Contra Costa County Regional Alternative
Compliance System Overview
Rinta Perkins, CCCWP Interim Program Manager
City of Hercules City Council
April 28, 2026
Introduction
What Are the Challenges with the Existing System?
• The Municipal Regional
Stormwater Permit (MRP)
requires low impact
development (LID)/green
stormwater infrastructure
(GSI) to be implemented:
– On new development and
redevelopment projects (C.3.b)
– To retrofit a proportion of
permittee impervious surfaces
(C.3.j)
– To address PCBs/mercury
TMDLs in San Francisco Bay
(C.11/C.12)
What Are the Challenges with the Existing System?
Challenges:
• Some development sites have
physical or site use constraints
to implement GSI
• Distributed GSI is costly and
requires considerable effort to
maintain
• PCBs/mercury pollution is
concentrated in certain areas
of Contra Costa County
Contra Costa County PCBs Load Distribution
How can Regional Alternative Compliance (RAC) address th challenges?
• The RAC System allows an off-site optionfor new and
redevelopment projects to meet MRP C.3 requirements
– Other regulated stormwater dischargers may also participate (e.g., Caltrans)
• The RAC System allows for investment in regional GSI projec that:
– Are less expensive to implement and maintain per acre treated – Can be located to target old industrial areas
– Could provide multiple benefits
AND
• The RAC System establishes designated O&M funding to
ensure long-term performance of facilities
What is the Legal Basis for Alternative Compliance?
• Alternative compliance systems
are legally enabled through
existing rules, guidance, and plans
• Contra Costa County (CCC) RAC
System was developed in input
from:
– CCC Permittees
– Advisory Committee made from nine
SF Bay Area Counties + Caltrans +
Port of Oakland
– Water Quality Control Board and
EPA
– Internal and external Legal
Reviewers
RAC System
Overview
Contra Costa County RAC System
RAC Joint Powers Authority (JPA) and Community Facilities District (CFD)
RAC Joint Powers
Agreement
Initial Members
Permittee
1 Permittee
3 Permittee
2 Permittee
4 Permittee
5 Permittee
6 CIP Projects
Non-Profits
RAC System Participation
Sellers & Buyers
1. Form
Community
Facilities
District
2. RAC
Administration
Private
Developers
Functions of JPA
RAC System
Implementation
Process
RAC Joint Power Authority (JPA)
• JPA Formation and Independence
o A legally separate entity formed with its own liabilities, independent from agency members.
• Term Sheet and Membership
o Outlines JPA powers; how new members are admitted, and legislative body approval.
• Operational Structure and Staffing
o Contract manager instead of hiring employees (avoid pension liabilities and increase flexibility).
• Financial Responsibilities
o Limited to the JPA and shared administrative expenses among members.
RAC Community Facilities District
CFD formedwith initial taxable property only
and multi-jurisdiction “future annexation area”
Properties annex into the CFD as
they to opt to participate in RAC
System
CFD formationrequires three
meetings of JPA governing board
JPA authorizes the CFD to levy special taxes to finance the acquisition, improvement, rehabilitation, and maintenance of stormwater infrastructure
RAC Community Facilities District (Continued)
• Annexing property owner executes “unanimous
approval” (voting in favor of special taxes etc.)
• JPA legislative body may confirm annexations by
resolution
Annexation of Parcels into the
CFD from Future Annexation Area
• Resolution of intention to add territory
• Public hearing and resolution determining addition
of territory to future annexation area
When new public agencies join
the JPA, the JPA legislative body
may add new members’ territory
to the “future annexation area”
Next Steps for
Implementation
Implementation Steps and Timeline
Next Steps
• Sixteen agencies are interested in joining RAC JPA
• Final JPA Agreement based on City/Town/County attorneys’ comments
• Participate in RAC JPA coordination meetings and operationa discussions
• Adoption of resolution and approval of JPA agreement by the agency’s governing body
Contact
Rinta Perkins
Interim Program Manager
[email protected]
(925) 313-2392
Thank You!