. Calabasas: Scheduling of EWMP Implementation Strategy to Achieve EWMP / TMDL Milestones....................................................................................................................................................................... 7-15 Figure 7-12. Glendale: Scheduling of EWMP Implementation Strategy to Achieve EWMP / TMDL Milestones....................................................................................................................................................................... 7-16 Figure 7-13. Hidden Hills: Scheduling of EWMP Implementation Strategy to Achieve EWMP / TMDL Milestones....................................................................................................................................................................... 7-17 Figure 7-14. La Canada Flintridge: Scheduling of EWMP Implementation Strategy for Milestones .............. 7-18 Figure 7-15. Montebello: Scheduling of EWMP Implementation Strategy to Achieve EWMP / TMDL Milestones....................................................................................................................................................................... 7-19 Figure 7-16. Monterey Park: Scheduling of EWMP Implementation Strategy to Achieve EWMP / TMDL Milestones....................................................................................................................................................................... 7-20 Figure 7-17. Pasadena: Scheduling of EWMP Implementation Strategy to Achieve EWMP / TMDL Milestones....................................................................................................................................................................... 7-21 Figure 7-18. Rosemead: Scheduling of EWMP Implementation Strategy to Achieve EWMP / TMDL Milestones....................................................................................................................................................................... 7-22 Figure 7-19. San Fernando: Scheduling of EWMP Implementation Strategy for EWMP / TMDL Milestones....................................................................................................................................................................... 7-23 Figure 7-20. San Gabriel: Scheduling of EWMP Implementation Strategy for EWMP / TMDL Milestones. 7-24 Figure 7-21. San Marino: Scheduling of EWMP Implementation Strategy for EWMP / TMDL Milestones . 7-25 Figure 7-22. South El Monte: Scheduling of EWMP Implementation Strategy to Achieve EWMP / TMDL Milestones....................................................................................................................................................................... 7-26 Figure 7-23. South Pasadena: Scheduling of EWMP Implementation Strategy for EWMP / TMDL Milestones....................................................................................................................................................................... 7-27 Figure 7-24. Temple City: Scheduling of EWMP Implementation Strategy for EWMP / TMDL Milestones 7-28 Figure 7-25. Schedule for Eliminating Non-Stormwater Discharges in ULAR. ........................................................ 7-30 Figure 7-26. Non-Stormwater Reductions by Wet Weather Control Measures in ULAR. ................................... 7-31 Figure 7-27. Effect of Priority Outfall Actions on E. coli Loading to Segment B from ULAR EWMP Group. 7-33 Figure 7-28. Drainage Areas for Priority and Outlier Outfalls in Segment B LRS by ULAR EWMP Group .. 7-34 Figure 7-29. Drainage Areas for Preliminary Priority and Outlier Outfalls in City of LA Jurisdictional Area in Arroyo Seco Watershed............................................................................................................................................ 7-35 Figure 8-1. Hypothetical Alternative Control Measure Scenarios to Attain Compliance Targets ......................8-7

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Table of Contents (Continued)
Upper LA River EWMP vi Draft June 2015
List of Tables
Table 1-1. Waterbodies within the ULAR EWMP Area ..........................................................................................................1-4 Table 1-2. ULAR EWMP Agencies and Land Areas ..................................................................................................................1-5 Table 1-3. TMDLs Applicable to the Upper Los Angeles River Watershed Management Area Group..............1-8 Table 1-4. Applicability of WQBELs and RWLs Associated with TMDLs as Identified in the Permit................1-9 Table 1-5. Applicability of Water Quality Based Effluent Limitations and/or Wasteload Allocations Associated with TMDLs for Lakes as Identified in the Permit ................................................................ 1-10 Table 3-1. Category 1 Water Quality Priorities and summary of Compliance Dates and Milestones for TMDLs in the ULAR EWMP area ..............................................................................................................................3-2 Table 3-2. Dry Weather Compliance Milestones for the LAR Bacteria TMDL Applicable to ULAR EWMP Group ...................................................................................................................................................................................3-3 Table 3-3. Water Body-Pollutant Classification Categories (Permit Section IV.C.5.a.ii).........................................3-5 Table 3-4. Details for Water Body-Pollutant Classification Subcategories ...................................................................3-7 Table 3-5. Compliance Schedule for Category 1 and 2 Water Quality Priorities that are not Included in a Regional Board Adopted TMDL ............................................................................................................................ 3-10 Table 3-6. Dry Weather Compliance Milestones for 2,3,7,8-TCDD (Dioxin) with and without the use of a LA River Bacteria Load Reduction Strategy (LRS) based Approach to Dry Weather .......................... 3-11 Table 3-7. Compliance Schedule based on the LA River Metals TMDL for Category 2 and 3 Water Quality Priorities that Do Not Meet the 303(d) Listing Requirements................................................................ 3-11 Table 3-8. Water Quality Priorities where either MS4 discharges are not Considered to be a Source or the Water Body Pollutant Combination is a Condition Rather than a “pollutant” with the Potential to be Discharged from the MS41................................................................................................................................. 3-13 Table 4-1. Signature Regional Projects in the ULAR EWMP............................................................................................. 4-10 Table 4-2. Key Design Parameters for Signature EWMP Projects ................................................................................. 4-11 Table 4-3. Key Design Parameters for North Hollywood Park........................................................................................ 4-12 Table 4-4. Key Design Parameters for Almansor Park........................................................................................................ 4-17 Table 4-5. Key Design Parameters for Fremont Park.......................................................................................................... 4-22 Table 4-6. Key Design Parameters for Roosevelt Park ....................................................................................................... 4-27 Table 4-7. Key Design Parameters for Sierra Vista Park.................................................................................................... 4-31 Table 4-8. Key Design Parameters for San Fernando Regional Park............................................................................ 4-36 Table 4-9. Key Design Parameters for Lacy Park .................................................................................................................. 4-41 Table 4-10. Key Design Parameters for Lower Arroyo Park............................................................................................ 4-46 Table 5-1. Summary of the City of Los Angeles’ Green Infrastructure-related Streets Programs......................5-3 Table 5-2. Permit Requirements................................................................................................................................................... 5-20 Table 6-1. Summary of Hydrology Calibration Performance by Baseline Model.......................................................6-6 Table 6-2. Summary of Water Quality Calibration Performance by Baseline Model ...............................................6-6 Table 6-3. Targets for Modeled Water Quality Priority Pollutants ............................................................................... 6-11 Table 6-4. Zinc Exceedance Volume Summary Statistics for Upper Los Angeles River (acre-feet)................ 6-14 Table 6-5. Limiting Pollutant Selection and Justification for RAA ................................................................................. 6-17 Table 6-6. Limiting ULAR Pollutant Reductions for Interim and Final Compliance .............................................. 6-19 Table 6-7. Summary of BMP Opportunities for Final Compliance RAA....................................................................... 6-21 Table 6-8. Summary of BMP Preferences for ULAR EWMP Agencies .......................................................................... 6-21 Table 6-9. Summary of BMP Design Assumptions for Final Compliance RAA ......................................................... 6-23 Table 6-10. Summary of BMP Cost Functions for Final Compliance RAA (20-year, including O&M)............ 6-24 Table 7-1. Bacteria TMDL Schedule for LRS Submittal to Regional Board by ULAR EWMP Group................ 7-32 Table 7-2. Control Measures identified by Load Reduction Strategy for Segment B of the LA River ............ 7-33 Table 7-3. Preliminary List of Control Measures identified by City of LA for Arroyo Seco LRS ....................... 7-35

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Table of Contents (Continued)
Upper LA River EWMP vii Draft June 2015
Table 7-4. Additional Institutional Control Measures to be Implemented by Select ULAR Agencies............ 7-37 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...8-2 Table 9-1. Summary of Annualized BMP Cost Estimation Formulas...............................................................................9-2 Table 9-2. Total Costs by Milestone for each ULAR EWMP Group member ($ millions)1 .....................................9-2 Table 9-3. Total Costs for each Watershed in the ULAR EWMP Area ($ millions) (Part 1)................................ 9-65 Table 9-3 Total Costs for each Watershed in the ULAR EWMP Area ($ millions) (Part 2)....................................9-6 Table 9-3 Total Costs for each Watershed in the ULAR EWMP Area ($ millions) (Part 3)....................................9-7 Table 9-4. Existing Stormwater Program Costs for ULAR EWMP Group.......................................................................9-8

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Table of Contents (Continued)
Upper LA River EWMP viii Draft June 2015
List of Appendices
1A Background information on Los Angeles County Flood Control District 1B San Gabriel River Portion of South El Monte for Upper Los Angeles River EMWP

2.A Legal Authority

3.A Detailed Description of Water Quality Priorities

3.B Supporting Information for the Receiving Water Data Analysis

3.C Discharge Data Analysis

3.D Source Assessment

4.A Structural Control Measure Fact Sheets

4.B Regional Project Site Selection Process

4.C Engineering and Feasibility for Signature Regional Projects

4.D Pump Plant Conceptual Design Reports

5.A Comparison of 2001 Permit MCMs to 2012 Permit MCMs

5.B Concept Report for the Arroyo Seco Urban Runoff Projects and Arroyo Seco Dry Weather Urban Runoff Projects – Conceptual Design Report

6.A Model Calibration and Parameters

6.B Dry Weather RAA and Non-stormwater Analysis

6.C Control Measure Opportunity Assessment

6.D Control Measure Design and Representation

6.E Green Streets Results Synthesis and List of Opportunities

6.F Detailed List of Existing and Planned Control Measures

6.G Cost Optimization Curves

6.H Approach for Gradual Phasing from Average Interim Conditions to Critical Final Conditions

7.A Detailed Recipe for Final EWMP Compliance (Compliance Targets and EWMP Implementation Strategy)

7.B Subwatershed Index Maps with Control Measure Capacity

7.C Scheduling of Control Measures for TMDL and EWMP Milestones

7.D Segment B Load Reduction Strategy

7.E Details of Enhanced Burbank MCMs and Effectiveness Analysis

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Upper LA River EWMP ix Draft June 2015
Acronyms and Abbreviations
ARBOR Area with Restoration Benefits and Opportunities for Revitalization BMP best management practice
Caltrans California Department of Transportation
CDFW California Department of Fish and Wildlife
cfs cubic feet per second
CIMP Coordinated Integrated Monitoring Program
CTR California Toxics Rule
CWA Clean Water Act
EWMP Enhanced Watershed Management Programs
EWMP Area Upper Los Angeles River Watershed Management Area EWMP Group Upper Los Angeles River Watershed Management Group GIS geographic information system
HFS High Flow Suspension
LA Los Angeles
LACDPW Los Angeles County Department of Public Works
LACFCD Los Angeles County Flood Control District
LAR Lost Angeles Region
LARWQCB Los Angeles Regional Water Quality Control Board LFD Low Flow Diversion System
LID Low Impact Development
LRS load reduction strategy
LSPC Loading Simulation Program – C+
MCM minimum control measure
MS4 Municipal Separate Storm Sewer System
NGO non-governmental organization
NPDES National Pollutant Discharge Elimination System
O&M operations and maintenance
PCB polychlorinated biphenyls
RAA Reasonable Assurance Analysis
RWL receiving water limitation
SCMP Stormwater Capture Master Plan

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Acronyms and Abbreviations
Upper LA River EWMP x Draft June 2015
SUSTAIN System for Urban Stormwater Treatment Analysis and Integration TMDL Total Maximum Daily Load
ULAR Upper Los Angeles River
USEPA U.S. Environmental Protection Agency
WBPC water body-pollutant combination
WLA wasteload allocation
WMMS Watershed Management Modeling System
WQBEL water quality based effluent limit
WQP water quality priority

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Upper LA River EWMP ES-1 Draft June 2015
Executive Summary
The Municipal Separate Storm Sewer System (MS4) Permit Order No. R4-2012-0175 (Permit) for Los Angeles County provides an innovative approach to Permit compliance through development of Enhanced Watershed Management Programs (EWMP). Through a collaborative approach, an EWMP for the Upper Los Angeles River (ULAR) Watershed Management Area (EWMP area) was developed by the ULAR EWMP Group. The ULAR EWMP Group is comprised of the cities of Los Angeles (lead coordinating agency), Alhambra, Burbank, Calabasas, Glendale, Hidden Hills, La Cañada Flintridge, Montebello, Monterey Park, Pasadena, Rosemead, San Fernando, San Gabriel, San Marino, South El Monte, South Pasadena, and Temple City and the County of Los Angeles (Unincorporated County) and the Los Angeles County Flood Control District (LACFCD). By electing to comply with the optional compliance pathway in the MS4 Permit, the ULAR EWMP Group has leveraged this ULAR EWMP to facilitate a robust, comprehensive approach to stormwater management for the Los Angeles River watershed to address the priority water quality conditions in the EWMP area.

The planning area for the ULAR EWMP is the largest of all the EWMPs being developed in the Los Angeles (LA) region, representing 485 square miles of watershed and over 50 miles of mainstem LA River from its headwaters to just above the estuary. The LA River watershed has been subject to numerous water quality planning and compliance efforts, and the EWMP leveraged those efforts and identified additional projects to address water quality issues in the Upper LA River.

The vision for development of the EWMP was to utilize a multi-pollutant approach that maximizes the retention and use of urban runoff as a resource for groundwater recharge and irrigation, while also creating additional benefits for the communities in the ULAR watershed. This EWMP presents a toolbox of distributed and regional watershed control measures to address applicable stormwater quality regulations. Controlling pollutants in stormwater is a major challenge, and the EWMP Group members have been working towards improving stormwater quality for many years by implementing numerous stormwater capture projects across the watershed. State and federal regulations establish compliance timelines to address water quality issues, and this EWMP lays the path forward for implementation of additional water quality improvement projects.

For example, the Los Angeles River watershed is
subject to a Total Maximum Daily Load (TMDL)
for metals that requires compliance by 2028 and a
bacteria TMDL that requires compliance by 2037.

High levels of metals can negatively impact
aquatic life (e.g., fish) in the rivers, creeks and
estuary; elevated bacteria concentrations can
pose a potential health risk to people that
recreate in the watershed. This EWMP plan has
been prepared to address water quality issues
and comply with the Permit requirement and
timelines in a quantitative manner.

ES.1 Elements of the EWMP
The objective of the EWMP Plan is to determine the network of control measures (often referred to as best management practices [BMPs]) that will achieve required pollutant reductions while also providing

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Executive Summary
Upper LA River EWMP ES-2 Draft June 2015
multiple benefits to the community and leveraging sustainable green infrastructure practices. This EWMP includes the following elements:

ES.1.1 Water Quality Priorities
The identification of Water Quality Priorities (Section 3 of the EWMP) was an important first step in the EWMP Plan development process. The Water Quality Priorities highlight the pollutants and waterbodies that are potentially not attaining water quality standards. The Water Quality Priorities are a driver of the control measures in the EWMP. For example, if a water quality objective is not being attained, additional pollutant reduction is required and thus more or larger control measures are needed to achieve those reductions. Over 170,000 data records of water quality monitoring data were compiled and analyzed to determine three categories of Water Quality Priorities based on whether TMDLs have been developed for waterbody-pollutants, whether water quality exceedances have occurred in the last 10 years, and whether the stormwater system is a likely source of these pollutants. The water quality prioritization process of the Permit determines the water body-pollutant combinations (WBPCs) that will be addressed by the EWMP. The Permit defines three categories of Water Quality Priorities:
 Category 1 are pollutants subject to an established TMDL.  Category 2 are pollutants on the State Water Resources Control Board 2010 Clean Water Act Section 303(d) List of Impaired Water Bodies or those constituents that have sufficient exceedances to be listed.
 Category 3 for pollutants with observed exceedances that are too infrequent to be listed, and parameters that are not considered typical pollutants.

The applicable TMDLs are the highest priority for stormwater quality compliance, and thus scheduling for addressing Water Quality Priorities was developed based on TMDL milestones (i.e., interim and final numeric limits) and other representative Regional Board-adopted TMDLs. The scheduling of EWMP implementation is based on the milestones of the applicable metals, toxics and bacteria TMDLs, as follows:
 Achieve a 31 percent milestone for the Los Angeles River Metals TMDL by 2017;  Achieve a 50 percent milestone for the Los Angeles River Metals TMDL by 2024;  Achieve final compliance (100 percent milestone) for the Los Angeles River Metals TMDL by 2028;
 Achieve final compliance for the Los Angeles / Long Beach Harbors Toxics TMDL by 2032; and  Achieve final compliance for the Los Angeles River Bacteria TMDL by 2037.

ES.1.2 Watershed Control Measures
The Permit requires the identification of Watershed Control Measures, which are strategies and BMPs that will implemented through the EWMP, individually or collectively, at watershed-scale to address the Water Quality Priorities. Section 4 of the EWMP describes the regional projects and Section 5 of the EWMP describes the distributed BMPs. The total network of Low Impact Development (LID), green streets and regional BMPs is referred to as the EWMP Implementation Strategy. The BMP capacity to be implemented by 2037 has the equivalent capacity of 20 Rose Bowl stadiums. For EWMP development it was important to establish nomenclature / definitions of the various control measures. Distributed and regional control measures make up the EWMP Implementation Strategy (see figure below for an illustration of distributed versus regional approaches).

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Executive Summary
Upper LA River EWMP ES-3 Draft June 2015

Illustration of Regional (left) and Distributed (right) BMP Approaches The three main categories of structural BMPs include low-impact development, green streets, and regional projects, as defined below:
 Low-Impact Development: distributed structural practices that capture, infiltrate, and/or treat runoff at the parcel, normally less than 10 tributary acres (see LID illustration on next page).

Common LID practices (discussed in Section 5) include bioretention, permeable pavement, and other infiltration BMPs that prevent runoff from leaving a parcel. Rainfall harvest practices such as cisterns can also be used to capture rainwater - that would otherwise run off a parcel - and use it to offset potable water demands. The types of LID incorporated into the EWMP are the LID ordinance, residential LID, and LID retrofits of public parcels. Since the vast majority (nearly 70 percent) of runoff from the developed portion of the watershed is generated from impervious areas on parcels, LID is a natural choice as a key EWMP strategy to treat runoff from parcel-based impervious areas. LID can be viewed as the “first line of defense” due to the fact that the water is treated on-site before it runs off from the parcel and travels downstream.

Illustration of LID implemented on a parcel (arrows indicate water pathways)

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Executive Summary
Upper LA River EWMP ES-4 Draft June 2015
Green Streets: distributed structural
practices that are typically implemented
as linear bioretention/ biofiltration
installed parallel to roadways (see
illustration of a green street on the next
page). These systems receive runoff
from the gutter via curb cuts or curb
extensions (sometimes called bump
outs) and infiltrate it through native or
engineered soil media. Permeable
pavement can also be implemented in
tandem or as a standalone practice, such
as in parking lanes of roads. As shown in
the figure to the right, a high percentage
of streets are planned for green street
retrofits for the EMWP Implementation
Strategy. Green streets have been
demonstrated to provide “complete
streets” benefits in addition to
stormwater management, including
pedestrian safety and traffic calming,
street tree canopy and heat island effect mitigation, increased property values, and even reduced crime rates.

Regional projects: Regional projects are
centralized facilities located near the
downstream ends of large drainage
areas (typically treating 10s to 100s of
acres; see illustration on the next page).

Regional projects receive large volumes
of runoff from extensive upstream areas
and can provide a cost-effective
mechanism for infiltration and pollutant
reduction. . Runoff is typically diverted
to regional projects after it has already
entered storm drains. Routing offsite
runoff to public parcels (versus treating
surface runoff near its source, as with
green streets and LID) often allows
regional BMPs to be placed in costeffective locations. The ULAR EWMP includes over 120 regional BMPs (see
figure to left), including multi-benefit
regional projects that retain the storm
water volume from the 85th percentile,
24-hour storm. The EWMP also includes
regional projects on private land to
assure pollutant reductions are achieved.

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Executive Summary
Upper LA River EWMP ES-5 Draft June 2015
Illustration of a green street (arrows indicate water pathways) Illustration of a regional project (arrows indicate water pathways) ES.1.3 Reasonable Assurance Analysis
A key element of each EWMP is the Reasonable Assurance Analysis (RAA) (presented in Section 6), which was used to quantitatively demonstrate that the EWMP Implementation Strategy will address the Water Quality Priorities. While the Permit prescribes the RAA as a quantitative demonstration that control measures will be effective, the RAA also uses a modeling process to identify and select potential control measures to be implemented by the EWMP. The Watershed Management Modeling System

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Executive Summary
Upper LA River EWMP ES-6 Draft June 2015
(WMMS) is the basis for the modeling system used to conduct the RAA for the ULAR EWMP. WMMS is specified in the 2012 MS4 Permit as an approved tool to conduct the RAA. The LACFCD, through a joint effort with U.S. Environmental Protection Agency (USEPA), developed WMMS specifically to support informed decisions for managing stormwater.

The RAA demonstrates the calibrated modeling system is able to accurately predict flows and pollutant concentration in the LA River watershed. The RAA was developed based on complying with the applicable criteria for “limiting pollutants” during 90th percentile storm conditions. Limiting pollutants are the pollutants that drive BMP capacity (i.e., control measures that address the limiting pollutant will also address other pollutants). The limiting pollutants for ULAR are as follows:
 Wet weather – zinc and E. coli: according to the modeling analysis and review of monitoring data, control of zinc and E. coli requires BMP capacities that are the largest among the Water Quality Priority (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 ULAR first identifies the control measures to attain zinc limits (during the zinc critical condition) and then identifies additional capacity, if any, needed to achieve E.coli limits.
 Dry weather – E. coli: among all the pollutants monitored during dry weather at mass emission stations in LA County, E. coli most frequently exceeds receiving water limitation (RWLs). During monitoring “snapshots” of over 100 outfalls along the LA River, over 85 percent of samples exceeded limits for E. coli during dry weather through the Bacteria Source Identification Study along the Los Angeles River (CREST, 2008). Among the dry weather WQP pollutants, achievement of dry weather RWLs for E. coli will be the most challenging.

The RAA was used to select the BMPs in the EWMP Implementation Strategy based on three primary elements:
 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 WMMS considered millions of BMP scenarios and the EWMP Implementation Strategy was selected based on the most cost-effective scenarios, while incorporating the input from the EWMP Group related to the needs and opportunities within the communities.

ES.1.4 Detailed EWMP Implementation Strategy and Compliance Schedule The EWMP Implementation Strategy (presented in Section 7) is the “recipe for compliance” of each jurisdiction to address Water Quality Priorities and comply with the provisions of the MS4 Permit. The EWMP Implementation Strategy includes individual recipes for each of the 18 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.

Implementation of the EWMP Implementation Strategy will provide a BMP-based compliance pathway for each jurisdiction under the MS4 Permit.

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Executive Summary
Upper LA River EWMP ES-7 Draft June 2015
The EWMP Implementation Strategy is expressed in terms of [1] the volumes 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, 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 managed is considered the BMP performance goal for the EWMP.  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 RAA modeling framework has been used to quantitatively demonstrate that the EWMP Implementation Strategy will address the Water Quality Priorities.

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. The LID, green street and regional projects that will address the Water Quality Priorities is a network of control measures with the equivalent capacity of approximately 20 Rose Bowl stadiums. As shown in the figure below, for the set of BMPs to be implemented across the entire ULAR EWMP area by 2028, regional projects on public land make up 26 percent of the total control measure capacity. LID and green streets each make up 14 percent and 30 percent respectively. The EWMP Implementation Strategy will be validated and updated over time following review of water quality monitoring data through an adaptive management approach.

The EWMP Implementation Strategy is ultimately a recipe for compliance for each jurisdiction and subwatershed in the EWMP area. A total of 1,119 subwatersheds (see figure at top of next page) are provided a specific set of LID, green street and regional control measures. 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 EMWP Plan includes tabular versions of the map to the right in detailed appendices for each jurisdiction.

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Executive Summary
Upper LA River EWMP ES-8 Draft June 2015
The total capacity of LID, green
streets and regional BMPs to be
implemented by each jurisdiction by
2037 (the final compliance date for
addressing E. coli) is shown in the
bar chart at the bottom of this page.

The strategy varies by jurisdiction
depending on the pollutant
reduction requirements and BMP
preferences. The top panel groups
the BMP types into LID, green
streets and regional BMPs, while the
bottom panel provides more
resolution for the BMP subcategories.

The pace of implementation for the
EWMP Implementation Strategy is
rapid due to the compliance dates
specified in the LA River Metals
TMDL (interim milestones in 2017
and 2024), Los Angeles Harbor
Toxics TMDL (final compliance by 2032) and Los Angeles River Bacteria TMDL (final compliance by 2037). The scheduling of BMPs across all 18 jurisdictions to be implemented to achieve those milestones/compliance dates is shown in the figure on the next page.

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Executive Summary
Upper LA River EWMP ES-9 Draft June 2015
ES.1.5 Adaptive Management Framework
One of the key components of the EWMP is the incorporation of an Adaptive Management Approach for evaluating monitoring data and “lessons learned” or experience gained during implementation to evaluate EWMP implementation progress. The Permit specifies that an adaptive management process will be revisited every two years to evaluate the EWMP and update the program. The EWMP strategy will evolve based on monitoring results by identifying updates to the EWMP Implementation Plan to increase its effectiveness.

ES.1.6 EWMP Implementation Costs and Financial Strategy The costs to implement the EWMP will require orders of magnitude increases in stormwater program funding. The capital costs to address Water Quality Priorities by 2037 is estimated at over $6.0 billion, with total operations and maintenance costs exceeding $210 million per year once fully implemented (see table below). Expenditures for the EWMP Implementation Strategy will 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, the multi-benefits of the LID, green streets and regional projects will be quantified including improved aesthetics, increased recreational opportunity, water supply augmentation and climate change resiliency. 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.

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 168.78 17.01 458.65 55.27 2,889.50 176.91 2,580.94 210.84 6,097.87 210.84 Costs in units of $ million

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Executive Summary
Upper LA River EWMP ES-10 Draft June 2015

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Upper LA River EWMP 1-1 Draft June 2015
Section 1
Introduction
This Enhanced Watershed Management Program for the Upper Los Angeles River (ULAR EWMP) describes a customized compliance pathway that participating agencies will follow to address the pollutant reduction requirements of the 2012 Municipal Separate Storm Sewer System (MS4) Permit (Order No. R4‐2012‐0175; National Pollutant Discharge Elimination System [NPDES] Permit No.

CAS004001). By electing the optional compliance pathway in the MS4 Permit, the Upper Los Angeles River Watershed Management Group (EWMP Group) has leveraged this EWMP to facilitate a robust, comprehensive approach to stormwater planning for the Upper Los Angeles River watershed. This EWMP builds upon multiple previously-developed planning efforts1 and identifies a detailed implementation strategy that provides not only water quality improvement but also environmental, aesthetic, recreational, water supply and/or other community enhancements. The strategy has been developed through an extensive stakeholder coordination process including three public workshops and numerous one-on-one meetings.

A total of 19 MS4 Permittees comprise the EWMP Group (“Group members” or “jurisdictions”) including the cities of Los Angeles (lead coordinating agency), Alhambra, Burbank, Calabasas, Glendale, Hidden Hills, La Cañada Flintridge, Montebello, Monterey Park, Pasadena, Rosemead, San Fernando, San Gabriel, San Marino, South El Monte, South Pasadena, and Temple City, plus the County of Los Angeles, and the Los Angeles County Flood Control District (LACFCD)2. The City of South El Monte3 joined the original 18 Group members through a letter of intent4 submitted February 26, 2015.

The vision for development of the EWMP was to utilize a multi-pollutant approach that maximizes the retention and use of urban runoff as a resource for groundwater recharge and irrigation, while also creating additional benefits for the communities in the ULAR watershed. This EWMP presents a toolbox of distributed and regional watershed control measures (see Figure 1-1) to address applicable stormwater quality regulations including the following:
 Low impact development: control measures implemented on parcels to retain stormwater runoff during rain events. For the EWMP, the Group members’ LID ordinances are also incorporated. In addition, residential LID programs are incorporated to incentivize adoption of rain cisterns and other methods to reduce runoff from residential properties, while also facilitating community engagement and awareness. Group members will also implement LID retrofits on public parcels.
 Green streets: the right-of-way along streets offers a significant opportunity to implement control measures on public land. The EWMP includes extensive green streets to retain runoff from

1 A Work Plan for the ULAR EWMP was submitted to the Regional Board in June 2014. The Work Plan described the work efforts and analyses that support this EMWP development.” 2 See Appendix 1A for background information on the Los Angeles County Flood Control District. 3 A portion of South El Monte drains to the San Gabriel River watershed, which is covered by this ULAR EWMP.

Details on the analyses and results for the San Gabriel River portion of South El Monte are provided in Appendix 1B. 4 Letter of Intent to join EWMP and CIMP from Anthony Ybarra, City of South El Monte City Manager, to Sam Unger, California Regional Water Quality Control Board, Los Angeles Region Executive Officer, dated February 26, 2015.

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Section 1  Introduction
Upper LA River EWMP 1-2 Draft June 2015
roads and alleys. Green streets will potentially offer many other benefits to communities in terms of aesthetics, safety and increased property values.
 Regional projects: these control measures are an emphasis of the Permit because they are able to capture runoff from large upstream areas. The EWMP emphasizes implementation of regional projects, particularly those that are able to retain the 85th percentile, 24-hour storm event. The ULAR EWMP includes 128 regional BMPs, including multi-benefit regional projects that retain the storm water volume from the 85th percentile, 24-hour storm for the drainage areas tributary to the multi-benefit regional projects. In addition, the EWMP includes regional projects on private land to assure required pollutant reductions are achieved.  Institutional control measures: these control measures can be cost-effective because they prevent transport of pollutants in the watershed without building structures. The MS4 Permit requires Group Members to implement minimum control measures (MCMs), which are a subset of institutional control measures that may be enhanced over the course of EWMP implementation.

Collectively, these measures make up the “EWMP Implementation Strategy” also referred to as the “recipe for compliance,” for the Group members. The EWMP Implementation Strategy is quantitatively robust, as modeling was used to demonstrate that RWLs and/or WQBELs will be achieved by the identified control measures, via a Reasonable Assurance Analysis (RAA). Over time, through adaptive management, the EWMP Implementation Strategy will evolve based on monitoring results, lessons learned during implementation and other factors.

Figure 1-1. Conceptual Schematic of Regional (left) and Distributed (right) BMP Approaches

1.1 What Areas are Covered by this EWMP?
The area included in the ULAR EWMP is the largest of all the EWMP areas in Los Angeles County, approximately 485 square miles (Figure 1-2). The Los Angeles River is approximately 55 miles long, and five of six reaches lie within the ULAR EWMP area. The4 natural hydrology of the Los Angeles River watershed has been altered by channelization and the construction of dams and flood control reservoirs.

The Los Angeles River and many of its tributaries are lined with concrete for most or all of their length.

Soft-bottomed segments of the Los Angeles River occur where groundwater upwelling prevents armoring of the river bottom, most notably at the Glendale Narrows.

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Section 1  Introduction
Upper LA River EWMP 1-3 Draft June 2015
Figure 1-2. Upper Los Angeles River EWMP Area and Jurisdictions that Comprise the ULAR EWMP Group

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Section 1  Introduction
Upper LA River EWMP 1-4 Draft June 2015
The Los Angeles River is segmented into six reaches by the California Water Quality Control Plan, Los Angeles Region (Basin Plan) as follows: (listed from upstream to downstream; reach breaks are shown in Figure 1-2):
 Reach 6 begins at the headwaters of the Los Angeles River (the confluence of Arroyo Calabasas and Bell Creek) and extends to Balboa Boulevard.
 Reach 5 runs from Balboa Boulevard through the Sepulveda Basin.  Reach 4 runs from Sepulveda Dam to Riverside Drive.
 Reach 3 runs from Riverside Drive to Figueroa Street.  Reach 2 runs from Figueroa Street to Carson Street.
 Reach 1 runs from Carson Street to the estuary.

Major tributaries to ULAR EWMP area include Aliso Canyon Creek, Bell Creek, Bull Creek, Tujunga Wash, Burbank Western Channel, Arroyo Seco, Rio Hondo, and Compton Creek. The major water bodies in the ULAR EWMP area are summarized in Table 1-1. The ULAR EWMP area also includes Lake Calabasas, Echo Park Lake, and Legg Lake.

Table 1-1. Waterbodies within the ULAR EWMP Area
Waterbody Associated Major Tributaries
LA River Reach 6
Dry Canyon Creek
McCoy Creek
Bell Creek
Aliso Canyon Wash
LA River Reach 5 Bull Creek
LA River Reach 4 Pacoima Wash
Tujunga Wash
LA River Reach 3
Burbank West Channel
Verdugo Wash
Arroyo Seco
LA River Reach 2 Rio Hondo Reach 2 and 3
Compton Creek
Echo Park Lake
Legg Lake
Calabasas Lake
Collectively, the ULAR EWMP area makes up over 58 percent of the total LA River watershed area. A breakdown of the areas associated with the participating MS4 Permittees is provided in Table 1-2. All drainage infrastructure operated and maintained by the LACFCD within the ULAR EWMP area have been covered under this EWMP. It should be noted that agencies participating in the ULAR EWMP have no jurisdiction over the land owned by the State of California (i.e., California Department of Fish and Wildlife [CDFW], the State Lands Commission, and California Department of Transportation [Caltrans]) and the U.S. Government.

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Section 1  Introduction
Upper LA River EWMP 1-5 Draft June 2015
Table 1-2. ULAR EWMP Agencies and Land Areas
Agency Land Area (Acres) % of EWMP Area
City of Los Angeles 181,288.00 58.48
County of Los Angeles 41,048.07 13.24

LACFCD NA N/A
City of Alhambra 4,884.31 1.58
City of Burbank 11,095.20 3.58
City of Calabasas 4,005.68 1.29
City of Glendale 19,587.50 6.32
City of Hidden Hills 961.03 0.31
City of La Canada Flintridge 5,534.46 1.79
City of Montebello 5,356.38 1.73
City of Monterey Park 4,951.51 1.60
City of Pasadena 14,805.30 4.78
City of Rosemead 3,310.87 1.07
City of San Fernando 1,517.64 0.49
City of San Gabriel 2,644.87 0.85
City of San Marino 2,409.64 0.78
City of South El Monte 1,823.94 0.59
City of South Pasadena 2,186.20 0.71
City of Temple City 2,576.50 0.83
Area of ULAR EWMP Agencies 309,987.10 100

1.2 Which Regulations are Motivating the EWMP?
While the EWMP comprises a multi-faceted document/program that is far broader than stormwater compliance, its fundamental purpose is to respond to regulatory requirements. Elements of the regulatory framework, including the MS4 Permit and applicable schedules for total maximum daily loads (TMDLs), are described in the following subsections.

1.2.1 Major Elements of the 2012 MS4 Permit
The Los Angeles Regional Water Quality Control Board (LARWQCB) adopted Waste Discharge Requirements for MS4 discharges within the Coastal Watersheds of Los Angeles County, except those discharges originating from the City of Long Beach MS4 (Order No. R4‐2012‐0175; NPDES Permit No.

CAS004001) on November 8, 2012 (referred to herein as the MS4 Permit or Permit). The MS4 Permit, which became effective on December 28, 2012, applies to the LACFCD, County of Los Angeles and 84 incorporated cities within Los Angeles County, including cities in the ULAR watershed. The MS4 Permit replaces the 2001 MS4 permit.

The 2012 MS4 Permit contains effluent limitations, receiving water limitations (RWLs), minimum control measures (MCMs), and TMDL provisions, and outlines the process for developing watershed management programs, including the EWMP. The MS4 Permit incorporates the TMDL Wasteload

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Section 1  Introduction
Upper LA River EWMP 1-6 Draft June 2015
Allocations (WLAs) applicable to dry- and wet- weather as water quality based effluent limits (WQBELs) and/or RWLs. Section V.A of the Permit requires compliance with the WQBELs as outlined by the respective TMDLs. The EWMP provides a compliance pathway for attaining these limitations, as described in the next subsection.

The MS4 Permit also requires Permittees to implement MCMs to protect water quality in receiving waters (Part VI.D). Unlike previous Permits, the 2012 Permit allows for the modification of MCMs to more effectively address the highest priority water quality conditions. Permittees can evaluate current MCMs, identify potential modifications that will address Water Quality Priorities, and provide justification for modification and/or elimination of any MCM that is determined to not be applicable to the Permittee (with the exception of MCMs in the Planning and Land Development Program, which may not be eliminated). At this time, no Group members have elected to formally customize their MCMs, but may choose to do so over the course of EWMP implementation. Customization may include replacement of an MCM for a more effective measure, reduced implementation of an MCM, augmented implementation of the MCM, focusing the MCM on the water quality priority (WQP), or elimination of an MCM.

1.2.2 Role of EWMP for Permit Implementation
The EWMP provides a compliance pathway for attaining RWLs and WQBELs limitations. The definition of an EWMP, provided in Permit Section VI.C.1.g., is as follows:
“EWMP is one that comprehensively evaluates opportunities, within the participating Permittees’ collective jurisdictional area in a Watershed Management Area, for collaboration among Permittees and other partners on multi-benefit regional projects that, wherever feasible, retain (i) all non-storm water runoff and (ii) all storm water runoff from the 85th percentile, 24-hour storm event for the drainage areas tributary to the projects, while also achieving other benefits including flood control and water supply, among others. In drainage areas within the EWMP area where retention of the 85th percentile, 24-hour storm event is not feasible, the EWMP shall include a Reasonable Assurance Analysis (RAA) to demonstrate that applicable WQBELs and RWLs shall be achieved through implementation of other watershed control measures. An EWMP shall:
i. Be consistent with the provisions in Part VI.C.1.a.-f and VI.C.5-C.8; ii. Incorporate applicable State agency input on priority setting and other key implementation issues;
iii. Provide for meeting water quality standards and other CWA obligations by utilizing provisions in the CWA and its implementing regulations, policies and guidance; iv. Include multi-benefit regional projects to ensure that MS4 discharges achieve compliance with all final WQBELs set forth in Part VI.E. and do not cause or contribute to exceedances of receiving water limitations in Part V.A. by retaining through infiltration or capture and reuse the storm water volume from the 85th percentile, 24-hour storm for the drainage areas tributary to the multi-benefit regional projects.;
v. In drainage areas where retention of the storm water volume from the 85th percentile, 24- hour event is not technically feasible, include other watershed control measures to ensure that MS4 discharges achieve compliance with all interim and final WQBELs set forth in Part VI.E. with

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Section 1  Introduction
Upper LA River EWMP 1-7 Draft June 2015
compliance deadlines occurring after approval of a EWMP and to ensure that MS4 discharges do not cause or contribute to exceedances of receiving water imitations in Part V.A.; vi. Maximize the effectiveness of funds through analysis of alternatives and the selection and sequencing of actions needed to address human health and water quality related challenges and non-compliance;
vii. Incorporate effective innovative technologies, approaches and practices, including green infrastructure;
viii. Ensure that existing requirements to comply with technology-based effluent limitations and core requirements (e.g., including elimination of non-storm water discharges of pollutants through the MS4, and controls to reduce the discharge of pollutants in storm water to the maximum extent practicable) are not delayed;
ix. Ensure that a financial strategy is in place.”
The ULAR EWMP meets all of these requirements as prescribed by the Permit.

1.2.3 Applicable TMDLs and Implementation Schedules
A primary driver of the extent and scheduling of control measures that make up the EWMP Implementation Strategy are the applicable TMDLs in the LA River watershed. Section 303(d) of the Clean Water Act (CWA) requires states to prepare a list of water bodies that do not meet water quality standards and establish for each of these water bodies load and waste load allocations (load refers to pollutants), that is, a TMDL that will ensure attainment of water quality standards. A TMDL represents an amount of pollution that can be released by anthropogenic and natural sources of a watershed into a specific water body without causing a decline in water quality and beneficial uses. Unlike federal law, State law requires Regional Boards to include an implementation plan for TMDLs and these plans generally include compliance schedules.

A summary of the existing TMDLs for the ULAR is presented in the following tables:
 Table 1-3 presents TMDLs developed for water bodies within the ULAR EWMP area and also TMDLs for downstream waterbodies.
 Table 1-4 (mainstem and tributaries) and Table 1-5 (lakes) show where the Permit assigns WQBELs, RWLs, or WLAs to Permittees within the ULAR EWMP area. The numeric WQBELs and RWLs as well as the WLAs for the USEPA TMDLs listed in Table 1-3 and Table 1-4 can be found in Attachments N and O of the Permit.
 A summary of the WLAs contained within these TMDLs applicable to participants in the ULAR EWMP area is provided in Appendix 1.A. These WLAs provide the overall water quality targets to be achieved through implementation of the EWMP and are key considerations for the RAA.  Some of the Regional Board-adopted TMDLs presented in Table 1-3 required responsible parties to submit a TMDL Implementation Plan to describe how they would achieve compliance with the WLAs. The cities of Los Angeles, Alhambra, Burbank, Calabasas, Glendale, Hidden Hills, La Cañada Flintridge, Montebello, Monterey Park, Pasadena, Rosemead, San Fernando, San Gabriel, San Marino, South Pasadena, and Temple City, and Caltrans submitted TMDL Implementation Plans to address the impairments contained within the Metals TMDL. Additionally, the County of Los

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Section 1  Introduction
Upper LA River EWMP 1-8 Draft June 2015
Angeles and LACFCD submitted an integrated TMDL Implementation Plan to address multiple impairments. Once approved, the ULAR EWMP will take the place of those individual TMDL Implementation Plans.

Table 1-3. TMDLs Applicable to the Upper Los Angeles River Watershed Management Area Group TMDL
LARWQCB Resolution
Number
Effective Date and/or
EPA Approval Date
LA River Nitrogen Compounds and Related Effects
2003-009 03/23/2004
2012-010 (amended) 08/07/2014
Legg Lake Trash TMDL 2007-010 03/06/2008
LA River Trash 2007-012 09/23/2008
LA River Metals TMDL
2007-014 10/29/2008
2010-003 (amended) 11/03/2011
LA River Bacteria TMDL 2010-007 03/23/2012
Dominguez Channel and Greater Los Angeles and Long
Beach Harbor Waters Toxic Pollutants TMDL 2011-008 03/23/2012 Los Angeles Area Lakes TMDLs for Lake Calabasas, Echo
Park Lake, and Legg Lake
NA
(USEPA TMDL)
03/26/2012

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Section 1  Introduction
Upper LA River EWMP 1-9 Draft June 2015
Table 1-4. Applicability of WQBELs and RWLs Associated with TMDLs as Identified in the Permit TMDL Constituent
LA River Reaches
1 – 6
Compton
Creek
Rio
Hondo
R1 – R3
Arroyo
Seco
Verdugo
Wash
Burbank
Western
Channel
Tujunga
Wash
Bell
Creek
Bull Creek
Aliso Canyon Wash
McCoy Canyon
Dry Canyon
LAR Trash Trash E E E E E E E E E
LAR
Nutrients
Ammonia -N E E E E E E E E E
Nitrate – N E E E E E E E E E
Nitrite – N E E E E E E E E E
Nitrate as N +
Nitrite as N E E E E E E E E E
LAR Metals
Copper and
Lead (dry and
wet weather)
E E E
1 E E E E E --
Zinc
(dry weather) -- -- E
1 -- -- -- -- -- --
Zinc
(wet weather) E E E E E E E E --
Cadmium
(wet weather) E E E E E E E E --
DC and
LA/LB
Harbors
Toxics
Sediment:

DDTs, PCBs,
Copper, Lead,
Zinc, PAHs
-- -- -- -- -- -- -- -- --
LAR Bacteria E. coli E/R E/R E/R E/R E/R E/R E/R E/R E/R Note that unless explicitly stated as sediment, constituents are associated with the water column E – Effluent limit established based on a TMDL.

R – Receiving water limit established based on a TMDL.
1 – The dry weather metals limits only apply to Rio Hondo Reach 1.

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Section 1  Introduction
Upper LA River EWMP 1-10 Draft June 2015
Table 1-5. Applicability of Water Quality Based Effluent Limitations and/or Wasteload Allocations Associated with TMDLs for Lakes as Identified in the Permit TMDL Constituents
Lake
Legg Calabasas Echo Park
Legg Lake Trash TMDL Trash E
USEPA Lakes TMDLs
Total-P WLA WLA WLA
Total-N WLA WLA WLA
Trash WLA
PCBs (water and sediment) WLA
Chlordane (water and sediment) WLA
Dieldrin (water and sediment) WLA
Note that unless explicitly stated as sediment, constituents are associated with the water column.

E – Effluent limit established based on a TMDL.

PCB – polychlorinated biphenyls
WLA – Wasteload Allocation assigned in a USEPA TMDL, but not included as effluent or receiving water limitations.

1.3 EWMP Overview
The remainder of this EWMP includes the following sections:
 Section 2 – Legal Authority: Presents the legal authority of each participating Permittee to implement or compel implementation of watershed control measures.  Section 3 – Priorities for Water Quality Compliance: Presents the process to identify and prioritize water quality impairments in the watershed based on review of available monitoring data. The water quality prioritization process of the Permit was used to determine the water body-pollutant combinations (WBPCs) that will be addressed by the EWMP. Note the EWMP Group has also developed a Coordinated Integrated Monitoring Program (CIMP) to collect water quality data and measure the effectiveness of the EWMP.  Section 4 – Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts: Provides an overview of the benefits and role of regional projects in the EWMP and the detailed screening and analysis process used to prioritize regional project opportunities in the ULAR watershed. In addition, this section highlights signature regional projects that have been evaluated through detailed conceptual level designs by each of the EWMP Group members. Finally, EWMP incorporates and will align with other regional planning efforts underway by many other agencies and organizations (e.g., the LA River Ecosystem Restoration Feasibility Study and the Stormwater Capture Master Plan),  Section 5 – Overview of EWMP Control Measures: Green Infrastructure and Institutional Control Measures: Complementary to the regional BMP program introduced in Section 4, robust green infrastructure programs will be critical to achieving water quality compliance in the Upper LA River watershed. This section provides a summary of the green infrastructure programs within the EWMP and highlights several signature projects as an example of the types of efforts that are upcoming and ongoing.

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Section 1  Introduction
Upper LA River EWMP 1-11 Draft June 2015
 Section 6 – Reasonable Assurance Analysis Approach: 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.” This section details how the RAA was used to evaluate the many different scenarios/combinations of institutional, distributed and regional control measures 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.  Section 7 – Detailed EWMP Implementation Strategy and Compliance Schedule: Outlines the output of the RAA process, referred to as the EWMP Implementation Strategy. This strategy can be thought of as the “recipe for compliance” for 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 Low Impact Development (LID), green streets and regional BMPs that comprise the EWMP Implementation Strategy and assure those control measures will address the Water Quality Priorities.  Section 8 – Compliance Determination and Adaptive Management Framework: Provides an overview of the compliance determination process and the adaptive management framework. The adaptive management process will be revisited every two years to evaluate the EWMP and update the program as necessary. As part of the process, the EWMP may be adapted and modified over time to become more effective as new program elements are implemented and information is gathered
 Section 9 – EWMP Implementation Costs and Financial Strategy: Presents the financial strategy for addressing the additional costs of compliance with the 2012 MS4 Permit as a result of the extensive set of BMPs required for compliance. In the context of the EWMP, the financial strategy is deemed to represent the strategic options available to the Permittees for financing the program costs associated with the new MS4 Permit.
 Section 10 – References: Contains a list of references cited in the EWMP.

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Section 1  Introduction
Upper LA River EWMP 1-12 Draft June 2015

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Upper LA River EWMP 2-1 Draft June 2015
Section 2
Legal Authority

2.1 Permit Section VI.A.2.a
Pursuant to Part VI.A.2.a of Order No. R4-2012-0175 (the “Order”), “each Permittee must establish and maintain adequate legal authority, within its respective jurisdiction, to control pollutant discharges into and from its MS4 through ordinance, statue, permit, contract or similar means.” Each Permittee in the ULAR EWMP area has established ordinances within their own jurisdiction addressing the control of urban runoff to meet all of the requirements imposed by Part VI.A.2.a:
i. Control the contribution of pollutants to its MS4 from storm water discharges associated with industrial and construction activity and control the quality of storm water discharged from industrial and construction sites. This requirement applies both to industrial and construction sites with coverage under an NPDES permit, as well as to those sites that do not have coverage under an NPDES permit.
ii. Prohibit all non-storm water discharges through the MS4 to receiving waters not otherwise authorized or conditionally exempt pursuant to Part III.A; iii. Prohibit and eliminate illicit discharges and illicit connections to the MS4; iv. Control the discharge of spills, dumping, or disposal of materials other than storm water to its MS4;
v. Require compliance with conditions in Permittee ordinances, permits, contracts or orders (i.e., hold dischargers to its MS4 accountable for their contributions of pollutants and flows); vi. Utilize enforcement mechanisms to require compliance with applicable ordinances, permits, contracts, or orders;
vii. Control the contribution of pollutants from one portion of the shared MS4 to another portion of the MS4 through interagency agreements among Copermittees; viii. Control of the contribution of pollutants from one portion of the shared MS4 to another portion of the MS4 through interagency agreements with other owners of the MS4 such as the State of California Department of Transportation;
ix. Carry out all inspections, surveillance, and monitoring procedures necessary to determine compliance and noncompliance with applicable municipal ordinances, permits, contracts and orders, and with the provisions of this Order, including the prohibition of non-storm water discharges into the MS4 and receiving waters. This means the Permittee must have authority to enter, monitor, inspect, take measurements, review and copy records, and require regular reports from entities discharging into its MS4;
x. Require the use of control measures to prevent or reduce the discharge of pollutants to achieve water quality standards/receiving water limitations; xi. Require that structural BMPs are properly operated and maintained; and

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Section 2  Legal Authority
Upper LA River EWMP 2-2 Draft June 2015
xii. Require documentation on the operation and maintenance of structural BMPs and their effectiveness in reducing the discharge of pollutants to the MS4.

2.2 Permit Section VI.A.2.b
Pursuant to Part VI.A.2.b of the Permit, EWMP participants are required to submit an annual statement certified by its chief legal counsel that “the Permittee has the legal authority within its jurisdiction to implement and enforce the requirements contained in 40 CFR §122.26(d)(2)(i)(A-F) and this Order.” Furthermore, Order Part VI.A.2.b.i requires “citation of applicable municipal ordinance or other appropriate legal authorities and their relationship to the requirements of 40 CFR §122.26(d)(2)(i)(A-F) and of this Order.”
The Permittees have issued statements certifying the above and adopted ordinances related to the regulation of urban runoff to control and prohibit discharges of pollutants into the MS4 and to comply with the requirements of the Permit applicable to it, as well as, to the extent applicable, 40 CFR §122.26(d)(2)(i)(A-F). The legal authority certifications for each Permittee are contained in Appendix 2A.

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Upper LA River EWMP 3-1 Draft June 2015
Section 3
Priorities for Water Quality Compliance
The requirement to identify Water Quality Priorities is an important first step in the EWMP process. The Water Quality Priorities highlight the pollutants and waterbodies that are potentially not attaining water quality standards5. The Water Quality Priorities are a driver of the control measures in the EWMP. For example, if a water quality objective is not being attained, additional pollutant reduction is required and thus more or larger control measures are needed to achieve those reductions. The following section summarizes the approach to identifying Water Quality Priorities as well as the outcome of the analysis.

Appendix 3.A contains a detailed description of the analysis and results.

This section also includes the compliance schedule for Water Quality Priorities for which a compliance schedule was developed including USEPA TMDLs, 303(d) listings, and other RWL exceedances in the ULAR EWMP area. The applicable TMDLs are the highest priority for stormwater quality compliance, and thus scheduling for addressing Water Quality Priorities was developed based on TMDL milestones (i.e., interim and final numeric limits) and other representative LARWQCB adopted TMDLs where appropriate (see Table 3-1 and Table 3-2; also see Section 1.3.3). Interim and final compliance dates in the LAR Bacteria TMDL, LAR Metals TMDL, Harbors Toxics TMDL, LAR Trash TMDL, Machado Lake Nutrient TMDL, and the Machado Lake Toxics TMDL are the primary drivers for the RAA and EWMP implementation schedule.

The Water Quality Priorities provide the basis for prioritizing implementation activities within the EWMP and the selection and scheduling of BMPs through the RAA. The Permit defines three categories of Water Quality Priorities, as shown in Table 3-3. The Permit establishes a four-step process that leads to prioritization and sequencing of the water quality issues within each watershed, ultimately leading to an organized list of Water Quality Priorities, as follows:
 Step 1: Water quality characterization (Permit VI.C.5.a.i, pg. 58) based on available monitoring data, TMDLs, 303(d) lists, stormwater annual reports, etc.;  Step 2: Water body-pollutant classification (Permit VI.C.5.a.ii, pg. 59), to identify water bodypollutant combinations that fall into three Permit defined categories;  Step 3: Source assessment (Permit VI.C.5.a.iii, pg. 59) for the water body-pollutant combinations in the three categories; and
 Step 4: Prioritization of the water body-pollutant combinations (Permit VI.C.5.a.iv, pg. 60).

These steps are described in the following subsections. This EWMP addresses and provides compliance coverage for all pollutants analyzed as part of the Water Quality Priorities process, including Category 1, 2, and 3 WBPCs.

5 Each water quality standard includes a beneficial use (e.g., the Basin Plan designates most waterbodies as subject to water contact recreational use) and a corresponding water quality objective to protect that use (e.g., the Basin Plan specifies that concentrations of E. coli must be less than 235 MPN per 100mL to protect water contact recreational uses). Water quality standards also incorporate an antidegradation requirement.

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Section 3  Priorities for Water Quality Compliance
Upper LA River EWMP 3-2 Draft June 2015
Table 3-1. Category 1 Water Quality Priorities and summary of Compliance Dates and Milestones for TMDLs in the ULAR EWMP area TMDL Waterbodies1 Constituents Compliance
Goal
Weather
Condition
Compliance Dates and Compliance Milestones (Bolded numbers indicated milestone deadlines within the
current Permit term) 1
2012 2013 2014 2015 2016 2020 2024 2028 2032 2037
LAR Nutrients All Waterbodies
Ammonia-N, Nitrate-N,
Nitrite-N, NitrateN+Nitrite-NMeet WQBELs All
Pre 2012
Final
LAR Trash All Waterbodies Trash % Reduction All
9/30 9/30 9/30 9/30 9/30
70% 80% 90% 96.7% 100%
Legg Lake
Trash Legg Lake Trash % Reduction All
3/6 3/6 3/6 3/6 3/6
20% 40% 60% 80% 100%
LAR Metals2
Reach 1 through
6, CC, RH, AS,
Copper, Lead, Zinc (only
RH)
% of MS4 area
Meets WQBELs Dry
1/11 1/11 1/11

VW, BWC, TW,

ACW, MC, DC,
BeC and BuC
50% 75% 100%
All Waterbodies Copper, Lead, Zinc,
Cadmium
% of MS4 area
Meets WQBELs Wet
1/11 1/11 1/11
25% 50% 100%
LAR Bacteria
(Wet
Weather)
All Waterbodies E. coli Meet WQBELs Wet
3/23
Final
Harbors
Toxics Estuary Sediment: DDTs, PCBs, Copper, Lead, Zinc, PAHs Meet WQBELs All 3/23 3/23
Interim Final
USEPA Lakes
Lake Calabasas Total-P, Total-N Meet WLAs All
USEPA TMDLs, which do not contain interim milestones or implementation schedule. The Permit (Part VI.E.3.c, pg. 145) allows MS4 Permittees to propose a schedule in an EWMP.

Legg Lake Total-P, Total-N Meet WLAs All
Echo Park Lake
Total-P, Total-N, Trash
Water and Sediment:

PCBs, Chlordane, Dieldrin
Meet WLAs All
1The Permit term is assumed to be five years from the Permit effective date or December 27, 2017. 2CC (Compton Creek), RH (Rio Hondo), AS (Arroyo Seco), VW (Verdugo Wash), BWC ( Western Channel), TW(Tujunga Wash), ACW (Aliso Canyon Wash), MC (McCoy Canyon Creek), DC (Dry Canyon Creek), BeC (Bell Creek), and BuC (Bull Creek)

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Section 3  Priorities for Water Quality Compliance
Upper LA River EWMP 3-3 Draft June 2015
Table 3-2. Dry Weather Compliance Milestones for the LAR Bacteria TMDL Applicable to ULAR EWMP Group (with and without the use of a Load Reduction Strategy [LRS]) Waterbodies
Compliance Dates and Compliance Milestones
2022 2023 2024 2025 2028 2029 2030 2031 2032 2035 2036 2037 Compton Creek
w/o LRS
3/23
Final
w LRS
3/23 3/23
Interim Final
Segment B
w/o LRS
3/23
Final
w LRS
3/23 3/23
Interim Final
Rio Hondo and
Arroyo Seco
w/o LRS
3/23
Final
w LRS
3/23 3/23
Interim Final
Segment C
w/o LRS
3/23
Final
w LRS
3/23 3/23
Interim Final
Tujunga Wash,
Burbank Western
Channel, and
Verdugo Wash
w/o LRS
3/23
Final
w LRS
3/23 3/23
Interim Final
Segment D
w/o LRS
3/23
Final
w LRS
3/23 3/23
Interim Final

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Section 3  Priorities for Water Quality Compliance
Upper LA River EWMP 3-4 Draft June 2015
Table 3-2. Dry Weather Compliance Milestones for the LAR Bacteria TMDL Applicable to ULAR EWMP Group (with and without the use of a Load Reduction Strategy [LRS]) Waterbodies
Compliance Dates and Compliance Milestones
2022 2023 2024 2025 2028 2029 2030 2031 2032 2035 2036 2037 Bull Creek
w/o LRS
3/23
Final
w LRS
3/23 3/23
Interim Final
Segment E
w/o LRS
3/23
Final
w LRS
3/23 3/23
Interim Final
Dry Canyon Creek,
McCoy Creek, Bell
Creek, and Aliso
Canyon Wash
w/o LRS
3/23
Final
w LRS
3/23 3/23
Interim Final

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Section 3  Priorities for Water Quality Compliance
Upper LA River EWMP 3-5 Draft June 2015
Table 3-3. Water Body-Pollutant Classification Categories (Permit Section IV.C.5.a.ii) Category
Water Body-Pollutant
Combinations (WBPCs) Included
1 Highest Priority
WBPCs for which TMDL WQBELs and/or RWLs are established in Part VI.E and Attachment L and O of the MS4 Permit.
2 High Priority
WBPCs for which data indicate water quality impairment in the receiving water according to the State’s Listing Policy, regardless of whether the pollutant is currently on the 303(d) List and for which the MS4 discharges may be causing or contributing to the impairment. 3 Medium Priority
WBPCs for which there are insufficient data to indicate impairment in the receiving water according to the State’s Listing Policy, but which exceed applicable receiving water limitations contained in the MS4 Permit and for which MS4 discharges may be causing or contributing to the exceedance.

3.1 Water Quality Characterization (Step 1)
Data were compiled to identify constituents exceeding applicable water quality objectives. Over 170,000 data records were reviewed as part of the data analysis. Figure 3-1 presents the site locations for the data received and used for the water quality characterization process.

Applicable water quality objectives were compiled from the California Toxics Rule (CTR), the Basin Plan, and relevant TMDLs. Applicable water quality objectives from the CTR and Basin Plan were selected based on the beneficial uses identified in the Basin Plan. Generally, the water quality objectives utilized included those established for the protection of aquatic life, contact recreation and human health related to the consumption of organisms. Appendix 3.B presents additional details on the data analysis approach and results. Additionally, a characterization was conducted on stormwater and nonstormwater discharges from the MS4 associated with constituents identified in a TMDL, a 303(d) listing, or through the receiving water data analysis. Discharge characterization data were also reviewed and are summarized in Appendix 3.C.

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Section 3  Priorities for Water Quality Compliance
Upper LA River EWMP 3-6 Draft June 2015
Figure 3-1. Monitoring Site Locations for Data Utilized in the Water Quality Priorities Process BWRP = Burbank Water Reclamation Plant, CLA EP = City of LA Echo Park Lake, DCTWRP = City of LA Donald C. Tillman Water Reclamation Plan, LAWRP = LA Glendale Water Reclamation Plant, MS4 = LA County M4 Permit, Metals CMP = Metals TMDL Coordinated Monitoring Program, S&T = City of LA Status and Trends, WNWRP = LA County Sanitation District’s Wittier Narrows Water Reclamation Plant.

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Section 3  Priorities for Water Quality Compliance
Upper LA River EWMP 3-7 Draft June 2015

3.2 Water Body Pollutant Classification (Step 2)
Based on available information and data analysis, WBPCs were classified in one of the three Permit categories, as described in Table 3-1. To further support development of the EWMP, the three Permit categories were further subdivided into subcategories (described in Table 3-4) and each WBPC was assigned to an appropriate subcategory. Summary tables presenting the data analysis to support the placement of WBPCs into the various subcategories are presented in Appendix 3.B.

Table 3-4. Details for Water Body-Pollutant Classification Subcategories Category WBPCs Description
1 Category 1A: WBPCs with past due or
current Permit term TMDL deadlines
with exceedances in the past 5 years.

WBPCs with TMDLs with past due or current Permit term interim and/or final limits. These pollutants are the highest priority for the current Permit term.

Category 1B: WBPCs with TMDL
deadlines beyond the Permit term
with exceedances in the past 5 years.

The Permit does not require the prioritization of TMDL interim and/or final deadlines outside of the Permit term or USEPA TMDLs, which do not have implementation schedules. To ensure EWMPs consider long term planning requirements and utilize the available compliance mechanisms, these WBPCs should be considered during BMP planning and scheduling, and during CIMP development.

Category 1C: WBPCs addressed in
USEPA TMDL without a Regional
Board adopted Implementation Plan.

Category 1D: WBPCs with past due or
current Permit term TMDL deadlines
but have had no exceedances in the
past 5 years.

WBPCs where specific actions may end up not being identified because recent exceedances have not been observed and specific actions may not be necessary. The CIMP should address these WBPCs to support future re-prioritization.
2 Category 2A: 303(d) Listed WBPCs or
WBPCs that meet 303(d) Listing
requirements with exceedances in
the past 5 years.

WBPCs with confirmed impairment or exceedances of RWLs. WBPCs in a similar class1 as those with TMDLs are identified. WBPCs currently on the 303(d) List are differentiated from those that are not to support utilization of EWMP compliance mechanisms.

Category 2B: 303(d) Listed WBPCs or
WBPCs that meet 303(d) Listing
requirements that are not a
“pollutant”2(e.g., toxicity).

WBPCs where specific actions may not be identifiable because the cause of the impairment or exceedances is not resolved. Either routine monitoring or special studies identified in the CIMP should support identification of a “pollutant” linked to the impairment and re-prioritization in the future.

Category 2C: 303(d) Listed WBPCs or
WBPCs that meet 303(d) Listing
requirements but there have been no
exceedances in the past 5 years.

WBPCs where specific actions for implementation may end up not being identified because recent exceedances have not been observed (and thus specific BMPs may not be necessary.) Pollutants that are in a similar class1 as those with TMDLs are identified. Either routine monitoring or special studies identified in the CIMP should ensure these WBPCs are addressed to support re-prioritization in the future. 3 Category 3A: All other WBPCs that
have exceeded in the past 5 years.

Pollutants that are in a similar class1 as those with TMDLs are identified.

Category 3B: All other WBPCs that are
not a “pollutant”2(e.g., toxicity).

WBPCs where specific actions may not be identifiable because the cause of the impairment or exceedances is not resolved. Either routine monitoring or special studies identified in the CIMP should support identification of a “pollutant” linked to the impairment and re-prioritization in the future.

Category 3C: All other WBPCs that
have exceeded in the past 10 years,
but not in past 5 years.

Pollutants that are in a similar class1 as those with TMDLs are identified.
1 – Pollutants are considered in a similar class if they have similar fate and transport mechanisms, can be addressed via the same types of control measures, and within the same timeline already contemplated as part of the EWMP for the TMDL. (Permit pg. 49, footnote 21).
2 – While pollutants may be contributing to the impairment, it currently is not possible to identify the specific pollutant/stressor.

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Section 3  Priorities for Water Quality Compliance
Upper LA River EWMP 3-8 Draft June 2015

3.3 Source Assessment (Step 3)
Following classification of WPBCs into Category 1, 2 and 3, the next step in the prioritization process is to conduct a source assessment. The Permit requires that a source assessment be conducted to identify potential sources within the watershed for the WBPCs in Categories 1-3, utilizing existing information.

The source assessment also evaluates whether pollutants likely originate from the MS4 versus other sources. Pollutant exceedances may come from point or non-point sources, described below. Often, however, non-point source discharges may flow through the MS4 and thus become associated with the MS4 and subject to the MS4 Permit requirements. A detailed source assessment for the ULAR watershed is provided in Appendix 3.D.

3.4 Prioritization (Step 4)
The Permit outlines a prioritization process that defines how pollutants in the various categories will be considered in scheduling. The factors to consider in the scheduling include the following based on the compliance approaches outlined in the Permit:
 Regional Board-adopted TMDLs with past due interim and/or final limits and those with interim and/or final limits within the Permit term (schedule according to TMDL schedule)  Regional Board-adopted TMDLs with interim and/or final limits outside the Permit term (schedule according to TMDL schedule)
 Other receiving water exceedances.

USEPA TMDLs, 303(d) listings without a TMDL adopted, and other exceedances of RWLs do not contain milestones or an implementation schedule. As such, these Water Quality Priorities do not have a defined schedule for attainment/implementation. To address this issue for USEPA TMDLs, Part VI.E.3.c of the Permit (page 145) allows MS4 Permittees to propose a schedule in the EWMP. To address this issue for exceedances of RWLs associated with WBPCs not addressed through a TMDL (i.e., 303(d) listings and other exceedances of RWLs), Part VI.C.2.a of the Permit (page 49) specifies how interim numeric milestones and compliance schedules must be set for each WBPC based on its placement in one of the following groups that were developed as part of the EWMP:
 Group 1: Pollutants that are in the same class6 as those addressed in a TMDL in the watershed and for which the water body is identified as impaired on the 303(d) List as of December 28, 2012;
 Group 2: Pollutants that are not in the same class as those addressed in a TMDL for the watershed, but for which the water body is identified as impaired on the 303(d) List as of December 28, 2012;
 Group 3: Pollutants for which there are exceedances of RWLs, but for which the water body is not identified as impaired on the 303(d) List as of December 28, 2012; or  USEPA TMDL: Pollutants addressed by USEPA TMDL without an implementation plan/schedule.

6 As defined in Part VI.C.2.a.i of the Permit (page 49), “Pollutants are considered in a similar class if they have similar fate and transport mechanisms, can be addressed via the same types of control measures, and within the same timeline already contemplated as part of the Watershed Management Program for the TMDL.”

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Section 3  Priorities for Water Quality Compliance
Upper LA River EWMP 3-9 Draft June 2015
The process for setting numeric milestones and compliance schedules for the remaining Water Quality Priorities (those not addressed by a Regional Board-adopted TMDL) is dependent upon whether or not the water body is identified as impaired on the 303(d) list as of December 28, 2012, and if the pollutants are considered to be in the same class as those pollutants addressed in a TMDL for the watershed. A detailed description of the prioritization process and outcomes for the ULAR watershed is provided in Appendix 3.A.

3.5 Numeric Milestones and Compliance Schedule
Part VI.C.5.c of the Permit discusses the compliance schedule requirements associated with the EWMP.

The compliance schedule for the ULAR EWMP was developed based on TMDL milestones (i.e., interim and final numeric limits) and other representative Regional Board adopted TMDLs where appropriate (i.e., for the lakes addressed by USEPA TMDLs). Interim and final compliance dates in the LARWQCB adopted TMDLs are the primary drivers for the ULAR RAA and EWMP implementation schedule (presented in Table 3-1). Table 3-5 presents the compliance schedule for USEPA TMDLs, 303(d) listings, and other RWL exceedances which fall under Category 1 and Category 2. For simplicity, only the year of each milestone is shown; however, the exact date remains consistent with the milestone dates included in the relevant LARWQCB adopted TMDL (presented in Table 3-1). Table 3-6 presents the dry weather compliance milestones applicable to WBPCs in the EWMP which use the LAR Bacteria TMDL as the foundation for establishing the compliance schedule.

Category 2 WBPCs that meet the requirements to be removed from the 303(d) List and Category 3 WBPCs are the lowest priority given their relatively low exceedance frequency. However, for these WBPCs, where MS4 discharges may have caused or contributed to the exceedances, a schedule has been established to support continual attainment of the RWLs. The interim and final schedule milestones are based on the dry and wet weather schedule for the LA River Metals TMDL. The final dry and wet weather Category 3 WBPCs milestones are January 11, 2024 and January 11, 2028, respectively.

Table 3-7 presents the compliance schedule for the Category 2 WBPCs that meet the requirements to be removed from the 303(d) List and Category 3 WBPCs. Table 3-8 presents the list of the remaining Category 2 and 3 WBPCs where either MS4 discharges are not considered to be a source or the WBPC is a condition rather than a “pollutant” with the potential to be discharged from the MS4. Available data will be assessed and if the MS4 discharges are identified as causing or contributing to exceedances for WBPCs identified in Table 3-8, the EWMP will be revised consistent with Part VI.c.2.a.iii (page 51) of the Permit.

A detailed description of the process and outcomes for identifying the numeric milestones and compliance schedule for the ULAR watershed is provided in Appendix 3.A.

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Section 3  Priorities for Water Quality Compliance
Upper LA River EWMP 3-10 Draft June 2015
Table 3-5. Compliance Schedule for Category 1 and 2 Water Quality Priorities that are not Included in a Regional Board Adopted TMDL Constituent WQP Category and Water
Body
Compliance
Schedule Source
Weather
Condition
Compliance Dates and Compliance Milestones (Bolded numbers indicated milestone deadlines within the current Permit term) 1, 2 2013 2014 2015 2016 2019 2020 2024 2028 2032 2037
2,3,7,8-TCDD (Dioxin)
C2: Reach 3
C2: Burbank Western
Channel
LAR Bacteria
TMDL
Dry See Table 3-6 for Interim and Final Compliance Milestones Wet Final
Mercury Total
C2: LAR Reach 1
C2: LAR Reach 2
C2: LAR Reach 3
C2: LAR Reach 4
C2: LAR Reach 6
LAR Metals TMDL
Dry 75% 100%
Wet 50% 100%
Copper C2: RH Reach 3 LAR Metals TMDL
Dry 75% 100%
Wet 50% 100%
Thallium Total C2: LAR Reach 6 LAR Metals TMDL Dry 75% 100% Diazinon C2: Reach 5 Harbors Toxics All Final
Total Phosphorus
C1 (USEPA): Legg Lake
C1 (USEPA): Lake Calabasas
C1 (USEPA): Echo Park Lake
Machado Lake
Nutrient TMDL All Baseline Interim 50% 100%
Total Nitrogen
C1 (USEPA): Legg Lake
C1 (USEPA): Lake Calabasas
C1 (USEPA): Echo Park Lake
Machado Lake
Nutrient TMDL All Baseline Interim 50% 100%
Trash C1 (USEPA): Echo Park Lake LAR Trash TMDL All 80% 90% 96.7% 100% PCBs (water and sediment) C1 (USEPA): Echo Park Lake Machado Lake Toxics TMDL All Interim Final
Chlordane (water and
sediment) C1 (USEPA): Echo Park Lake Machado Lake Toxics TMDL All Interim Final Dieldrin (water and
sediment) C1 (USEPA): Echo Park Lake Machado Lake Toxics TMDL All Interim Final 1The Permit term is assumed to be five years from the Permit effective date or December 27, 2017. 2 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. In the case of the USEPA adopted TMDLs attainment will can be demonstrated through reduction from the baseline at the time of TMDL promulgation or percent area meeting the WQBEL or RWL.

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Section 3  Priorities for Water Quality Compliance
Upper LA River EWMP 3-11 Draft June 2015
Table 3-6. Dry Weather Compliance Milestones for 2,3,7,8-TCDD (Dioxin) with and without the use of a LA River Bacteria Load Reduction Strategy (LRS) based Approach to Dry Weather
Waterbodies
Compliance Dates and Compliance Milestones
2022 2023 2024 2025 2028 2029 2030 2031 2032 2035 2036 2037 LAR Reach 3 and
Burbank Western
Channel
w/o LRS
3/23
Final
w LRS
3/23 3/23
Interim Final
Table 3-7. Compliance Schedule based on the LA River Metals TMDL for Category 2 and 3 Water Quality Priorities that Do Not Meet the 303(d) Listing Requirements
Constituent WQP Category and
Water Body
Weather
Condition
Dry Weather
Schedule
Wet Weather
Schedule
Notes Interim Final Interim Final
2020 2024 2024 2028
2,3,7,8-TCDD (Dioxin) C3: LAR Reach 6 Dry 75% 100% Only 1 of 4 exceedances in last 10 years in LAR Reach 6 Mercury Total
C3 (Dry): LAR Reach 5
C3 (Dry/Wet): CC
C3 (Dry): RH Reach 3
C3 (Wet): AS
C3 (Wet): VW
C3 (Dry/Wet): BWC
C3 (Dry): TW
C3 (Dry): Caballero
Creek
Dry/Wet 75% 100% 50% 100%
Only 6 of 156 exceedances in last 10 years in LAR Reach 5, 1 of 16 exceedances in last 10 years in CC during dry weather, 1 of 2 exceedances in last 10 years in CC during wet weather, 2 of 74 exceedances in last 10 years in RH Reach 3, 1 of 6 exceedances in last 10 years in AS, 1 of 6 exceedances in last 10 years in VW, 17 of 244 exceedances in last 10 years in BWC during dry weather, 1 of 7 exceedances in last 10 years in BWC during wet weather, 1 of 15 exceedances in last 10 years in TW, and 1 of 12 exceedances in last 10 years in Caballero Creek
Thallium Total
C3: LAR Reach 1
C3: LAR Reach 2
C3: LAR Reach 3
C3: LAR Reach 4
C3: BWC
Dry 75% 100%
Only 3 of 91 exceedances in last 10 years in LAR Reach 1, 2 of 112 exceedances in last 10 years in LAR Reach 2, 4 of 177 exceedances in last 10 years in LAR Reach 3, 2 of 128 exceedances in last 10 years in LAR Reach 4, and 1 of 61 exceedances in last 10 years in BWC Dibenzo(a,h)
Anthracene
C3: LAR Reach 3
C3: LAR Reach 5
C3: RH Reach 3
Dry 75% 100%
Only 8 of 122 exceedances in last 10 years in LAR Reach 3, 1 of 75 exceedances in last 10 years in LAR Reach 5, and 2 of 43 exceedances in last 10 years in RH Reach 3

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Section 3  Priorities for Water Quality Compliance
Upper LA River EWMP 3-12 Draft June 2015
Table 3-7. Compliance Schedule based on the LA River Metals TMDL for Category 2 and 3 Water Quality Priorities that Do Not Meet the 303(d) Listing Requirements
Constituent WQP Category and
Water Body
Weather
Condition
Dry Weather
Schedule
Wet Weather
Schedule
Notes Interim Final Interim Final
2020 2024 2024 2028
Indeno(1,2,3-cd)Pyrene
C3: LAR Reach 3
C3: LAR Reach 5
C3: RH Reach 3
Dry 75% 100%
Only 3 of 56 exceedances in last 10 years in LAR Reach 3, 1 of 75 exceedances in last 10 years in LAR Reach 5, and 1 of 36 exceedances in last 10 years in RH Reach 3
4,4-DDD C3: LAR Reach 5 Dry 75% 100% Only 2 of 72 exceedances in last 10 years in LAR Reach 5 4,4-DDE C3: LAR Reach 5 Dry 75% 100% Only 4 of 72 exceedances in last 10 years in LAR Reach 5 Nickel
C3: LAR Reach 3
C3: LAR Reach 5
C3: Caballero Creek
Dry 75% 100%
Only 2 of 140 exceedances in last 10 years in LAR Reach 3, 1 of 72 exceedances in last 10 years in LAR Reach 5, and 1 of 41 exceedances in last 10 years in Caballero Creek
Benzo(a)Anthracene C3: LAR Reach 3 Dry 75% 100% Only 1 of 75 exceedances in last 10 years in LAR Reach 3 Chrysene
C3: LAR Reach 3
C3: LAR Reach 4
C3: LAR Reach 6
C3: RH Reach 3
Dry 75% 100%
Only 1 of 75 exceedances in last 10 years in LAR Reach 3, 1 of 38 exceedances in last 10 years in LAR Reach 4, 1 of 15 exceedances in last 10 years in LAR Reach 6, and 1 of 43 exceedances in last 10 years in RH Reach 3
Heptachlor C3: LAR Reach 5
C3: BWC Dry 75% 100% Only 2 of 72 exceedances in last 10 years in LAR Reach 5 and 1 of 131 exceedances in last 10 years in BWC Copper4
C3: RH Reach 2
C3: Caballero Creek Dry 75% 100% Only 1 of 2 exceedances in last 10 years in RH Reach 2 and 4 of 41 exceedances in last 10 years in Caballero Creek Benzo(a)Pyrene C3: RH Reach 3
C3: BWC Dry 75% 100% Only 1 of 43 exceedances in last 10 years in RH Reach 3 and 2 of 137 exceedances in last 10 years in BWC Benzo(b)Fluoranthene C3: BWC Dry 75% 100% Only 5 of 135 exceedances in last 10 years in BWC Benzo(k)Fluoranthene C3: RH Reach 3 Dry 75% 100% Only 1 of 43 exceedances in last 10 years in RH Reach 3 Chlorpyrifos C3: CC Dry 75% 100% Only 1 of 4 exceedances in last 10 years in CC beta-BHC C3: BWC Dry 75% 100% Only 1 of 131 exceedances in last 10 years in BWC Cadmium
C3: BWC
C3: TW
C3: Caballero Creek
Dry 75% 100%
Only 1 of 298 exceedances in last 10 years in BWC, 1 of 38 exceedances in last 10 years in TW, and 2 of 41 exceedances in last 10 years in Caballero Creek

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Section 3  Priorities for Water Quality Compliance
Upper LA River EWMP 3-13 Draft June 2015
Table 3-7. Compliance Schedule based on the LA River Metals TMDL for Category 2 and 3 Water Quality Priorities that Do Not Meet the 303(d) Listing Requirements
Constituent WQP Category and
Water Body
Weather
Condition
Dry Weather
Schedule
Wet Weather
Schedule
Notes Interim Final Interim Final
2020 2024 2024 2028
Lead4
C3: RH Reach 2
C3: Caballero Creek Dry 75% 100% Only 1 of 2 exceedances in last 10 years in RH Reach 2 and 2 of 41 exceedances in last 10 years in Caballero Creek Zinc3
C3: LAR Reach 1 Dry 75% 100% Meets criteria to de-list for dry weather impairment2 and wet weather impairment is being addressed by the LAR Metals TMDL C3: LAR Reach 3
C3: LAR Reach 4
C3: VW
C3: BWC
C3:TW
C3: Caballero Creek
Dry 75% 100%
Only 7 of 415 exceedances in last 10 years in LAR Reach 3, 1 of 284 exceedances in last 10 years in LAR Reach 4, 1 of 41 exceedances in last 10 years in VW, 2 of 321 exceedances in last 10 years in BWC, 4 of 70 exceedances in last 10 years in TW, and 2 of 41 exceedances in last 10 years in Caballero Creek
Diazinon
C2: LAR Reach 1 Wet 50% 100% Meets criteria to de-list
C3 (Dry): LAR Reach 4
C3 (Wet): RH Reach 2
C3 (Dry): RH Reach 3
C3 (Wet): ACW
Dry/Wet 75% 100% 50% 100%
Only 1 of 7 exceedances in last 10 years in LAR Reach 4, 1 of 4 exceedances in last 10 years in RH Reach 2, 3 of 60 exceedances in last 10 years in RH Reach 3, and 1 of 4 exceedances in last 10 years in ACW
1 – CC (Compton Creek), RH (Rio Hondo), AS (Arroyo Seco), VW (Verdugo Wash), BWC (Burbank Western Channel), TW(Tujunga Wash), ACW (Aliso Canyon Wash), MC (McCoy Canyon Creek), DC (Dry Canyon Creek), BeC (Bell Creek), and BuC (Bull Creek) 2 –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. 3 – The LAR Metals TMDL states that “Dry-weather impairments related to zinc only occur in Rio Hondo Reach 1”. As a result, dry weather impairments related to zinc in other water bodies are not addressed by the Regional Board adopted TMDL and are, therefore, addressed by this EWMP. 4 – The LAR Metals TMDL does not address dry weather impairments related to copper or lead in Rio Hondo Reach 2, Rio Hondo Reach 3, or Caballero Creek.

Table 3-8. Water Quality Priorities where either MS4 discharges are not Considered to be a Source or the Water Body Pollutant Combination is a Condition Rather than a “pollutant” with the Potential to be Discharged from the MS41 Constituent WQP Category and
Water Body
Weather
Condition Notes
Chloride
C2: LAR Reach 5
C2: LAR Reach 6
C3: CC
C3: RH Reach 3
Dry MS4 determined to not be a source that may be causing or contributing to observed exceedances (determined to be a natural source, per Source Assessment). 2

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Section 3  Priorities for Water Quality Compliance
Upper LA River EWMP 3-14 Draft June 2015
Table 3-8. Water Quality Priorities where either MS4 discharges are not Considered to be a Source or the Water Body Pollutant Combination is a Condition Rather than a “pollutant” with the Potential to be Discharged from the MS41 Constituent WQP Category and
Water Body
Weather
Condition Notes
C3: BWC
C2: TW
Cyanide
C2: LAR Reach 1
C2: RH Reach 2 All
MS4 determined to not be a source that may be causing or contributing to observed exceedances (known to have potential laboratory analysis quality assurance/quality control issues). 2 C2: BWC Dry
C3 (Dry): LAR Reach 3
C3 (Dry): LAR Reach 4
C3 (Dry): LAR Reach 5
C3 (Dry): LAR Reach 6
C3 (Wet): BuC
C3 (Wet): ACW
Dry/Wet
Sulfate
C3: LAR Reach 3
C3: LAR Reach 4
C2: LAR Reach 5
C2: LAR Reach 6
C3: ACW
Dry MS4 determined to not be a source that may be causing or contributing to observed exceedances (determined to be a natural source, per Source Assessment). 2 TDS
C3: LAR Reach 4
C2: LAR Reach 5
C2: LAR Reach 6
C3: BWC
C3: TW
C3: ACW
Dry MS4 determined to not be a source that may be causing or contributing to observed exceedances (determined to be a natural source, per Source Assessment). 2 Bis(2-ethylhexyl)Phthalate
C2: LAR Reach 1
C2: RH Reach 2
C2: AS
C2: VW
C2: BWC
C2: BuC
C2: ACW
C3: LAR Reach 3
C3: LAR Reach 5
Dry/Wet MS4 determined to not be a source that may be causing or contributing to observed exceedances (known to have potential laboratory analysis quality assurance/quality control issues). 2 Oil C2: LAR Reach 2
C2: LAR Reach 5 Dry/Wet MS4 determined to not be a source that may be causing or contributing to observed exceedances (determined to be a natural source, as described in Appendix 3.B) 2 Chlorine (Total) C3: LAR Reach 3
C3: LAR Reach 4
Dry/Wet MS4 determined to not be a source that may be causing or contributing to observed exceedances (water reclamation plant effluent is identified source). 2

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Section 3  Priorities for Water Quality Compliance
Upper LA River EWMP 3-15 Draft June 2015
Table 3-8. Water Quality Priorities where either MS4 discharges are not Considered to be a Source or the Water Body Pollutant Combination is a Condition Rather than a “pollutant” with the Potential to be Discharged from the MS41 Constituent WQP Category and
Water Body
Weather
Condition Notes
C3: LAR Reach 5
C3: LAR Reach 6
C2: BWC
Dichlorobromomethane C3: LAR Reach 3 Dry/Wet MS4 determined to not be a source that may be causing or contributing to observed exceedances (water reclamation plant effluent is identified source). 2 Chlorodibromomethane C3: BWC Dry/Wet MS4 determined to not be a source that may be causing or contributing to observed exceedances (water reclamation plant effluent is identified source). 2 Selenium
C3: LAR Reach 1
C3: LAR Reach 3
C3: LAR Reach 4
C2: LAR Reach 5
C2: LAR Reach 6
C2: BWC
C2: Caballero Creek
C2: ACW
Dry/Wet MS4 determined to not be a source that may be causing or contributing to observed exceedances. As noted in the LAR Metals TMDL, selenium originates from natural sources. 2 pH
C2: LAR Reach 1
C2: LAR Reach 2
C3: LAR Reach 3
C3: LAR Reach 5
C2: LAR Reach 6
C3: RH Reach 2
C2: RH Reach 3
C3: BWC
Dry/Wet Reflective of a condition of pollution, not necessarily a result of MS4 discharge.

Dissolved Oxygen
C3: LAR Reach 1
C3: LAR Reach 3
C3: LAR Reach 5
C3: LAR Reach 6
C2: RH Reach 3
Dry/Wet Reflective of a condition of pollution, not necessarily a result of MS4 discharge.

BenthicMacroinvertebratesC2: CC
C2: AS Dry Reflective of a condition of pollution, not necessarily a result of MS4 discharge. 1 – CC (Compton Creek), RH (Rio Hondo), AS (Arroyo Seco), VW (Verdugo Wash), BWC (Burbank Western Channel), TW(Tujunga Wash), ACW (Aliso Canyon Wash), MC (McCoy Canyon Creek), DC (Dry Canyon Creek), BeC (Bell Creek), and BuC (Bull Creek). 2 – Available data will be assessed to determine if MS4 discharges are causing or contributing to exceedances.

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Section 3  Priorities for Water Quality Compliance
Upper LA River EWMP 3-16 Draft June 2015

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Upper LA River EWMP 4-1 Draft June 2015
Section 4
Overview of EWMP Control Measures: Regional
Projects and Integration with Related Planning
Efforts
The Permit places heavy emphasis on regional projects as multi-benefit components of the EWMP7.

This section provides an overview of the benefits and role of regional projects in the EWMP and the detailed screening and analysis process used to prioritize regional project opportunities in the ULAR watershed. In addition, this section highlights signature regional projects that have been evaluated through detailed conceptual level designs by each of the EWMP Group members. This section also describes how the EWMP can be integrated with efforts underway by many other organizations to increase water supplies and make the river more safe, accessible, healthy and beautiful (e.g., the LA River Ecosystem Restoration Feasibility Study and the Stormwater Capture Master Plan). This section provides a high-level summary while the details of the EWMP Implementation Strategy and RAA results are provided in later sections of the EWMP. A separate overview of green infrastructure and institutional control measures is provided in Section 5.

4.1 What are the Benefits of Regional Projects?
Regional projects are centralized facilities located near the downstream ends of large drainage areas (typically treating 10s to 100s of acres). Regional projects receive large volumes of runoff from extensive upstream areas and can provide a cost-effective mechanism for infiltration and pollutant reduction. Runoff is typically diverted to regional projects after it has already entered storm drains and engineered channels. Routing offsite runoff to public parcels (versus treating surface runoff near its source, as with green streets and LID) often allows regional BMPs to be placed in cost-effective locations with the best available BMP opportunity. The regional project program will consider the interactions between BMPs and their environmental factors as well as synergies and integration with concurrent drinking water, wastewater, and other engineering programs.

It is important to emphasize that
regional projects offer a variety of
benefits beyond simply water quality
improvement. Other benefits may
include water supply augmentation,
community enhancement, and habitat
restoration. The ability to meet many
needs with a single project makes
regional projects attractive from a
water quality efficiency standpoint
and also provides significant opportunity to showcase the potential community-wide benefits of stormwater capture projects. These opportunities can be used to educate the public about the value of

7 For example, the compliance determination of the Permit specifies that retention of the stormwater volume associated with the 85th percentile, 24-hour storm (design storm) achieves compliance with final TMDL RWLs and WQBELs for upstream areas.

Regional BMP Program Highlights:
 Implements large-scale BMPs on parcels
 High potential for significant load reduction
 Strategic selection of sites can yield cost savings
 Multi-benefits include water supply augmentation
 Integration with park enhancements key for funding
 Acquisition of parcels likely needed in the future

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-2 Draft June 2015
the EWMP effort, generate funding interest, and make significant progress toward multi-agency objectives (e.g., park improvements, flood control facility rehabilitation, etc.).

Regional projects can provide many other amenities to the community, including the following:
 Development and/or improvement of park facilities promote recreation and enhances accessibility. Underground systems can allow the beneficial use of a site to be maintained while simultaneously managing stormwater.
 Where conditions restrict infiltration, runoff can be captured, stored, and used to offset potable water use for activities like toilet flushing and irrigation.  Naturalized systems like infiltration basins and stormwater wetlands can enhance plant and bird habitat and allow educational opportunities through the creation of “outdoor classrooms.” Given these multi-benefit attributes, the EWMP development process placed special emphasis on regional project selection.

4.2 What Types of Regional Projects are Included in the EWMP?
A wide array of regional project types were considered for inclusion in the EWMP Implementation Strategy. Appendix 4.A includes a series of example “BMP fact sheets” that present the different types of regional projects, including the following (illustrated in Figure 4-1):
 Surface infiltration basin,
 Subsurface infiltration gallery
 Surface detention basin,
 Subsurface detention gallery, and
 Constructed wetland, flow-through/linear wetland
Through detailed screening processes, water quality modeling, and feasibility analyses (described in subsequent subsections), regional projects8 were selected and placed into one of four categories, as follows:
 Very High: projects located on parcels owned by EWMP Group members and considered to be the highest priority for EWMP implementation schedule. Several of these projects are considered “signature projects” and were subject to further conceptual designs.  High: projects located on parcels owned by the EWMP Group members and considered the next-highest priority for the EWMP implementation schedule.

8 While the Permit emphasizes Regional EWMP Projects that can retain the 85th percentile, 24-hour storm from its upstream drainage area, WMG members determined that it would be useful to identify and include the broadest group of all potential regional BMP projects and locations, and not simply the subset of projects that could capture the 85th percentile storm.

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-3 Draft June 2015
 Medium: projects located on parcels owned by other agencies (e.g., school districts) but evaluated for EWMP implementation. Not all EWMP Group members included Medium projects in their EWMP Implementation Strategy.
 Regional BMPs on private land: in cases where the water quality modeling required more pollutant reduction than could be achieved with the identified BMP opportunities for LID, green infrastructure and regional BMPs on public land. Regional projects on private land were generally given the lowest priority for implementation, although there are some significant opportunities to integrate LA River restoration efforts that will include land acquisition (as described in a subsection below), in which case regional BMPs on (currently) private land could be prioritized for implementation earlier in the schedule.

4.3 What is the Role of Regional Projects in the EWMP?
Regional projects provide a significant portion of the pollutant reduction to be achieved by the EWMP Implementation Strategy. As shown in Figure 4-2, a total of 16 Very High, 93 High and 19 Medium projects are included in the EWMP Implementation Strategy9. Combined, as shown in Figure 4-3, regional projects on public land make up 26% of the total control measure capacity in the EWMP.

Regional projects on private land make up an additional 31% of the EWMP capacity10. Combined, regional projects represent 57% of the EWMP control measures. The total network of LID, green streets and regional BMPs in the EWMP Implementation Strategy represents approximately 20 Rose Bowls of BMP capacity.

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.

9 The RAA incorporated a specific footprint, depth and drainage area for each of these projects (as described in Section 6), but most were not subject to specific concepts (e.g., infiltration basin or underground gallery). The signature regional projects were subject to conceptual level designs as described below. 10 The capacities shown in Figure 4-3 are for implementation through 2028, which is the final wet weather compliance date for the LA River Metals TMDL. Between 2028 and 2037, an additional capacity of regional BMPs on private land is included for implementation of the LA River Bacteria TMDL.

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-4 Draft June 2015
Infiltration Basins
Infiltration facilities are designed to
decrease runoff volume through
groundwater recharge and improve water
quality through filtration and sorption.

Infiltration facilities can be open-surface
basins or subsurface galleries.

Detention Basins
Detention facilities are designed to detain
runoff and improve water quality
primarily through pollutant settling.

Detention facilities can be open-surface
practices or subsurface galleries and can
be dry during non-rainy seasons or wet
year-round.

Constructed Wetlands
Constructed wetlands are engineered,
shallow-marsh systems designed to
control and treat stormwater runoff.

Particle-bound pollutants are removed
through settling, and other pollutants are
removed through biogeochemical
activity.

Figure 4-1. Examples of Types of Regional Projects to be used for EWMP Implementation (more details provided in Appendix 4.A)

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-5 Draft June 2015

4.4 How were Regional BMPs Selected for the EWMP?
The EWMP Group developed and implemented a process for identifying opportunities for regional projects during 2014. The process for identifying potential regional project locations and selecting the preliminary list of potential regional projects in the watershed is depicted below. Details of the process are provided in Appendix 4.B.

Emphasis was placed on developing and implementing a process for Step 2, Identify New/Additional Regional Projects. All public parcels within the watershed were evaluated according to geographic information system (GIS) criteria such as: parcel ownership, land use, parcel size, slope, proximity to 36” storm drain or open channel, tributary drainage area and other criteria described in more detail in Appendix 4.B.

The outcome of this process was identification of close to 700 opportunities throughout the watershed and initially ranked into three categories: Very High (18), High (109) and Medium (568), based on criteria summarized in Appendix 4.B. These regional project opportunities are depicted in Figure 4-4. Of these, nearly all of the Very High and High opportunities were evaluated by the RAA and selected for inclusion in the EWMP based on cost-benefit optimization. Most agencies determined that Medium opportunities, because they would include siting regional projects located on other agencies land, should be evaluated for inclusion in the EWMP over the course of adaptive management (rather than including them in the 2015 submittal).

Step 1. Compile
Existing/Planned
Regional Projects
Step 2. Identify
New/Additional
Regional Projects
Step 3.

Evaluate/Prioritize
Regional Projects
Step 4.

Recommend
Projects for
Implementation

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-6 Draft June 2015
Figure 4-2. Regional Projects included in the ULAR EWMP Implementation Strategy

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-7 Draft June 2015
Figure 4-3. Relative Capacities of Different Control Measure Categories to be implemented by the ULAR EWMP by 2028.

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-8 Draft June 2015
Figure 4-4. Regional Project Opportunities in the ULAR Watershed Considered by the RAA

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-9 Draft June 2015

4.5 Which Signature Regional Projects are included in the EWMP?
A key outcome of the regional project selection process was identification of eight signature regional projects, as listed in Table 4-1. These signature projects were subjected to more detailed environmental, geotechnical and engineering feasibility analysis. The evaluation methodology and a more detailed description of these analyses and results is presented in Appendix 4.C. Key design parameters considered for each signature project are presented in Table 4-2. Each of the signature regional projects will achieve multiple benefits including water supply, groundwater recharge, flood control, recreation and/or habitat.

The signature regional projects emphasize subsurface retention and infiltration as primary functionality. On the following pages (Figures 4-5 through 4-35), example “project fact sheets” are presented for the signature projects. The following items are included for each project fact sheet:
 Summary description of the recommended BMP project; BMP parameters; and a description of potential benefits
 Summary fact sheet
 Figure showing a plan view of the project site, showing the identified BMP opportunity area(s) and surrounding storm drain infrastructure
 Figure showing a plan view of the maximum and alternative drainage areas delineated for the project site
 Figure presenting preliminary design concepts.

It should be noted that all of these regional projects are concepts at this stage and subject to change, but that each of the respective EWMP Group members have provided significant input and review of these concepts.

Several of the signature regional projects meet the EWMP definition of a regional project that captures the 85th percentile, 24-hour (design) storm event (Table 4-1). During the engineering evaluation of optimum stormwater capture events, it was also determined that there are unique situations where it is advisable to consider capturing much larger tributary areas upstream of the regional project site in order to maximize capture of dry weather flows. Also, some sites are constrained by the size of the BMP footprint available at the site, which prevents capture of the entire 85th percentile storm event. It is important to recognize there are many situations in which regional projects that are sized smaller than the design storm may actually provide more pollutant reduction benefit if they manage a larger area than a regional project at the same location that captures the 85th percentile storm event from a smaller drainage area.

The following subsections present project fact sheets for the signature regional projects.

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-10 Draft June 2015
Table 4-1. Signature Regional Projects in the ULAR EWMP Regional Project BMP Type
Maximum Drainage
Area
Alternative Drainage
Area
Available
BMP Volume
Recommended
BMP Volume
Retain the
85th
Percentile,
24-Hour
Storm Event
(acres)
BMP
Volume
(AF)
(acres)
BMP
Volume
(AF)
(AF) (AF)
Alhambra Golf
Course Subsurface Retention & Infiltration 1,145 49.0 51 0.52 255 74.7 Yes Freemont Park Subsurface Retention & Infiltration NA1 NA1 206 16.0 8 8.0 No Roosevelt Park Subsurface Retention & Infiltration 2,250 82.4 169 2.2 200 8.4 Yes Sierra Vista Park Subsurface Retention & Infiltration 2,928 178.6 800 48.6 14 10.0 No San Fernando
Regional Park Subsurface Retention & Infiltration NA1 NA1 423 11.3 54 22.6 Yes Lacy Park Subsurface Retention & Infiltration 1,067 46.6 928 40.0 48 46.4 Yes Lower Arroyo
Park Subsurface Retention & Infiltration NA1 NA1 145 0.06 265 3.7 Yes North Hollywood
Park Subsurface Retention & Infiltration NA1 NA1 5,122 38.0 156 38.0 Yes 1 Maximum Drainage Areas for these locations could have directly managed the receiving water, but this option was not considered.

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-11 Draft June 2015
Table 4-2. Key Design Parameters for Signature EWMP Projects Project Site Parameters Total (Maximum) Drainage Area
The area in acres of the maximum drainage area delineated for each project site. The drainage area delineation is described in Section 2 of the Appendix 4.C.

Alternative (Minimum) Drainage Area
The area in acres of the alternative drainage area delineated for each project site. The drainage area delineation is described in Section 2 of Appendix 4.C.

Maximum Required BMP Volume
The BMP volume in acre-feet that is required to retain the 85th percentile design storm volume generated from the maximum drainage area.

Alternative Required BMP Volume
The BMP volume in acre-feet that is required to retain the 85th percentile design storm volume generated from the alternative drainage area.

Groundwater Depth
The groundwater depth in feet from the ground surface.

Groundwater depths were determined using groundwater contours and ground elevation GIS data provided by the lead agency.

BMP Design Parameters
BMP Opportunity Area
The area in acres of the BMP opportunity area(s) identified during the field investigations and follow-up discussions. This process is described in Section 2 of Appendix 4.C.

Recommended Maximum BMP Depth
The depth in feet of the recommended BMP project. This depth is based on groundwater depth and practical project design characteristics, as discussed in Section 2 of Appendix 4.C.

Available BMP Volume
The BMP volume in acre-feet that is potentially available at the project site. This volume is based on the BMP opportunity area and recommended depth presented above, as discussed in Section 2 of Appendix 4.C.

Recommended Active BMP Volume
The recommended BMP volume in acre-feet. This volume is recommended based on the hydrologic modeling and optimization results as discussed in Section 2 of Appendix 4.C.

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-12 Draft June 2015

4.5.1 North Hollywood Park
North Hollywood Park is located within the City of Los Angeles in an area that drains to Tujunga Wash.

Park facilities include an auditorium, baseball diamonds, basketball courts, playground, indoor gym, picnic tables, seasonal pool, and tennis courts. The potential BMP type is proposed as a below‐ground retention/infiltration basin situated beneath open field space in the south and central areas of the park.

No maximum drainage area was identified for this site since it is located adjacent to a receiving waterbody, Tujunga Wash. After review of available site opportunities and surrounding infrastructure, a smaller (alternative) drainage area was delineated, encompassing approximately 5,122 acres.

After reviewing the hydrologic model results and estimated runoff volume for the various diversion scenarios, it was determined that this project site was suitable for a retention/infiltration BMP sized to accommodate the 85th percentile design storm flows contributed from the smaller alternative drainage area. As a result, the recommended active volume of the BMP is 38 acre feet.

Table 4-3 summarizes key conceptual design parameters of the BMP proposed at North Hollywood Park. Figure 4-5 presents summary facts of the North Hollywood Park signature project. Figures 4-6 to 4-8 provided on the following pages show proposed site features and the tributary drainage area(s) considered during the engineering and environmental feasibility analysis.

Table 4-3. Key Design Parameters for North Hollywood Park Summary of North Hollywood Park (NHP)
Project Site
Param
eters
Total (Maximum) Drainage Area N/A
Alternative (Minimum) Drainage Area 5,122 ac
Maximum Required BMP Volume N/A
Alternative Required BMP Volume 38.0 ac‐ft
Groundwater Depth 65 ft
BMP Design
Param
eters
BMP Opportunity Area 7.8 ac
Recommended Maximum BMP Depth 20 ft
Available BMP Volume 156 ac‐ft
RecommendedActive BMP Volume 38.0 ac‐ft

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-13 Draft June 2015
Figure 4-5. Summary Facts: North Hollywood Park Signature Project

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-14 Draft June 2015
Figure 4-6. North Hollywood Park Subsurface Infiltration Drainage Area

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-15 Draft June 2015
Figure 4-7. North Hollywood Park Subsurface Infiltration Site Location

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-16 Draft June 2015
Figure 4-8. North Hollywood Park Subsurface Infiltration Concept

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-17 Draft June 2015

4.5.2 Almansor Park
The Alhambra Golf Course and Almansor Park are located in the City of Alhambra in an area that drains to Alhambra Wash. The Park consists of open grass fields, picnic tables with covered shelters, playgrounds, baseball fields, tennis courts, meeting/activity rooms, restrooms, and basketball court.

During the site visit it was noted that the trail around the perimeter of Almansor Park is popular among residents. The potential BMP is proposed as a below‐ground retention/infiltration basin situated beneath the baseball fields and open space in the southwest portions of the park.

The maximum drainage area for this project site is approximately 1,145 acres. After review of available site opportunities and surrounding infrastructure, a smaller (alternative) drainage area was delineated, encompassing approximately 51 acres.

After reviewing the hydrologic model results and estimated runoff volumes for the various diversion scenarios, it was determined that a retention/infiltration BMP sized to accommodate all inline flows contributed from the maximum drainage area is best suited for this project site. As a result, the recommended active volume of the BMP is 74.7 acre‐feet.

Table 4-4 below summarizes key conceptual design parameters of the BMP proposed at Amansor Park. Figure 4-9 presents summary facts of the Almansor Park signature project. Figures 4-10 to 4- 12 provided on the following pages show proposed site features and the tributary drainage area(s) considered during the engineering and environmental feasibility analysis.

Table 4-4. Key Design Parameters for Almansor Park
Summary of Almansor Park (AL01)
Project Site
Parameters
Total (Maximum) Drainage Area 1,145 ac
Alternative (Minimum) Drainage Area 51 ac
Maximum Required BMP Volume 49.0 ac‐ft
Alternative Required BMP Volume 0.515 ac‐ft
Groundwater Depth 165 ft
BMP Design
Parameters
BMP Opportunity Area 10.2 ac
Recommended Maximum BMP Depth 25 ft
Available BMP Volume 255 ac‐ft
RecommendedActive BMP Volume 74.7 ac‐ft

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-18 Draft June 2015
Figure 4-9. Summary Facts: Almansor Park Signature Project

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-19 Draft June 2015
Figure 4-10. Almansor Park Surface and Subsurface Drainage Area

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-20 Draft June 2015
Figure 4-11. Almansor Park Surface and Subsurface Infiltration Site

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-21 Draft June 2015
Figure 4-12. Almansor Park Infiltration Concept

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-22 Draft June 2015

4.5.3 Fremont Park
Fremont Park is located in Glendale in an area that drains to Verdugo Wash. The park is approximately 8 acres and consists of basketball courts, horseshoe courts, tennis courts, volleyball courts, playground equipment, and a wading pool. The potential BMP is proposed as a below‐ ground retention/infiltration basin situated beneath the open field space in the southeast corner of the park site.

No maximum drainage area was identified for this site since it is located adjacent to a receiving waterbody, Verdugo Wash. After review of available site opportunities and surrounding infrastructure, a smaller (alternative) drainage area was delineated, encompassing approximately 206 acres. A considerable part of this alternative watershed area is comprised of Caltrans right‐of‐way for the CA‐134 Freeway.

After reviewing the hydrologic model results and estimated runoff volumes for the various diversion scenarios, it was determined that this site is not suited for accommodating the 85th percentile design storm runoff volume contributed from the smaller drainage area. As a result, a BMP implemented at this site will provide important water quality benefits; however, it will not qualify as a regional project. As such, the recommended active volume of the BMP is 8.0 acre‐feet.

Table 4-5 below summarizes key conceptual design parameters of the BMP proposed at Fremont Park Figure 4-13 presents summary facts of the Fremont Park signature project. Figures 4-14 to 4- 16 provided on the following pages show proposed site features and the tributary drainage area(s) considered during the engineering and environmental feasibility analysis.

Table 4-5. Key Design Parameters for Fremont Park
Summary of Fremont Park (GL01)
Project Site
Parameters
Total (Maximum) Drainage Area N/A
Alternative (Minimum) Drainage Area 206 ac
Maximum Required BMP Volume N/A
Alternative Required BMP Volume 16.0 ac‐ft
Groundwater Depth 50 ft
BMP Design
Parameters
BMP Opportunity Area 0.4 ac
Recommended Maximum BMP Depth 20 ft
Available BMP Volume 8 ac‐ft
RecommendedActive BMP Volume 8.0 ac‐ft

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-23 Draft June 2015
Figure 4-13. Summary Facts: Fremont Park Signature Project

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-24 Draft June 2015
Figure 4-14. Fremont Park Subsurface Infiltration Drainage Area

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-25 Draft June 2015
Figure 4-15. Fremont Park Subsurface Infiltration Site Location

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-26 Draft June 2015
Figure 4-16. Fremont Park Subsurface Infiltration Concept

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-27 Draft June 2015

4.5.4 Roosevelt Park
Roosevelt Park is located in unincorporated Los Angeles County. The park is a large facility that includes basketball courts, picnic facilities with barbecue grills, playground equipment, a senior center, community room, computer center, fitness zone, and gym. The County investigated several BMP options including an infiltration basin near the north end of the park and dry wells to the east and west of the park.

The maximum drainage area for this project site is approximately 2,250 acres. After review of the available site information and surrounding infrastructure, a smaller (alternative) drainage area was delineated, encompassing approximately 190 acres.

After reviewing the hydrologic model results and estimated runoff volumes for the various diversion scenarios, it was determined that this site is suitable for a BMP sized to accommodate more than the 85th percentile design storm runoff volume contributed from the maximum drainage area. As a result, the recommended active volume of the BMP was initially suggested as 138.2 acre feet.

After reviewing this recommendation the County requested that a BMP with 8.4 AF be implemented at this location.

Table 4-6 below summarizes key conceptual design parameters of the BMP proposed at Roosevelt Park. Figure 4-17 presents summary facts of the Roosevelt Park signature project. Figures 4-18 to 4- 19 provided on the following pages show proposed site features and the tributary drainage area(s) considered during the engineering and environmental feasibility analysis.

Table 4-6. Key Design Parameters for Roosevelt Park
Summary of Roosevelt Park (LAC01)
Project Site
Parameters
Total (Maximum) Drainage Area 2,250 ac
Alternative (Minimum) Drainage Area 190 ac
Maximum Required BMP Volume 82.4 ac‐ft
Alternative Required BMP Volume 8.4 ac‐ft
Groundwater Depth 80 ft
BMP Design
Parameters
BMP Opportunity Area 10 ac
Recommended Maximum BMP Depth 20 ft
Available BMP Volume 200 ac‐ft
Recommended Active BMP volume 8.4 ac-ft

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-28 Draft June 2015
Figure 4-17. Summary Facts: Roosevelt Park Signature Project

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-29 Draft June 2015
Figure 4-18. Roosevelt Park Subsurface Infiltration Drainage Area

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-30 Draft June 2015
Figure 4-19. Roosevelt Park Subsurface Infiltration Concept

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-31 Draft June 2015

4.5.5 Sierra Vista Park
Sierra Vista Park is located within the City of Monterey Park. The park includes a senior/community center, baseball diamond, basketball court, picnic shelters, tennis courts, restrooms, and playground equipment. The potential BMP type is proposed as a below‐ground retention/infiltration basin situated beneath the baseball diamond in the southwest corner of the site.

The maximum drainage area for this project site is 2,928 acres. After review of available site information and surround infrastructure data, a smaller (alternative) drainage area was delineated, encompassing approximately 800 acres.

After reviewing the hydrologic model results and estimated runoff volumes for the various diversion scenarios, it was determined that this site cannot accommodate the 85th percentile design storm flows from the smaller drainage area. Thus, it is recommended that the BMP be sized for retention/infiltration of approximately 10 acre-feet of runoff, which will be conveyed to the BMP via a 20 cubic feet per second (cfs) pumped diversion. 20 cfs is viewed as a maximum realistic peak pumped flowrate.

Table 4-7 below summarizes key conceptual design parameters of the BMP proposed at Sierra Vista Park. Figure 4-20 presents summary facts of the Sierra Vista Park signature project. Figures 4-21 to 4-23 provided on the following pages show proposed site features and the tributary drainage area(s) considered during the engineering and environmental feasibility analysis.

Table 4-7. Key Design Parameters for Sierra Vista Park
Summary of Sierra Vista Park (MP01)
Project Site
Parameters
Total (Maximum) Drainage Area 2,928 ac
Alternative (Minimum) Drainage Area 800 ac
Maximum Required BMP Volume 178.6 ac‐ft
Alternative Required BMP Volume 48.6 ac‐ft
Groundwater Depth 80 ft
BMP Design
Parameters
BMP Opportunity Area 0.7 ac
Recommended Maximum BMP Depth 20 ft
Available BMP Volume 14 ac‐ft
RecommendedActive BMP Volume 10.0 ac‐ft

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-32 Draft June 2015
Figure 4-20. Summary Facts: Sierra Vista Park Signature Project

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-33 Draft June 2015
Figure 4-21. Sierra Vista Park Drainage Area

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-34 Draft June 2015
Figure 4-22. Sierra Vista Park Site Location

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-35 Draft June 2015
Figure 4-23. Sierra Vista Park Subsurface Infiltration Concept

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-36 Draft June 2015

4.5.6 San Fernando Regional Park
The park representing the San Fernando Regional Park is located within the City of San Fernando. The park includes open field space, baseball diamonds, community center, and pool facilities. The potential BMP type is proposed as a below‐ground retention/infiltrationbasin situated beneath the open fields and baseball diamond at the southwest end of the park.

No maximum drainage area was identified for this site since it is located adjacent to a receiving waterbody, Pacoima Wash. After review of available site opportunities and surrounding infrastructure, a smaller (alternative) drainage area was delineated, encompassing approximately 423 acres.

After reviewing the hydrologic model results and estimated runoff volumes for the various diversion scenarios, it was determined that this site is suitable for an underground retention/infiltration BMP sized to accommodate more than the 85th percentile design storm runoff volume contributed from the smaller drainage area. As a result, the recommended active volume of the BMP is 22.6 acre‐feet.

Table 4-8 below summarizes key conceptual design parameters of the BMP proposed at San Fernando Regional Park. Figure 4-24 presents summary facts of the San Fernando Regional Park signature project. Figures 4-25 to 4-27 provided on the following pages show proposed site features and the tributary drainage area(s) considered during the engineering and environmental feasibility analysis.

Table 4-8. Key Design Parameters for San Fernando Regional Park Summary of San Fernando Regional Park (SF01)
Project Site
Parameters
Total (Maximum) Drainage Area N/A
Alternative (Minimum) Drainage Area 423 ac
Maximum Required BMP Volume N/A
Alternative Required BMP Volume 11.3 ac‐ft
Groundwater Depth 50 ft
BMP Design
Parameters
BMP Opportunity Area 2.7 ac
Recommended Maximum BMP Depth 20 ft
Available BMP Volume 54 ac‐ft
RecommendedActive BMP Volume 22.6 ac‐ft

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-37 Draft June 2015
Figure 4-24. Summary Facts: San Fernando Park Signature Project

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-38 Draft June 2015
Figure 4.25. San Fernando Regional Park Subsurface Infiltration Drainage Area

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-39 Draft June 2015
Figure 4.26. San Fernando Regional Park Subsurface Infiltration Site Location

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-40 Draft June 2015
Figure 4-27. San Fernando Park Subsurface Infiltration Concept

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-41 Draft June 2015

4.5.7 Lacy Park
Lacy Park is a public park located within the City of San Marino in an area that drains to the ULAR. Park features include a picnic area heavily used by residents, open green space, two walking trails, and tennis courts. The potential BMP type proposed is a below‐ground retention/infiltration basin situated in the center of the park beneath a depressed area of land that used to be a natural lake.

The maximum drainage area for this project site is approximately 1,067 acres. After review of available site information and surrounding infrastructure, a smaller (alternative) drainage area was delineated, encompassing approximately 928 acres.

After reviewing the hydrologic model results and estimated runoff resulting from the various diversion scenarios, it was determined that this is suitable for an underground retention/infiltration BMP sized to accommodate the 85th percentile design storm runoff volume contributed from the maximum drainage area. As a result, the recommended active volume of the BMP is 46.4 acre‐feet.

Table 4-9 below summarizes key conceptual design parameters of the BMP proposed at the Lacy Park.

Figure 4-28 presents summary facts of the Lacy Park signature project. Figures 4-29 to 4-31 provided on the following pages show proposed site features and the tributary drainage area(s) considered during the engineering and environmental feasibility analysis.

Table 4-9. Key Design Parameters for Lacy Park
Summary of Lacy Park (SM01)
Project Site
Parameters
Total (Maximum) Drainage Area 928 ac
Alternative (Minimum) Drainage Area 1,067 ac
Maximum Required BMP Volume 46.6 ac‐ft
Alternative Required BMP Volume 40.0 ac‐ft
Groundwater Depth 145 ft
BMP Design
Parameters
BMP Opportunity Area 2.4 ac
Recommended Maximum BMP Depth 20 ft
Available BMP Volume 48 ac‐ft
RecommendedActive BMP Volume 46.4 ac‐ft

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-42 Draft June 2015
Figure 4-28. Summary Facts: Lacy Park Signature Project

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Figure 4-29. Lacy Park Drainage Area

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Figure 4-30. Lacy Park Site Location

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Figure 4-31. Lacy Park Subsurface Infiltration Concept

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-46 Draft June 2015

4.5.8 Lower Arroyo Park
Lower Arroyo Park is located within the City of South Pasadena in an area that drains to Arroyo Seco. A channelized portion of Arroyo Seco runs through the center of the proposed site parcel. Park facilities include two baseball diamonds, open field space, and playground equipment. The potential BMP type is proposed as a below‐ground retention/infiltrationbasin situated beneath the baseball diamonds and other open field space in the southwest corner and northern portions of the park.

No maximum drainage area was identified for this site since it is located adjacent to a receiving waterbody, Arroyo Seco. After review of available site opportunities and surrounding infrastructure, a smaller (alternative) drainage area was delineated, encompassing approximately 145 acres.

After reviewing the hydrologic model results and estimated runoff volume for the various diversion scenarios, it was determined that this project site was suitable for a retention/infiltration BMP sized to accommodate more than the 85th percentile design storm flows contributed from the smaller alternative drainage area. As a result, the recommended active volume of the BMP is 3.7 acre feet.

Table 4-10 below summarizes key conceptual design parameters of the BMP proposed at Lower Arroyo Park. Figure 4-32 presents summary facts of the Lower Arroyo Park signature project. Figures 4-33 to 4-35 provided on the following pages show proposed site features and the tributary drainage area(s) considered during the engineering and environmental feasibility analysis.

Table 4-10. Key Design Parameters for Lower Arroyo Park Summary of Lower Arroyo Park (SP01)
Project Site
Parameters
Total (Maximum) Drainage Area N/A
Alternative (Minimum) Drainage Area 145 ac
Maximum Required BMP Volume N/A
Alternative Required BMP Volume 0.06 ac‐ft
Groundwater Depth 25 ft
BMP Design
Parameters
BMP Opportunity Area 10.6 ac
Recommended Maximum BMP Depth 25 ft
Available BMP Volume 265 ac‐ft
RecommendedActive BMP Volume 3.7 ac‐ft

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-47 Draft June 2015
Figure 4-32. Summary Facts: Lower Arroyo Park Signature Project

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-48 Draft June 2015
Figure 4-33. Lower Arroyo Park Subsurface Infiltration Drainage Area

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Figure 4-34. Lower Arroyo Park Subsurface Infiltration Site Location

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-50 Draft June 2015
Figure 4-35. Lower Arroyo Park Subsurface Infiltration Concept

4.6 How is the EWMP Integrated with Previous, Ongoing
and Future Water Quality Planning Efforts?
The EWMP includes a compilation of numerous previous stormwater compliance planning documents created for the ULAR, and the EWMP represents the “master stormwater compliance plan” moving forward. As such, it is important to recognize and, to the extent practicable, incorporate other planning efforts in the LA River watershed. This section provides a brief overview of the previous planning documents incorporated into the EWMP and considers how the EWMP will be integrated into other efforts to restore and provide access to the Los Angeles River and increase the reliability of local water supplies.

4.6.1 Previous Water Quality Planning Efforts
The process of developing a set of regional project opportunities described above included a review and analysis of many local and regional planning efforts underway by many other agencies and organizations throughout the watershed. The previously developed plans reviewed during EWMP development include the following:
 Implementation Plans for the LA River and Tributaries Metals TMDLs:
- City of Los Angeles Draft Implementation Plan, 2010

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-51 Draft June 2015
- Calabasas Metals TMDL Implementation Plan, 2010
- Hidden Hills Metals TMDL Implementation Plan, 2010
- La Cañada Flintridge Metals TMDL Implementation Plan, 2010 - Multi- Pollutant TMDL Implementation Plan for the Unincorporated County Area of the Los Angeles River Watershed, 2010
 Los Angeles River Revitalization Plan, 2011
 USACE Ecosystem Restoration Feasibility Study (Draft), 2013  Los Angeles River Master Plan, 1996
 Arroyo Seco Watershed Management Plan, 2006
 Tujunga-Pacoima Watershed Management Plan, 2008
 Sun Valley Watershed Management Plan, 2004
 Greater Los Angeles Integrated Regional Water Management Plan (LA IRWMP), 2006  Greater Los Angeles Integrated Regional Water Management Plan (LA IRWMP), 2013  City of Los Angeles Proposition O Monthly Report, October 2013  Upper Los Angeles River Watershed Report, Phase III - A Prioritized Approach to Selecting Runoff Capture Projects (December 2013)
 Water Quality Compliance Master Plan for Urban Runoff (May 2009) The list of over 100 regional projects identified for the EWMP includes many of the projects described in these planning documents. In some cases, the project opportunities identified in previous planning documents are outside of the ownership or jurisdiction of the EWMP Group members. While most jurisdictions decided to not include non-agency owned parcels in the regional project selection process, a database of non-owned opportunities was developed and is available as a reference document for future use by EWMP Group members. Over the course of adaptive management, nonagency owned opportunities can be evaluated for inclusion in the EWMP implementation Strategy.

Furthermore, over the course of adaptive management there may be many opportunities discovered to combine new project concepts with existing infrastructure. As an example, shown in Appendix 4D are three concept designs by City of Los Angeles for leveraging existing pump stations to manage and treat stormwater using innovative retrofits.

4.6.2 Los Angeles River Restoration and Revitalization Efforts There are multiple initiatives in the LA River watershed to restore habitat, increase public access to waterways and develop greenways that provide new recreational opportunities. Leaders of these efforts are numerous, including, The LA River Corp, Santa Monica Mountains Conservancy, Mountains Recreation and Conservation Authority, Amigos de los Rios, The River Project, Tree People, Friends of the LA River, Council for Watershed Health, and many others. As the EWMP Implementation Strategy is pursued, it will be important to integrate stormwater quality / compliance with these other efforts

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-52 Draft June 2015
to make the river more safe, accessible, healthy and beautiful. A key consideration will be the component of the EWMP Implementation Strategy achieved by regional projects on private land. As shown in Figure 4-2, regional projects on private land are a major component of the EWMP Implementation Strategy and thus there may be much potential to leverage acquired land to achieve stormwater compliance goals. Over time, the regional BMP programs will seek to identify additional public opportunities and identify strategic locations to acquire land for siting stormwater control measures. As land acquisition efforts are pursued, they will likely consider the potential multiple benefits of habitat protection, increasing public access, providing recreation opportunities and perhaps even restoring floodplains in certain areas.

To illustrate how the effort to identify regional projects on private land could be integrated with related restoration efforts, consider Los Angeles River Ecosystem Restoration Feasibility Study 11. The study, which is a partnership between the City of Los Angeles Bureau of Engineering and the US Army Corps of Engineers, includes an evaluation of alternatives for the purpose of restoring 11 miles of the Los Angeles River from approximately Griffith Park to downtown Los Angeles, while maintaining existing levels of flood risk management in this highly urbanized watershed. Restoration measures considered include:
 Creation and reestablishment of historic riparian strand and freshwater marsh habitat to support increased populations of wildlife and enhance habitat connectivity;  Increasing opportunities for connectivity to ecological zones, such as the Santa Monica Mountains, Verdugo Hills, Elysian Hills, and San Gabriel Mountains;  Reintroduction of ecological and physical processes, such as a more natural hydrologic and hydraulic regime that reconnects the river to historic floodplains and tributaries, reduced flow velocities, increased infiltration, improved natural sediment processes, and improved water quality; and
 Evaluating opportunities for passive recreation that is compatible with the restored environment.

The study also identifies a more focused study area of the Los Angeles River as the “Area with Restoration Benefits and Opportunities for Revitalization” (ARBOR) Reach, which extends from the Headworks at the upstream end to First Avenue at the downstream end. Within the ARBOR area, the following project opportunities have been highlighted:
 Piggyback Yard
 Arroyo Seco Land
 Verdugo Wash Land
These areas are key candidates for future integration with the EWMP process, especially pursuit of regional projects on private land. Future efforts to achieve the vision for the ARBOR Reach will likely include land acquisition. Shown in Figure 4-36 are the City of Los Angeles subwatersheds in the ARBOR Reach that include regional projects on private land as a part of the EWMP Implementation

11 http://www.spl.usace.army.mil/Portals/17/docs/publicnotices/DraftIntegratedReport.pdf

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-53 Draft June 2015
Strategy. As the EWMP is implemented, opportunities to integrate regional projects into the restoration efforts along the ARBOR Reach will be pursued.

A similar EWMP integration effort will need to take place for the other types of restoration and public access initiatives, as mentioned above.

4.6.3 Stormwater Capture Master Plan (City of Los Angeles Department of Water and Power)
The City of Los Angeles Department of Water and Power is undertaking the Stormwater Capture Master Plan (SCMP)12, a significant regional planning effort to identify opportunities to increase stormwater capture throughout the City. Goals and activities include:
 Increase reliability and sustainability of local water supply  Enhance stormwater capture for water supply
 Quantify potential stormwater capture both short term (2035) and long term (2099)  Define and prioritize groundwater aquifers ‘well suited’ for infiltration  Evaluate inflows and outflows of stormwater.
 Evaluate effectiveness of stormwater BMPs
Many of the projects identified by the SCMP will have positive benefits on water quality, and over the course of EWMP adaptive management, those projects and benefits may be incorporated into the EWMP. The City of Los Angeles is developing a One Water LA strategy13 to integrate drinking water, wastewater and stormwater goals, and integration of the EWMP and SCMP will be key consideration.

One project from the SCMP that has already been integrated into the ULAR EWMP is the Strathern Park, see Figure 4-37 for a description of the concept.

12 https://www.ladwp.com
13 http://www.lacitysan.org/irp/OneWater.htm

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-54 Draft June 2015
Figure 4-36. LA River ARBOR / Restoration Areas and Nearby Areas where Regional Projects on Private Land are a Component of the EWMP Implementation Strategy

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Section 4  Overview of EWMP Control Measures: Regional Projects and Integration with Related Planning Efforts Upper LA River EWMP 4-55 Draft June 2015
Figure 4-37. Concept for Strathern Park, future site of a stormwater capture and infiltration project that is integrated into ULAR EWMP

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Upper LA River EWMP 5-1 Draft June 2015
Section 5
Overview of EWMP Control Measures: Green
Infrastructure and Institutional BMPs
Complementary to the regional BMP program introduced in Section 4, robust green infrastructure programs will be critical to achieving water quality compliance in the ULAR watershed. While the regional BMP program is structured around large projects that are likely to be individually planned and designed specifically for available parcels, the green infrastructure component will implement vast numbers of distributed control measures in available rights-of-way and on both private and public parcels (where regional BMPs are not feasible/desirable). This section provides an overview of the green infrastructure programs within the EWMP and highlights several signature projects as an example of the types of efforts that are upcoming and ongoing. The details of the EWMP Implementation Strategy and RAA results are provided in later sections of the EWMP.

5.1 What Types of Green Infrastructure Control Measures are included in the EWMP?
The ULAR EWMP includes two primary types of green infrastructure – LID and green streets – as illustrated below. Appendix 5.A provides fact sheets explaining both green streets and LID practices.

Low-Impact Development: these are distributed structural practices that capture, infiltrate, and/or treat runoff at the parcel-scale (normally less than 10 tributary acres (Figure 5-1). Common LID practices include bioretention, permeable pavement, and other infiltration BMPs that prevent runoff from leaving a parcel. Rainfall harvest practices such as cisterns can also be used to capture rainwater - that would otherwise run off a parcel - and use it to offset potable water demands. The types of LID incorporated into the EWMP are the LID ordinance, residential LID, and LID retrofits of public parcels.

Figure 5-1. Conceptual schematic of LID implemented at the site scale (arrows indicate water pathways)

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Section 5  Overview of EWMP Control Measures: Green Infrastructure and Institutional BMPs Upper LA River EWMP 5-2 Draft June 2015
Green Streets: these are distributed structural practices that are typically implemented as linear bioretention/biofiltration practices installed parallel to roadways. Systems receive runoff from the gutter via curb cuts or curb extensions14 (sometimes called bump outs) and infiltrate it through native or engineered soil media. Permeable pavement can also be implemented in tandem, or as a standalone practice, in parking lanes of roads (Figure 5-2).

Figure 5-2. Conceptual schematic of green street
(arrows indicate water pathways)

5.2 What is the Role of Green Infrastructure in the EWMP? Green infrastructure will be responsible for a major portion of the pollutant reduction to be achieved by the EWMP. Green infrastructure makes up over 58 percent of the control measure capacity in the EWMP to be implemented by 2028, as shown in Figure 5-3 (LID and green streets each make up 40 percent and 18 percent, respectively). The total network of LID, green streets and regional BMPs in the EWMP Implementation Strategy represents approximately 20 Rose Bowls of BMP capacity. Given the large number of green infrastructure control measures that make up the EWMP Implementation Strategy, it is envisioned that green infrastructure will be implemented through “programs,” namely watershed-scale LID and green street programs. These programs will consider the following objectives:
 Identify and prioritize opportunities – Individual green infrastructure projects and programs can vary widely in cost efficiency and site applicability. Assessing and comparing individual project opportunities (e.g., Street A vs. Street B) or programs (e.g. residential LID vs. green streets) will help to define the most cost effective decisions.  Generate demonstration projects – A series of early-stage demonstrations will serve several key purposes: (1) facilitate public interest, education, and support in the programs; (2) collect

14 While the RAA assumed green streets are engineered with bioretention cells, there is potential for lessengineered options (“parkway basins”) to be an element of the EWMP Implementation Strategy. Parkway basins are described as an element of the residential LID program, since to date they have been a component of residential LID demonstration projects in the LA River watershed.

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Section 5  Overview of EWMP Control Measures: Green Infrastructure and Institutional BMPs Upper LA River EWMP 5-3 Draft June 2015
BMP performance data for future adaptive management; and (3) explore and document implementation alternatives and lessons learned.
 Establish standards – Since many green infrastructure opportunities are situated in common or standard spaces (e.g., rights of way), design standards and templates would streamline design processes and increase the certainty that EWMP pollutant reduction goals are achieved.  Systematize implementation – Due to the large number of discrete individual green infrastructure opportunities and the heavy reliance on these practices to address Water Quality Priorities, the EWMP includes a rapid rate of green infrastructure implementation. The implementation process will need to encourage rapid adoption by stakeholders (e.g., residential property owners), to establish streamlined project planning processes, and to cleanly integrate with existing capital improvement programs.

Not only are these green infrastructure programs critical to the success of the EWMP, they provide an excellent opportunity for multiple benefits to the local community. For example, the City of Los Angeles has already adopted a number of green infrastructure-based programs that promote water quality improvement as a primary or secondary objective. For instance, Table 5-1 provides an overview of the many street programs that the City of Los Angeles and its partners participate in. Recently, the City of Los Angeles adopted an ordinance that incorporates green infrastructure requirements for streets projects. These types of programs and ordinances represent the initial stages of developing a comprehensive infrastructure program specifically designed to meet water quality objectives.

Table 5-1. Summary of the City of Los Angeles’ Green Infrastructure-related Streets Programs Street
Program Description of Program & Objectives
Includes Stormwater ElementsIdentifies & Prioritizes OpportunitiesDemonstration ProjectsEstablishes StandardsSystematizes Implementation Green Streets
Designs streets & sidewalks to capture and/or infiltrate runoff in drought-tolerant bioswales and permeable
pavement.

X X X X X
Great Streets Active mayoral initiative in early stages of design and planning. X X X
Complete
Streets
Planning and guidance document with conceptual
designs for streets. Complete Streets Design Guide is
Companion to Mobility Plan 2035
X X X
Green Alleys
Program
Sister to Green Streets Program. Effort began as a
study led by USC and NGO partners. X X X X X
GRASS
Program
Collaboration between LASAN, Cal Poly, and UCLA.

Task to create a priority grid of stormwater capture
greenways.

X X X
Water LA
An NGO-led effort, this program promotes “urban
acupuncture” that includes installing shallow
infiltration basins in the parkways of residential
neighborhoods.

X X X X X
NGO – non-governmental organization

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Section 5  Overview of EWMP Control Measures: Green Infrastructure and Institutional BMPs Upper LA River EWMP 5-4 Draft June 2015
Figure 5-3. Relative Capacity of LID, Green Streets and Regional Control Measures to be implemented by the ULAR EWMP by 2028

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

5.3 How are Green Streets integrated into the EWMP?
The right-of-way along streets may be the most extensive opportunity for the ULAR EWMP Group to implement BMPs on public land. In developed areas, curb and gutter in the road provide an opportunity to intercept both dry and wet weather runoff prior to entering the storm drain system and treat it within the extents of the public right-of-way. Green streets have been demonstrated to provide “complete streets” benefits in addition to stormwater management, including pedestrian safety and traffic calming, street tree canopy and heat island effect mitigation, increased property values, and even reduced crime rates. Details on green street BMPs, including the additional benefits, are presented in Appendix 4.A.

To quantify the potential benefit of
green streets for pollutant reduction
and integrate them into the EWMP
Implementation Strategy, all available
streets throughout the watershed
were screened to define the maximum
available green street length, as shown
in Figure 5-4. The RAA evaluated a
series of detailed green street
implementation parameters
(described in detail in the RAA,
Section 6.3), and determined the
percent of available street
opportunities to be retrofitted with green infrastructure to meet EWMP objectives, as shown in Figure 5-5. While it is anticipated that the implementation of green streets will evolve over the course of adaptive management, the EWMP Implementation Strategy provides the foundation of a robust watershed-wide green streets program going forward.

Although the green streets program will carry significant responsibility for achieving EWMP goals, effort on this program must be balanced with other programs, especially the residential LID program and the regional BMP program.

For example, downstream of places where the residential LID program is heavily implemented, or upstream of locations where large regional projects are constructed, the need for green street retrofits will be reduced. As with the other programs, it will be important to track the details of green street implementation, such as street length, retention design characteristics, and drainage area to compare to the
assumptions used in and performance predicted by the RAA.

Further, the program should identify opportunities to reduce the O&M burden and engage stakeholders, such as through partnerships with homeowners and stewardship programs
with business owners.

Green Street Program Highlights:
 Implements green infrastructure in the rights-of-way
 High potential for significant load reduction
 Agencies retain ownership and O&M burden
 Design/construction standards can yield efficiency
 Strategic selection of streets can yield cost savings  Opportunity for integration with capital
improvement projects
 Data limitations currently hamper decision making
Typical residential green street

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Section 5  Overview of EWMP Control Measures: Green Infrastructure and Institutional BMPs Upper LA River EWMP 5-6 Draft June 2015
Figure 5-4. Green Street Screened Opportunities in the Upper Los Angeles River EWMP Area

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Section 5  Overview of EWMP Control Measures: Green Infrastructure and Institutional BMPs Upper LA River EWMP 5-7 Draft June 2015
Figure 5-5. Percent of Required Green Street Implementation in the Upper Los Angeles River EWMP Area Relative to Total Available Capacity
(i.e. percent utilization was calculated as the EWMP-prescribed BMP volume divided by the total available BMP volume)

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Section 5  Overview of EWMP Control Measures: Green Infrastructure and Institutional BMPs Upper LA River EWMP 5-8 Draft June 2015

5.4 How is Low Impact Development integrated into the
EWMP?
The LID program is an important component of the EWMP. While individually, LID projects are smaller than regional projects, when deployed across numerous parcels throughout the watershed, they can collectively make significant progress towards improving water quality and achieving RWLs. Since the vast majority (nearly 70 percent) of runoff from the developed portion of the watershed is generated from impervious areas on parcels, LID is a natural choice as a key EWMP strategy to treat runoff from parcel-based impervious areas. LID can be viewed as the “first line of defense” due to the fact that the water is treated on-site before it runs off from the parcel and travels downstream. Especially for areas where regional opportunities do not exist downstream, LID is an effective strategy that will only be limited by the extent of implementation. An overview of key components of the LID program is provided below. Technical details about how the BMP opportunities were identified and how each BMP was modeled in the RAA are provided in Section 6.3.

5.4.1 LID Ordinance (Redevelopment)
The MS4 Permit and local ordinances now require
significant development and redevelopment projects to
incorporate LID concepts into their site design. For
development and redevelopment15 projects, this means that the runoff normally generated by the parcel will be routed to individual BMPs, greatly improving runoff water quality and supporting attainment of EWMP objectives. The key
advantage to the EWMP Group members is that LID
implemented by new/redevelopment is 100 percent funded
by the developer. As such, the RAA assumes that a certain percentage of parcels are redeveloped over the course of the compliance period based on projected growth rates.

Under the LID ordinance, the EWMP Group
retains the responsibility of reviewing and
approving calculations, engineering plans, and
specifications provided by developers. As the
LID ordinance program matures, it will be
important to maintain a robust set of
engineering standards to ensure that BMPs are
being sized, sited, and designed properly. As
development and redevelopment occur
throughout the watershed, it will be important
for the EWMP Group members to track BMP implementation and compare to the projections made by the RAA. Ultimately, a strong LID ordinance program provides a cost-effective strategy to continually make progress towards EWMP goals.

15 New development will also require post-construction BMPs, but is not included in the RAA because postconstruction BMPs are assumed to restore predevelopment water quality (therefore resulting in no net improvement in water quality like when parcels are redeveloped and existing impervious area is treated).

LID Ordinance Highlights:
 Redevelopment projects improve water quality
 Costs to EWMP Group members are minimal
 Requires strong standards and oversight
 Benefit is proportional to growth / number of
redeveloped parcels
Biofiltration in a redeveloped shopping
center parking lot

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Section 5  Overview of EWMP Control Measures: Green Infrastructure and Institutional BMPs Upper LA River EWMP 5-9 Draft June 2015

5.4.2 Residential LID
Accounting for approximately 25 percent of all developed impervious area in the watershed, residential parcels
represent an important opportunity for LID
implementation. Runoff from residential parcels is often directly-connected to a curb and gutter or other conveyance system on the street. Treating runoff through a voluntary program at the residential parcel scale can significantly offset the need for regional or green infrastructure BMPs and could reduce the overall operations and maintenance burden on the EWMP Group members. The RAA assumes
that a residential LID program will be initiated within the watershed to encourage and incentivize residential
homeowners to retrofit their properties with LID features such as rain tanks (Section 6.3). The goal is
to annually enroll 1% of residential
parcels in the residential LID program
(after a 2-year startup process).

A well-designed residential LID program
will thoroughly engage individual
homeowners to establish a sense of
stewardship and ownership as they
transform small areas of their property
into stormwater treatment elements.

Partnering with key non-governmental organizations can
be an effective strategy to rapidly develop an effective program that includes community engagement and even
preparation of standard plans and procedures. Under
Water LA, demonstration projects by The River Project in the LA River watershed (www.theriverproject.org) have
successfully shown that residents are willing to actively engage and reduce their contribution to stormwater
runoff. These “urban acupuncture” demonstration
projects have included rain tanks, rain grading, and
pervious surfaces to prevent runoff from leaving the
homeowner’s parcel, along with parkway basins that
intercept runoff from the street and infiltrate it in the right-of-way.

Incentive programs can potentially be aligned with
existing water conservation programs such as turf replacement or xeriscaping incentives. As with other BMP programs, it will be important to track the number and design of BMPs implemented as part of this program in order to compare to projections made by the RAA.

Residential LID Program Highlights:
 Incentivizes installation of BMPs on residential land (rain tanks, hardscape removal, etc.)
 Offsets more expensive BMPs downstream
 NGO partners can help develop/administer program
 Homeowner engagement and stewardship is critical
 Benefit based on rate of adoption by homeowners
Residential LID retrofit in the form of
a xeriscaped infiltration swale
Community members engaged in “urban
acupuncture” (residential LID) demonstration
projects

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Section 5  Overview of EWMP Control Measures: Green Infrastructure and Institutional BMPs Upper LA River EWMP 5-10 Draft June 2015

5.4.3 LID on Public Parcels (retrofits)
Although public parcels represent less than 1 percent of all impervious land use in the watershed, they provide
key opportunities to implement LID. These opportunities provide several key advantages, including the ability to coordinate efforts with already-planned infrastructure
upgrades (e.g., parking lot rehabilitations), avoidance of land acquisition costs, and the opportunity for public
engagement and education.

Sites that attract significant public traffic, such as
libraries, City Hall, and parks can also provide excellent forums to demonstrate LID practices. Not
only will these demonstrations help the
Group members to achieve the goals of the
EWMP, if done properly they can advance
the public’s understanding, acceptance,
and support for these types of projects
which will be critical to changing public
behavior and also to developing financial
funding strategies for larger efforts (such
as green streets and regional projects).

5.4.4 Existing and Planned BMPs
In addition to the above three programs, the EWMP
incorporates ongoing structural BMP activities that have recently been or are currently taken place. An inventory of existing and planned structural BMPs within each
jurisdiction was developed to account for these activities.

Existing and planned BMPs were identified through a data request distributed to the WMG agencies and a literature review to identify BMPs within the ULAR EWMP area (as
presented in Appendix 6.F).

5.5 What are Some Example Green Infrastructure Projects that Support the EWMP?
While Section 4 of this EWMP places a focus on specific regional projects that were identified, selected, and prepared as part of the EWMP development effort, green infrastructure efforts are outlined through more of a programmatic lens. Unlike large regional projects, which require significant design efforts and can individually treat large drainage areas, green infrastructure projects are best discussed at a smaller scale, with the understanding that the smaller projects can be replicated throughout the watershed. To support this message, the following pages briefly introduce a handful of projects that illustrate the initial stages of the Group Members’ efforts to support existing green infrastructure programs and stimulate the further development of a robust suite of green infrastructure programs specifically designed to meet EWMP and other Group Member objectives.

Public Parcel LID Program Highlights:
 Implements LID on public parcels through retrofits
 Key opportunities for public education
 Readily integrated into planned site rehabilitation
 Can be leveraged to generate public support/funding
 Dependent on number of viable public parcels
Bioretention and permeable pavement at
the Los Angeles Zoological Park
Recently constructed biofiltration in a
parking lot

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Section 5  Overview of EWMP Control Measures: Green Infrastructure and Institutional BMPs Upper LA River EWMP 5-11 Draft June 2015

5.5.1 Plans to Address Dry- and Wet-Weather Urban Runoff for Downtown Los Angeles, Subwatersheds R2-02 and R2-J
Following a Bacteria Source Identification Study of 110 outfalls conducted by the City of Los Angeles,
subwatersheds R2-02 and R2-J, were highlighted as
having some of the largest water quality impacts. The
proposed projects would treat dry- and wet-weather
flows from the two subwatersheds with both
conventional and green infrastructure approaches. Dryweather flows will be treated with a Low Flow Diversion System (LFD) and a Reuse and Removal Urban Flow,
similar to those installed along Santa Monica Bay, and wet-weather flows will be treated with green infrastructure implemented in the street right-of-way. The proposed projects will be implemented in two phases with BMPs to treat dry- and wet-weather flows in the R2-J subwatershed in Phase I and in the R2-02 subwatershed in Phase II.

Dry-weather flow will be treated with a combination of a LFD and a Reuse and Removal Urban Flow intended to intercept flow from storm drains prior to discharging into the LA River. Runoff from the R2-J subwatershed will be diverted to a Reuse and Removal Urban Flow in Phase I. The system’s primary function will be the use of runoff for irrigation of the green infrastructure (using a system of pumps), with diversion of excess flow to the sewer system.

The R2-02 drainage area will be treated with
an LFD system, which will divert runoff
using gravity flow from the storm drain that
collects runoff through a newly installed
diversion pipe to be implemented in
Phase II.

Wet-weather flow is treated by green
streets, which will effectively reduce runoff
volumes and pollutants loads by replicating
natural hydraulic processes. Green streets
have also been shown to have multiple
economic, social, and additional
environmental benefits.

At a Glance:
 Location: 2 Subwatersheds in Downtown
Los Angeles
 Control Measures: Dry-weather
Diversion, Green Streets
 Expected Completion: TBD
 Approx. Cost: $10.7M
Treated subwatersheds
Green Street configuration

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Section 5  Overview of EWMP Control Measures: Green Infrastructure and Institutional BMPs Upper LA River EWMP 5-12 Draft June 2015

5.5.2 Plans to Address Dry- and Wet-Weather Urban Runoff for Downtown Los Angeles, Subwatershed R2-G
This project will support the City of Los Angeles’s
efforts to address dry weather discharges and meet
TMDL requirements in Reach 2 of the LA River, while
providing multiple other benefits associated with green infrastructure. The R2-G subwatershed is serviced by approximately 630 catch basins that drain to a network of both city and county storm drains that discharge to the LA River.

Dry-weather flow from two parallel City-owned storm drains at Mission Road will be intercepted by the installation of a diversion weir sized to minimize any hydraulic head losses to the existing system. The storm drains consist of a 90-inch reinforced concrete arch (north drain) and an 84-inch by 120-inch reinforced concrete box (south drain). This diverted flow will travel by gravity to the trunk sanitary sewer, Northeast Interceptor Sewer, located at the intersection of the US 101 freeway and Mission Road for treatment at the Hyperion Treatment Plant.

The wet-weather implementation strategy proposes incorporating treatment through green infrastructure installed throughout the Ramona Gardens community. Wet-weather flows will be diverted from the street and the surrounding land into permeable pavement and bioretention BMPs implemented in the right-ofway and on adjacent public parcels. Total watershed impacts include reduction in stormwater volume and removal of various pollutants. The project will also provide pedestrian safety and traffic calming benefits near a local schools and playgrounds.

At a Glance:
 Location: R2-G Subwatershed, Downtown
Los Angeles, CA
 Control Measures: Low Flow Diversion,
Green Infrastructure
 Expected Completion:
 Approx. Cost: $3.77M
Rendering of a proposed bioswale at
a local playground (top) and
rendering of a proposed permeable
alley (bottom)
Proposed LFD location

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Section 5  Overview of EWMP Control Measures: Green Infrastructure and Institutional BMPs Upper LA River EWMP 5-13 Draft June 2015

5.5.3 Brandon Street and Green Street Road Improvement Project The Brandon Street and Green Street Road Project is an urban residential roadway improvement project by the Los Angeles Department of Public Works which incorporated a variety of sustainable low impact development (LID) features for
roadway design and storm-water management and treatment.

The approximately $2 million project improved a three-quarter mile stretch of roadway.

Brandon Street and Green Street Project was originally conceived as a traditional road improvement project with a small drainage component. The Project was re-designed to feature sustainable design methodologies that enhance community aesthetics, improve pedestrian safety, and provide sustainable storm-water management through infiltration features. The LID features include parkways with bioretention planters, narrowed traffic roadways, larger curb returns with ADA compliant curb ramps, porous concrete gutters and porous sidewalks, permeable pavers at crosswalk locations, and an underground storm-water infiltration basin to capture runoff. The extensive infiltration capacity of these LID devices allowed the original proposed storm drain to be deleted from the project.

An estimated annual recharge of 3.75 acre-feet of storm-water is projected for the improvements, and has been demonstrated to function during storm events. Runoff from a major event in December, 2014, were so successfully infiltrated by the porous gutters and bioretention planters on Green Street that at the downstream end of the block the gutter flow was almost completely eliminated.

Green Street infiltration basin under
construction (Source: Google Earth)
At a Glance:
 Location: Brandon Street and Green Street,
Unincorporated Pasadena Community
 Control Measures: Bioretention, Permeable
Pavement, Infiltration Basin
 Expected Completion: Completed 2014
 Approx. Cost: $2M
Project location (Source: Google Earth)
(Google Earth)
Newly constructed bioretention
cells along Brandon Street

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Section 5  Overview of EWMP Control Measures: Green Infrastructure and Institutional BMPs Upper LA River EWMP 5-14 Draft June 2015

5.5.4 Arroyo Seco Urban Runoff Project No. 1
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 involves curb cuts to the existing sidewalk and installing bioretention cells throughout sidewalk sections. Remaining sidewalk area is to be retrofit with permeable pavement and the interior portions of the cells would remain vegetated with native shrubs and grasses.

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

At a Glance:
 Location: Longfellow Street and Avenue 52
 Control Measures: Bioretention, Permeable
Pavement
 Expected Completion: Spring 2017
 Approx. Cost: $280,850
Existing intersection of proposed project
site, oriented northwest on South Avenue
52 (Source: Google Earth)
Proposed project location proximate
to Arroyo Seco tributary (Source:

Google Earth)
(Google Earth)
Example of bioretention and permeable
pavement retrofits during construction, San
Diego, CA

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Section 5  Overview of EWMP Control Measures: Green Infrastructure and Institutional BMPs Upper LA River EWMP 5-15 Draft June 2015

5.5.5 Arroyo Seco Urban Runoff Project No. 2
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 involves infiltration of dry and wet weather stormwater and would provide service to 200 acres of drainage area. The available park land would be restored to its original condition to resume the use of the park. A stormwater runoff treatment train involving a set of BMPs will aid in the removal of trash, bacteria, and metals.

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

At a Glance:
 Location: Arr0yo Seco and Avenue 49
 Control Measures: Infiltration treatment
train
 Expected Completion: Winter 2019
 Approx. Cost: $6.65M
Existing condition of South Avenue 49
adjacent to the park, oriented SE towards
Arroyo Seco (Source: Google Earth)
Proposed project location proximate
to Arroyo Seco (Source: Google Earth)
Example subsurface infiltration gallery (source:

City of Los Angeles)