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• Findings from the Permittees’ Industrial/Commercial Facilities Programs; • Findings from the Permittees’ Development Construction Programs; • Findings from the Permittees’ Public Agency Activities Programs; • TMDL source investigations;
• Watershed model results;
• Findings from the Permittees’ monitoring programs, including but not limited to, CIMP monitoring and TMDL compliance monitoring; and
• Any other pertinent data, information, or studies related to pollutant sources and conditions that contribute to the highest water quality priorities.
As stated earlier, the Dominguez Channel Watershed has significantly more industrial land use than the Santa Monica Bay Watershed (1,944 acres in Dominguez Channel vs 212 acres in SMB), and as a result, has some notably different pollutant sources when compared to the Santa Monica Bay Watershed. The following source assessment is broken down by pollutants applicable only to the Dominguez Channel Watershed.
Copper, Lead, Zinc, and Cadmium
The Dominguez Channel Toxics TMDL (which applies to wet weather only) provides general information on sources of metals within the Dominguez Channel Watershed but does not provide a detailed source assessment. The TMDL states that “the major pollutant sources of metals into Dominguez Channel and Torrance Lateral freshwaters are stormwater and urban runoff discharges.
Nonpoint sources include atmospheric deposition” (LARWQCB and USEPA, 2011).
SCCWRP conducted a detailed study of various wet weather pollutants throughout the Los Angeles region, including Dominguez Channel (Stein et al., 2007). They found that industrial land use sites contributed a substantially higher flux of copper and zinc compared to other land uses evaluated, followed by agriculture, recreational, transportation (for copper), and high density residential (for zinc). Wet weather EMCs for copper and zinc, based on the Los Angeles County land use EMC dataset (Geosyntec Consultants, 2012) were similar to SCCWRP’s findings, showing that the highest runoff concentrations are expected from industrial, transportation, and commercial land uses, excluding agriculture. With respect to copper, research has shown that brake pads are a significant source of copper in urban stormwater (TDC Environmental, 2013). Copper and other pollutants are deposited on roads and other impervious surfaces and then transported to aquatic habitats via stormwater runoff.
Pollutant loads of copper from urban land uses is expected to decrease due to Senate Bill (SB) 346 which was signed into law on September 25, 2010. This legislation phases out copper in vehicle brake pads over a period of years; milestones include the following dates:
• January 1, 2021: Limits the use of copper in motor vehicle brake pads to no more than five percent by weight; and
• January 1, 2025: Limits the use of copper in motor vehicle brake pads to no more than 0.5 percent by weight.
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A separate study focusing on zinc showed that the major sources of zinc in urban runoff are outdoor zinc surfaces (including galvanized surfaces) and tire wear debris (TDC Environmental, 2013).
Cadmium has similar sources, including tires and engine parts, as well as gasoline, antifreeze, and diesel oil. One study found that tire wear accounts for over 50 percent of the total cadmium and zinc loads in urban runoff (David et. al., 2001).
For lead, SCCWRP found that the greatest land use contributors were agricultural (minimal in Dominguez Channel Watershed), high density residential, and recreational (horse) land uses (Stein et al., 2007). Based on the Los Angeles County land use EMC dataset (Geosyntec Consultants, 2012), the highest lead contributing land uses are agriculture, industrial, commercial, and single family residential. Lead was also formerly used as an additive in gasoline and is still used in general aviation gasoline (Avgas) for small piston-engine aircraft. According to Federal Aviation Administration (FAA), Avgas emissions are the largest contribution to relatively low levels of lead emission in the U.S. (FAA, 2015). This has contributed to the contamination of some soils near highways and streets and in drainage ways in urban areas. Exhaust particulates, fluid losses, drips, spills, and mechanical wear products continue to contribute lead to street dust.
For both copper and lead, the SCCWRP and Los Angeles County datasets indicate that average EMCs exceed applicable CTR continuous concentration criteria for each land use sampled. For zinc, some land uses (single family residential, education, and vacant) have average EMCs below the CTR continuous concentration criterion, while others (commercial, industrial, transportation, multifamily residential, and agriculture) exceed this criterion. These land use EMC datasets were used to support BMP placement as part of the RAA.
Significantly, monitoring results collected as part of the Beach Cities CIMP demonstrate that lead levels within Beach Cities discharges are meeting final TMDL limits.
Toxicity
As is the case with metals, the Dominguez Channel Toxics TMDL does not provide a detailed source assessment for toxicity within the Dominguez Channel Watershed, nor is a linkage provided to other specific surrogate pollutants, such as total suspended solids or dissolved metals. The source assessment simply states that “the major sources of organo-chlorine pesticides [and] PCBs…into Dominguez Channel are stormwater and urban runoff discharges. Nonpoint sources include atmospheric deposition and fluxes from contaminated sediments into the overlying water” (LARWQCB and USEPA, 2011).
Pesticides are used in urban settings for structural pest control, landscape maintenance (parks, golf courses, cemeteries, and rights-of-way), vector control, and public health pest control. Two specific pesticides, diazinon and chlorpyrifos, were banned by the USEPA on December 31, 2005. As a result, mass emission monitoring at S28 has resulted in no measured exceedance of the 1 toxicity unit criteria for chlorpyrifos or diazinon in Dominguez Channel since 2006. Similarly, both DDT and PCBs were banned from general production and use in the 1970s, resulting in the elimination of active discharges of these chemicals to Dominguez Channel, SMB, and other local surface water bodies, except from residuals present from legacy sources.
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Toxicity monitoring has been conducted by other agencies in the Dominguez Channel to help assess if MS4 discharges are causing or contributing toxicity exceedances in Dominguez Channel. To date, no toxicity exceedances have occurred within Dominguez Channel or Torrance Lateral receiving waters. As a result, a toxicity identification evaluation (TIE) has not been necessary for the Beach Cities WMG.
Indicator Bacteria
Although the Dominguez Channel is 303(d) listed for indicator bacteria, a bacteria TMDL has not yet been developed for the watershed. E. coli data collected at outfalls as part of the Beach Cities CIMP indicates that bacteria levels are consistently higher than applicable standards during storm events. The source assessment for indicator bacteria within the Santa Monica Bay watershed portion of the Beach Cities EWMP area is provided above, and many of these urban anthropogenic and non-anthropogenic sources apply to the Dominguez Channel portion of the Beach Cities EWMP Area as well.
Organochlorine Pesticides (DDT)
Organochlorine pesticides (OC pesticides) are a large group of legacy pesticides, including DDT, that were previously used widely throughout the United States. Even though they have been banned from use for many years, they are slow to degrade and continue to persist in the environment.
Because of their chemical and physical properties, these pollutants tend to partition and bind preferentially to the surfaces of soil particles. When transported in stormwater-borne sediment to local receiving waters, OC pesticides have been shown to accumulate in the fatty tissue of fish and wildlife and bio-magnify in the food-web.
DDT was used widely in the U.S. between 1939 and 1970 as a pesticide. In 1963, DDT was declared a restricted material in California. The last year that substantial amounts of DDT were applied in California was 1970 when 1.2 million pounds of DDT were applied primarily to agricultural areas (LARWQCB, 2010).
Considering the ubiquitous use of DDT from 1939 through 1970 and understanding the history of land use and development within the Dominguez Channel Watershed, it is reasonable to expect that DDT was used in residential applications and that DDT and its breakdown products, DDE and DDD, may remain in soils within the watershed. However, outfall sampling data conducted to-date under the Beach Cities CIMP has not led to any detectable quantities of DDT in stormwater runoff.
Polychlorinated Biphenyls (PCBs)
Polychlorinated biphenyls (PCBs) are mixtures of synthetic organic chemicals that were commonly used for various applications from approximately 1929 until 1979 when the U.S. banned PCB manufacturing, processing, distribution, and use. PCBs may be present in products that were made before 1977 but are still in use today, such as transformers, fluorescent lighting fixtures, household caulking, paints and waxes (USEPA, 2012). U.S. EPA identifies the following list of products and materials that, if produced and installed prior to the 1979 ban, may still contain PCBs:5 5 https://www.epa.gov/pcbs/learn-about-polychlorinated-biphenyls-pcbs#commercial
Beach Cities EWMP | Appendix B | Water Quality Priorities B-23 | Page 2021
• Transformers and capacitors
• Electrical equipment including voltage regulators, switches, re-closers, bushings, and electromagnets
• Oil used in motors and hydraulic systems
• Old electrical devices or appliances containing PCB capacitors • Fluorescent light ballasts
• Cable insulation
• Thermal insulation material including fiberglass, felt, foam and cork • Adhesives and tapes
• Oil-based paint
• Caulking
• Plastics
• Carbonless copy paper
• Floor finish
The industrial nature of a significant portion of the Dominguez Channel Watershed implies that most of these may continue to be sources of PCBs in stormwater, with the most significant contributions likely coming from external building materials such as caulk or paint or in utility transformers. However, outfall sampling data conducted to-date under the Beach Cities CIMP has not led to any detectable quantities of PCBs in stormwater runoff.
Polycyclic Aromatic Hydrocarbons (PAHs) Including Benzo(a)pyrene Polycyclic aromatic hydrocarbons (PAHs) are a group of organic contaminants that are associated with the release of petroleum products (petrogenic sources) or form from the incomplete combustion of hydrocarbons (pyrogenic sources). PAHs are an environmental concern because they are toxic to aquatic life and because several of the individual PAH compounds are suspected human carcinogens. Research has shown that the dominant source of origin is pyrogenic (combustion of organic matter) in the Los Angeles Region, and PAHs are often deposited through atmospheric deposition and delivered to waterbodies in stormwater runoff (Sabin et al., 2009).
Other non-point sources may include leaking motor oil, tire wear, and vehicular exhaust.
PRIORITIZATION
Based on the water quality characterization above, the WBPCs have been classified into one of three categories, in accordance with the Permit: highest priority, high priority, and medium priority. This categorization is intended to prioritize WBPCs in order to guide the implementation of structural and institutional BMPs. An RAA was performed on the WBPCs in Categories 1, 2, and 3. Table B-6 summarizes the prioritized WBPCs within the Dominguez Channel Watershed portion of the Beach Cities EWMP Area.
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Table B-6. WBPC Prioritization and Pollutant Interim and Final Compliance Targets for Dominguez Channel Watershed Category Water Body Pollutant Reason for
Categorization WLA/Target Basis Interim TMDL WLA Final TMDL WLA or Other Target 1: Highest
Priority
Dominguez
Channel
Freshwater[1]
Toxicity
Dominguez
Channel Toxics
TMDL
Monthly Average 2 TUc [2] 1 TUc
Total Copper Wet Weather Single Event 207.51 ug/L[2] 9.7 ug/L[3] Total Lead Wet Weather Single Event 122.88 ug/L[2] 42.7 ug/L[3] Total Zinc Wet Weather Single Event 898.87 ug/L[2] 69.7 ug/L[3] Dominguez
Channel
Estuary
(including
Torrance
Lateral)
Total Copper Annual Average 220 mg/kg sediment[2] 31.6 mg/kg sediment
22.4 kg/yr[4]
Total Lead Annual Average 510.0 mg/kg sediment[2] 35.8 mg/kg sediment
54.2 kg/yr [4]
Total Zinc Annual Average 789.0 mg/kg sediment[2] 121 mg/kg sediment 271.8 kg/yr[4]
Cadmium Daily Maximum n/a 1.2 mg/kg sediment
DDT Annual Average 1.727 mg/kg sediment[2] 0.25 g/yr[4] Total PAHs Annual Average 31.60 mg/kg sediment[2] 0.134 kg/yr[4] PCBs Annual Average 1.490 mg/kg sediment[2] 0.207 g/yr [4] 2: High
Priority
Dominguez
Channel
(including
Torrance
Lateral) and
Dominguez
Channel
Estuary
Indicator Bacteria 303(d) List Exceedance Rate over 30- day Period n/a See Footnote 5
3: Medium
Priority
Dominguez
Channel
Freshwater
Benzo(a)pyrene
CIMP
Monitoring
California Toxics Rule
Human Health Standard n/a 0.049 ug/L[6]
[1]Wet weather only, based on the Dominguez Channel Toxics TMDL [2] The interim deadline for Dominguez Channel Toxic TMDL is 3/23/2012. [3] Also applicable to Torrance Lateral as an alternative compliance target. [4] Annual MS4 WLA to the entire Dominguez Channel estuary drainage area. [5]Per the Basin Plan Objective REC1 Water Bodies Limit for Indicator Bacteria, the statistical threshold value of E. coli (320/100 mL) is not to be exceeded by more than 10 percent of the samples collected in a calendar month. [6] The CTR Human Health numeric target is not directly applicable at outfalls, but has been utilized as an evaluative metric in this case.
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REFERENCES
City of Malibu, 2012. Comment Letter – Bacteria TMDL Revisions for Santa Monica Bay Beaches.
May 7.
Curren, J., S. Bush, S. Ha, M.K. Stenstrom, S. Lau, I.H.M. Suffet, 2011. Identification of subwatershed sources for chlorinated pesticides and polychlorinated biphenyls in the Ballona Creek watershed.
Science of the Total Environment, Vol. 409, Issue 13, pp. 2525-2533. 1 June 2011.
Davis A.P., M. Shokouhian, and S. Ni. 2001. Loading estimates of lead, copper, cadmium, and zinc in urban runoff from specific sources. Chemosphere.
Federal Aviation Administration (FAA), 2015. Aviation Gasoline, about Aviation Gasoline. (http://www.faa.gov/about/initiatives/avgas/)
Geosyntec Consultants, 2011a. Structural BMP Siting and Conceptual Design Study, Santa Monica Bay Beaches Bacteria TMDL Implementation. Produced for SMBBB TMDL Jurisdictional Groups 5 &
6. June.
Geosyntec Consultants, 2011b. Dry Weather Source Characterization and Control Summary, Santa Monica Bay Beaches Bacteria TMDL Implementation. Produced for SMBBB TMDL Jurisdictional Groups 5 & 6. June.
Geosyntec Consultants, 2012. A User’s Guide for the Structural BMP Prioritization and Analysis Tool (OCTA-SBPAT v1.0). Prepared for Orange County Transportation Authority. November 2012.
Klasing, S. and Brodberg, R., 2008. Development of Fish Contaminant Goals and Advisory Tissue Levels for Common Contaminants in California Sport Fish: Chlordane, DDTs, Dieldrin, Methylmercury, PCBs, Selenium, and Toxaphene. Pesticide and Environmental Toxicology Branch Office of Environmental Health Hazard Assessment California Environmental Protection Agency.
June 2008.
Los Angeles County Sanitation District (LACSD), 2009. Model Program for Bacterial Source Identification and Abatement Plan – Redondo Beach Pier Pilot Program. Final Report and Abatement Plan. December 1.
Los Angeles Regional Water Quality Control Board (LARWQCB), accessed 2021. Water Quality Control Plan (Basin Plan).
https://www.waterboards.ca.gov/losangeles/water_issues/programs/basin_plan/basin_plan_docu mentation.html
LARWQCB, 2010. Machado Lake Pesticides and PCBs TMDL. Staff Report - September 2, 2010.
LARWQCB and USEPA, 2011. Dominguez Channel and Greater Los Angeles and Long Beach Harbor Waters Toxic Pollutants TMDL. May 5.
LARWQCB, 2012a. Order No. R4-2012-0175 NPDES Permit No. CAS004001 Waste Discharge Requirements for Municipal Separate Storm Sewer System (MS4) Discharges within the Coastal Watersheds of Los Angeles County, except those Discharges Originating from the City of Long Beach MS4. November 8.
Beach Cities EWMP | Appendix B | Water Quality Priorities B-26 | Page 2021
LARWQCB, 2012b. Attachment A to Resolution No. R12-007, Proposed Amendment to the Water Quality Control Plan – Los Angeles Region to revise the Santa Monica Bay Beaches Bacteria TMDL.
June 7.
Long, E.R., D.D. MacDonald, S.L. Smith, and F.D. Calder, 1995. Incidence of adverse biological effects within ranges of chemical concentrations in marine and estuary sediments. Environmental Management. 19, (1): 81-97.
Sabin, L.D., K.A. Maruya, W. Lao, D. Diehl, D. Tsukada, K.D. Stolzenbach, and K.C. Schiff 2009.
Exchange of Polycyclic Aromatic Hydrocarbons among the Atmosphere, Water, and Sediment in Coastal Embayments of Southern California, U.S.A. Environmental Toxicology and Chemistry, Vol. 29, No. 2, pp. 265-274.
Southern California Coastal Water Research Project (SCCWRP), 2007. Technical Report 510 Sources, Patterns, and Mechanisms of Storm Water Pollutant Loading from Watersheds and Land Uses of the Greater Los Angeles Area, California, USA. Written by E.D. Stein, L.L. Tiefenthaler, and K.C. Schiff. March 2007.
State Water Resources Control Board (SWRCB), 2015. Water Quality Control Policy for Developing California’s Clean Water Act Section 303(d) List. February 3.
SWRCB, 2019. Water Quality Control Plan – Ocean Waters of California (Ocean Plan). February 4.
Stein, E.D., Tiefenthaler, L.L., and Schiff, K.C., 2007. “Sources, Patterns and Mechanisms of Storm Water Pollutant Loading From Watersheds and Land Uses of the Greater Los Angeles Area, California, USA.” Southern California Research Project (SCCWRP), Technical Report 510, March.
TDC Environmental, 2013. Estimate of Urban Runoff Copper Reduction in Los Angeles County from the Brake Pad Copper Reductions Mandated by SB 346. February.
USEPA, 2000. Office of Science and Technology Office of Water. Guidance for Assessing Chemical Contaminant Data for Use in Fish Advisories Volume 1: Fish Sampling and Analysis. EPA 823-B-00- 007 November.
USEPA, 2012. Santa Monica Bay Total Maximum Daily Loads for DDTs and PCBs.
Appendix C
Minimum
Control Measure
Customization and
Summary
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MINIMUM CONTROL MEASURE SUMMARY AND CUSTOMIZATION
Non-structural BMPs prevent or reduce the release of pollutants or transport of pollutants within the MS4 area but do not involve construction of physical facilities. Non-structural BMPs are often implemented as programs or strategies which seek to reduce runoff and/or pollution close to the source. Examples include but are not limited to: street sweeping, downspout disconnect programs, pet waste cleanup stations, irrigation ordinances, or illicit discharge elimination. Minimum control measures (MCMs) as set forth in the Permit are a subset of non-structural BMPs even though some MCMs include measures that require the implementation of structural BMPs.
The Beach Cities WMG has assessed the MCMs defined in the Permit to identify opportunities for focusing resources on the high priority issues in each watershed. The Permit requires the permittees to implement prescribed MCMs in each of six categories/programs: Public Information & Participation Program (PIPP), Industrial/Commercial Facilities, Planning & Land Development, Development Construction, Public Agency Activities (PAA), and Illicit Connection & Illicit Discharges (IC/ID) Elimination. These measures include procedures such as outreach programs, inspections, and reporting requirements designed to reduce runoff-related pollution within each permittees’ MS4 area. As LACFCD has no land use authority, the requirements of Industrial/Commercial Facilities, Planning & Land Development, and Development Construction programs are not applicable to LACFCD outside its own facilities (see Appendix G).
RECOMMENDED MCMS AND NON-STRUCTURAL BMPS
The Permit allows permittees developing an EWMP the opportunity to customize the MCMs specified in the Permit to focus resources on high priority issues within their watersheds. Modifications to the MCMs must be appropriately justified and still be consistent with 40 CFR § 122.26(d)(2)(iv)(A)-(D).
A control measure may only be eliminated based on the justification that it is not applicable to a particular permittee. Customized measures, once approved as part of the EWMP, will replace in part or in whole the prescribed MCMs in the Permit. The Planning & Land Development Program is not eligible for customization in that it may be no less stringent than the baseline requirements in the Permit. However, it can be enhanced over the baseline permit requirements if desired.
MCMs in each of the six identified categories are being implemented by the Beach Cities WMG as prescribed under the Permit, and in some cases, MCM program enhancements have been implemented to address watershed priorities for TMDL implementation. A summary of MCM enhancements is provided in Table C-1. Additional modifications may also be made through the Adaptive Management Process.
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GENERAL FRAMEWORK FOR MCM CUSTOMIZATION
An approach for evaluating existing institutional MCMs was developed as part of the Beach Cities original EWMP Work Plan and was used to evaluate existing MCMs and develop the customized MCMs. The following steps provide a general framework for MCM customization:
1. Identify MCMs for potential customization. This may include identifying:
a. MCM requirements prescribed by the Permit which are not already being implemented by the permittee;
b. Currently implemented MCMs which have been enhanced over the previous Permit as part of TMDL implementation, e.g., Enhanced Restaurant Inspection Program; c. Programmatic solutions/non-structural controls identified in TMDL implementation plans which may not yet have been implemented; and
d. MCMs which are currently being implemented but which may be excessive in scope. For example, commercial inspections being conducted of retail gasoline facilities which are already heavily regulated through other environmental programs in areas that have no receiving water impairments for the pollutants of concern may be carried out less frequently, or discontinued indefinitely.
2. Identify MCMs which are not applicable. A control measure may be eliminated based on the justification that it is not applicable to a particular permittee. For example, if it is the policy of a permittee not to use pesticides in public agency activities, then there is no need for tracking of pesticide use and this MCM may be proposed for elimination.
3. Assess the effectiveness of the incremental baseline MCM requirements with respect to water quality priorities. The data necessary to quantify this will vary greatly by MCM, but may include information such as: receiving water quality, inspection and reporting records, number of qualifying projects (e.g., number of construction projects greater than 1 acre), number of pet station bags used, amount of material picked up by street sweeping activities, number of employees trained, and maintenance records. Additionally, the California Stormwater Quality Association (CASQA) provides a tool to estimate the effectiveness of stormwater management programs (CASQA, 2015). The tool recommends possible assessment metrics that can be used for various stormwater programs.
4. Quantify the additional resources required to implement the incremental baseline MCMs.
This may include estimating additional staff resources in terms of full-time employees, consulting resources, and contracted services.
5. Assess the effectiveness and resources required to implement the customized MCM. The process to quantify these will be the same as the process used to quantify the baseline effectiveness of the existing MCM.
6. Compare the assessed effectiveness and resources required to implement the incremental baseline MCMs and the customized MCMs. Customization can be justified in several ways:
a. If the customized MCM effectiveness is equal to or greater than the baseline MCM, customization can be justified.
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b. If an MCM requirement is not applicable, then elimination is justified. c. If the incremental MCM requires additional resources that are disproportionate to the increased effectiveness achieved, then retention of the existing MCM may be justified.
7. Document the customized MCM justification.
MCMs were evaluated based on their effectiveness in addressing the WBPCs specific to the Beach Cities EWMP Area and based on the Beach Cities WMGs knowledge and experience with existing MCMs. In many ways, the WMG’s practical experience with MCM implementation over time provides the best insight as to what MCM modifications/enhancements will be most helpful to target the WBPCs of concern in the Beach Cities EWMP Area.
Table C-1 summarizes the proposed MCM enhancements common to the Beach Cities WMG, which include promotion of existing regional programs as part of the residential outreach permit requirement; development and distribution of digital and print outreach materials targeted at pollutants of concern in the Beach Cites watersheds; establishment of South Bay Environmentally Friendly Gardening, Landscaping, and Pest Management webpages; and annual restaurant inspections as commercial pollutant sources. For the MCMs applicable to the LACFCD (namely the PIPP, the IC/ID, and the PAA), the LACFCD will continue to implement the requirements both individually and in collaboration with the WMG as identified in the MS4 Permit.
In addition to the MCM modifications being implemented by the WMG as a group, the Beach Cities WMG has identified additional city-specific MCM enhancements, which include organization and promotion of educational and cleanup-oriented events, maintenance of pet waste collection stations as a part of the residential outreach requirement, bans on plastic bags and polystyrene food containers in Manhattan Beach and Hermosa Beach, and maintenance of environmentally-oriented city websites. City-specific MCMs enhanced beyond Permit requirements are specified in Table C-1.
The MCM enhancements shown in this table are examples and are not comprehensive.
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Table C-1. Enhancements to MCMs
MS4 Permit MCM Requirements
General Beach Cities MCM
Enhancement (all agencies)
City-Specific MCM Enhancement
City of
Manhattan Beach
City of
Redondo Beach
City of
Hermosa Beach City of Torrance
Public Information and Participation Program
(PIPP)1
Residential Outreach (individually or with group): Ongoing development and dissemination of targeted
outreach promoting behavior
change in activities among
the DIY residential
community that is a source of
priority pollutants.
Leveraging of successful
existing statewide and
regional outreach programs
using print and digital
distribution methods.
Manhattan Beach is implementing the
“Plastic Free MB” campaign to reduce
plastic use and waste. The City Council
has passed several comprehensive
ordinances targeted at plastic
reduction: plastic bag ban, ban on
polystyrene, prohibition on single-use
plastic straws and utensils, and ban on
polystyrene meat trays and mylar
balloons.
The Hermosa Beach City Council has
adopted ordinances to ban certain
polystyrene and single-use plastic
products in Hermosa Beach as well as
plastic bags.
Dissemination of Public education materials on
proper management, recycling and/or disposal of
vehicle fluids, household hazardous waste,
construction waste, green waste, animal waste,
pesticides, fertilizers, and integrated pest
management (IPM).
Each of the Beach Cities
leverages its solid waste
franchise contract to conduct
outreach on proper waste
management in the form of
solid waste bill inserts or
direct mailers.
Household hazardous waste collection
is offered to single and multi-family
residences. Free pharmaceutical drop
off and battery recycling collection
containers are located at city facilities.
Project Pollution Prevention brochures
are provided to residents and
contractors via the City's website.
The City promotes and hosts annual
household hazardous waste roundup
events.
Project Pollution Prevention brochures
are available at the public counter. The
City promotes and hosts annual
household hazardous waste roundup
events.
BMP brochures are made available at
City outreach and environmental
events and public counters.
Dissemination of public education information
targeted at residential do-it-yourself auto
activities
Participation in the
CalRecycle Used Oil Program.
Development and distribution
of a Mobile Business Tip Card
targeting mobile auto
detailers.
Dissemination of public education information
targeted at residential do-it-yourself home
improvement and maintenance activities
Distribution of a Small Site
(<1 acre) Construction
brochure with information
regarding material storage
and handling as well as spill
prevention and clean-up and
disposal. Distribution of LA
County Residential Pool and
Spa Maintenance BMPs for
the Environment flyer.
Promotion of West Basin
Municipal Water District
(WBMWD) programs via
SBESC e-blasts and City
websites.
1 The Permittees will adapt the PIPP over time to address new information, water quality priorities and stormwater management program priorities – activities listed below provide examples of how the PIPP is currently being enhanced.
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MS4 Permit MCM Requirements
General Beach Cities MCM
Enhancement (all agencies)
City-Specific MCM Enhancement
City of
Manhattan Beach
City of
Redondo Beach
City of
Hermosa Beach City of Torrance
Dissemination of public education information
targeted at residential do-it-yourself landscaping
and gardening activities and integrated pest
management.
Development and
maintenance of
Environmentally Friendly
Landscaping, Gardening and
Pest Control Webpages
hosted by the South Bay
Environmental Services
Center. Development,
distribution and promotion of
South Bay Homeowner’s
Guide to Rainwater
Harvesting. Promotion of
sustainable landscaping,
gardening and water
efficiency events and
programming hosted by West
Basin Municipal Water
District.
The City provides resources on OceanFriendly Gardens and Sustainable Landscapes on its website, and
continues to promote Sustainable
Landscaping principles in its Green
Code planning requirements for new
projects or significant remodels. The
City maintains a number of California
Friendly demonstration gardens.
The City maintains a number of
California Friendly demonstration
gardens. The City created a “tip card”
for residential notifications of
excessive over irrigation into the
streets that provides tips to control and
reduce the overspray and ponding in
the gutters.
The City maintains a number of
California Friendly demonstration
gardens.
The City maintains a number of
California Friendly demonstration
gardens and hosts rain barrel
distribution events.
Distribute public education information targeted
at residential pet owners
The City maintains pet waste collection
stations in locations with high
frequency of use by residents with
dogs. The stations are equipped with
disposable bags for collecting and
disposing of pet waste.
All City parks and the Esplanade are
equipped with pet waste collection
stations.
All City parks, The Strand and the
linear greenbelt are equipped with pet
waste collection stations. The City also
conducts targeted outreach to pet
owners to pick up after their pets and
follow the City’s pet owner ordinances.
City Parks are equipped with pet waste
collections stations. Dog waste BMP
brochures are made available at City
outreach and environmental events
and public counters. Residents can also
pick up a free pet waste dispenser with
biodegradable bags at the One-Stop
Permit Center.
Maintain stormwater website Development and
maintenance of
Environmentally Friendly
Landscaping, Gardening and
Pest Control Webpages
hosted by the South Bay
Environmental Services
Center.
The City maintains integrated
Environmental Sustainability
webpages which links to the Public
Works Environmental Programs page
that has information on several Public
Works environmental programs such
as the Solid Waste and Recycling
Program, Hazardous Waste Disposal
Program, Water Conservation Program,
and Stormwater Pollution Prevention
Program.
The City maintains water quality
information on its website.
The City has an Environmental
Programs webpage, and a Water
Conservation webpage which links to
the South Bay Environmentally
Friendly Landscaping, Gardening and
Pest Control Webpages..
The City has an NPDES/Stormwater
webpage.
The Public Works website provides
updates, information and links
regarding environmental programs,
household hazardous waste, water
conservation efforts, and sustainable
landscaping and gardening. Torrance
also has a dedicated recycling and
waste management website.
Provide schools with materials to educate
children (K-12); can use state produced materials
The Beach Cities WMG
agencies promote the
Generation Earth Program
delivered by Tree People
through funding by Los
Angeles County Department
of Public Works.
Manhattan Beach K-12 schools
participate in the Grades of Green.
The Roundhouse Marine Studies Lab
and Aquarium located at the end of the
Manhattan Beach Pier provides
outreach to thousands of students
through hands-on pollution and ocean
awareness classes.
City of Redondo Beach staff partners
with local schools to help educate
students regarding stormwater
pollution prevention and recycling.
The schools are invited to attend
various City sponsored cleanup events.
Hermosa Beach elementary schools
participate in the Grades of Green
program.
Beach Cities EWMP | Appendix C | MCM Enhancements
C-3 | Page 2 021
MS4 Permit MCM Requirements
General Beach Cities MCM
Enhancement (all agencies)
City-Specific MCM Enhancement
City of
Manhattan Beach
City of
Redondo Beach
City of
Hermosa Beach City of Torrance
D.6 Industrial/ Commercial
Implement a Business Assistance Program for
select sectors or small businesses - technical
assistance and distribute materials to specific
sectors. Assistance is targeted to select business
sectors based on information that activities may
be contributing substantial amounts of pollutants
of concern to the MS4 and will evolve over time
based on new information and feedback from
inspectors and the monitoring program.
Examples of current targeted Business Assistance
Programs are provided at right:
The Beach Cities WMG
agencies each implement an
annual restaurant inspection
program where outreach is
provided on proper waste
management and stormwater
pollution prevention.
The Green Business Program
recognizes businesses that incorporate
sustainability into their daily business
practices with the objective of reducing
waste. The City’s franchise solid waste
hauler offers free commercial waste
audits to assess areas of improvement
for the reduction of waste. The City
also offers a Green Business
certification through the California
Green Business Network for local
businesses that meet certain criteria to
reduce impacts on the environment.
The City of Redondo Beach staff
periodically meet with various
business association districts to help
educate them on stormwater pollution
prevention and recycling topics. In
addition, City staff work with the
Redondo Beach Chamber of Commerce
on various water quality related issues
affecting businesses within the City.
The City of Hermosa Beach offers a
Green Business certification through
the California Green Business Network
for local businesses that meet certain
criteria to reduce impacts on the
environment.
Torrance distributes outreach to
businesses on environmental practices
and the City of Torrance has partnered
with the Environmental Services
Center of the South Bay Cities COG to
administer a grant from the California
Green Business Network to offer the
Green Business Certification to its
businesses.
Inspect Commercial Sources All restaurants are inspected annually instead of twice
during 5-year permit.
Commercial facilities including
nurseries and automotive facilities are
inspected every other year instead of
twice during 5-year permit.
Inspect Industrial Sources Industrial facilities are inspected every other year instead of twice during 5-
year permit.
D.7 Planning and Land Development
Update and Implement ordinance/design
standards to conform with LID and
Hydromodification requirements
Development in the Coastal Zone that
requires a Coastal Development Permit
is required to meet the LID standards.
Hermosa LID ordinance requires all
new development projects to
implement LID with no minimum size
threshold.
D.8 Development Construction Program
Sites < 1 acre; inspect based upon water quality
threat
A building/grading site is inspected on
average about 12 times and each time
the inspector is on site, the condition of
stormwater BMPs is noted by the
inspector and, if necessary, corrections
required.
Site < 1 acre; Require sites with soil disturbing
activities to implement minimum BMPs
Distribution of Small Site
Construction brochure in
English and Spanish for sites
disturbing less than 1-acre
that includes an example site
schematic and information on
each of the required
minimum BMPs.
Beach Cities EWMP | Appendix C | MCM Enhancements
C-4 | Page 2 021
MS4 Permit MCM Requirements
General Beach Cities MCM
Enhancement (all agencies)
City-Specific MCM Enhancement
City of
Manhattan Beach
City of
Redondo Beach
City of
Hermosa Beach City of Torrance
D.9 Public Agency Activities
Prevent vehicle/equipment washing discharges to
the MS4, including firefighting and emergency
response vehicles
City Yard includes designated area for
washing vehicles equipped with
clarifier and diversion. Additionally,
the City Yard bulk storage area
includes roof canopies and a dry
weather diversion system.
The City Yard is retrofitted with a dry
weather diversion to the sanitary
sewer.
Implement IPM program The City has eliminated the use of non-organic pesticide products in
parks and open spaces and City
maintenance crews and contractors
utilize a combination of organic pest
control strategies and products to
control invasive weeds, insects and
rodents throughout city facilities.
The City has eliminated the use of nonorganic herbicide products in post emergent applications at all parks.
Hermosa Beach has designated all City
parks pesticide-free zones, and thus
uses no pesticides in maintaining these
public recreational areas, which
include the greenbelt that runs the
length of the City.
Torrance’s pesticide free zones include
around both community gardens, in
most playgrounds, and around all
picnic areas except for at Columbia and
Wilson Park.
Required trash management at public events The City implements a tiered matrix of requirements for special events in the
City to reduce waste and control litter.
Place and maintain trash receptacles/capture
devices at newly identified high trash generating
areas
The City maintains more than 125
additional receptacles for recyclable
glass, plastic and aluminum beverage
containers.
The City has placed trash receptacles in
high use area throughout the City,
including all bus stops, parks and
coastal areas.
The City has placed over 100 recycling
bins for beverage containers
throughout the City, at all bus stops, in
heavily used pedestrian areas and
parks.
Street sweeping - Priority A: 2x/mo.; B: 1x/mo.; C:
as needed, not less than 1x/yr.
Streets are swept weekly and posted
with no parking signs on street
sweeping days.
Streets are swept weekly and posted
with no parking signs on street
sweeping days.
Streets are swept weekly and posted
with no parking signs on street
sweeping days.
Streets are swept weekly and posted
with no parking signs on street
sweeping days.
Inspect and/or clean Permittee owned parking
lots 2x/mo.
City parking lots are swept weekly.
D.10 Illicit Connections and Illicit Discharges
Elimination
Continue IC/ID program Implementation of the model
California Water Efficient
Landscape Ordinance or
equivalent city-specific
ordinance for new
landscapes.
The City has a water conservation
ordinance as well as CalGreen Code
provisions for landscaping and
irrigation.
The City has Landscape Regulations
included in the Municipal Code,
including water conservation.
The City has a Water Conservation and
Drought Management Plan Ordinance.
The City has a Water Conservation and
Drought Management Program, under
which City staff proactively identify
irrigation overuse.
Facilitate public reporting via hotline The City’s “Go Hermosa!” app allows residents to report illicit discharges
directly to the City via the app.
Appendix D
RAA Report
Reasonable Assurance Analysis Report
Updated Beach Cities EWMP 2021
Prepared for
Beach Cities Watershed Management Group
(Cities of Hermosa Beach, Manhattan Beach, Redondo Beach, and Torrance and the Los Angeles County Flood Control District)
Prepared by
Geosyntec Consultants, Inc.
6167 Bristol Parkway Ste 390
Culver City, CA. 90230
Project Number CWR0645
May 2021
App D. Beach Cities EWMP RAA Report i May 2021
TABLE OF CONTENTS
1. Introduction........................................................................................................... 1
2. Water Body Pollutant Combinations.................................................................... 2
3. Model Selection and Overview ............................................................................ 6
3.1. WMMS 2.0 LSPC........................................................................................ 6
3.1.1. Updating Weather Data .................................................................. 9
3.1.2. Adding Fecal Indicator Bacteria as a Modeled Constituent........... 9
3.1.3. Use of Surrogate Pollutants.......................................................... 10
3.1.4. Model Calibration and Validation................................................ 10
3.1.5. Revising LSPC Sub-Basin Boundaries ........................................ 10
3.2. WMMS 2.0 SUSTAIN .............................................................................. 10
4. RAA Approach ................................................................................................... 12
4.1. Wet Weather RAA Approach.................................................................... 13
4.2. Dry Weather RAA Approach .................................................................... 14
5. Model Calibration and Validation ...................................................................... 16
5.1. Hydrologic Calibration.............................................................................. 17
5.2. Water Quality Calibration ......................................................................... 23
6. Critical Condition Definition.............................................................................. 27
6.1. Santa Monica Bay WMA .......................................................................... 27
6.1.1. Bacteria (Fecal Coliform)............................................................. 27
6.2. Dominguez Channel WMA....................................................................... 27
6.2.1. Indicator Bacteria (E. coli)........................................................... 27
6.2.2. Metals and Organic Pollutants ..................................................... 27
7. Target Load Reductions...................................................................................... 29
7.1. Santa Monica Bay WMA .......................................................................... 29
7.1.1. Bacteria (Fecal Coliform)............................................................. 29
7.1.2. Pesticides and PCBs..................................................................... 31
7.1.3. Mercury and Arsenic .................................................................... 31
7.1.4. Trash and Marine Debris.............................................................. 31
7.1.5. Final Wet Weather TLR Summary for Santa Monica Bay .......... 31
7.2. Dominguez Channel WMA....................................................................... 32
TABLE OF CONTENTS (Continued)
App D. Beach Cities EWMP RAA Report ii May 2021
7.2.1. Metals........................................................................................... 32
7.2.2. Pesticides, Organics, and PCBs.................................................... 34
7.2.3. Indicator Bacteria (E. coli)........................................................... 35
7.2.4. Toxicity ........................................................................................ 35
7.2.5. Final Wet Weather TLR Summary .............................................. 36
8. Stormwater Control Overview............................................................................ 38
8.1. Methods to Select and Prioritize BMPs..................................................... 38
8.2. Quantified Non-Structural BMPs.............................................................. 38
8.2.1. Copper Brake Pad Reduction ....................................................... 39
8.3. Modeling Structural BMPs........................................................................ 39
8.3.1. Regional and Distributed Structural Projects............................... 41
8.3.2. Low Impact Development Applied to Redevelopment................ 44
9. Wet Weather RAA Results................................................................................. 46
9.1. Santa Monica Bay WMA .......................................................................... 46
9.2. Dominguez Channel WMA....................................................................... 50
10. Dry Weather RAA Result................................................................................... 55
10.1. Santa Monica Bay WMA .......................................................................... 55
10.2. Dominguez Channel WMA....................................................................... 55
11. Conclusions......................................................................................................... 57
12. References........................................................................................................... 58
TABLE OF CONTENTS (Continued)
App D. Beach Cities EWMP RAA Report iii May 2021
LIST OF TABLES
Table 1. Updated Waterbody Pollutant Combinations – Santa Monica Bay ................... 3 Table 2. Updated Waterbody Pollutant Combinations – Dominguez Channel WMA..... 4 Table 3. Default BMPs Modeled in SUSTAIN.............................................................. 11 Table 4. Calibration Metrics........................................................................................... 17 Table 5. Summary of Calibrated Hydrology Modeling Parameters............................... 18 Table 6. Model Performance Summary - Hydrology ..................................................... 19 Table 7. Summary of Calibrated FIB Modeling Parameters.......................................... 24 Table 8. Summary of Calibrated Sediment Loading Parameters ................................... 24 Table 9. Summary of Calibrated Pollutant Loading Parameters.................................... 25 Table 10. Water Quality Model Calibration Summary .................................................. 25 Table 11. Dominguez Channel WMA 90th Percentile Daily Load Summary ............... 28 Table 12. Santa Monica Bay WMA Wet Weather TLR................................................. 32 Table 13. Dominguez Channel WMA Wet Weather TLRs............................................ 37 Table 14. Summary of Full 85th-Percentile, 24-Hr Design Storm Capture Project....... 40 Table 15. Summary of Modeled Projects....................................................................... 43 Table 16. Redevelopment LID BMP Modeling Parameters........................................... 45 Table 17. Beach Cities SMB WMA RAA Summary ..................................................... 47 Table 18. Beach Cities DC WMA RAA Summary ........................................................ 51 Table 19. Dry Weather RAA Summary for Dominguez Channel WMA....................... 55
LIST OF FIGURES
Figure 1. HRU Overview.................................................................................................. 7 Figure 2. Hydraulic Network, Drainage Delineation, and Weather Station Overview .... 8 Figure 3. Analysis Region Overview.............................................................................. 12 Figure 4. Dry Weather RAA Process ............................................................................. 15 Figure 5. Locations of Monitoring Stations Utilized for Calibration and Validation .... 16 Figure 6. Flow Comparison at OF-BCEG-03................................................................. 20 Figure 7. Flow Comparison at OF-BCEG-05................................................................. 21 Figure 8. Flow Comparison at OF-BCEG-07................................................................. 22 Figure 9. Example Concentration Comparison Plot (Total Zinc)................................... 26 Figure 10. Overview of 85th-Percentile, 24-Hour Storm Capture Projects ................... 41 Figure 11. Modeled Regional and Distributed Projects.................................................. 42 Figure 12. 24-Hour Management Volume Breakdown in Santa Monica Bay WMA .... 48 Figure 13. 24-Hour Management Mapping in Santa Monica Bay WMA. ..................... 49 Figure 14. 24-Hour Management Volume Breakdown in Dominguez Channel WMA. 53 Figure 15. 24-Hour Management Volume Mapping in Dominguez Channel WMA..... 54
TABLE OF CONTENTS (Continued)
App D. Beach Cities EWMP RAA Report iv May 2021
LIST OF ATTACHMENTS
Attachment D.1 Supplementary Calibration Exhibits
App D. Beach Cities EWMP RAA Report 1 May 2021
1. INTRODUCTION
As specified in the 2012 Los Angeles Municipal Separate Storm Sewer System (MS4) National Pollutant Discharge Elimination System (NPDES) Permit1 (Permit), the Cities of Hermosa Beach, Manhattan Beach, Redondo Beach, and Torrance, together with the County of Los Angeles and the Los Angeles County Flood Control District (LACFCD), collectively referred to as the Beach Cities Watershed Management Group (WMG), developed an Enhanced Watershed Management Program (EWMP) for their drainage areas within the Santa Monica Bay and Dominguez Channel watersheds. As a part of demonstrating progress and adaptive management, the Beach Cities WMG is required to submit a updated EWMP to the Los Angeles Regional Water Quality Control Board (LARWQCB), including an updated Reasonable Assurance Analysis (RAA), by June 30, 2021.
This report has been prepared to summarize the approach and results of the updated RAA.
Building upon the original and revised plans in 2015 and 2018, the updated RAA has been conducted to conform to the original RAA guidelines developed by the LARWQCB (LARWQCB, 2014a). The updated RAA also provides updates to include recent monitoring data, project planning and implementation, and modeling advances over the past five years. Where appropriate, it also addresses issues and comments raised by the State Water Resources Control Board (SWRCB, 2020), such as inclusion of relevant data for model calibration, non-structural Best Management Practices (BMP) credit, and application of the limiting pollutant approach.
The updated wet weather RAA was conducted using the Watershed Management Modeling System 2.0 (WMMS 2.0), the latest modeling tool developed by LACFCD, to determine a cost-effective implementation strategy to meet applicable water quality standards (i.e., TMDL waste load allocations [WLA] and Basin Plan Objectives) and targets. This modeling platform was approved and endorsed by the LARWQCB as an acceptable model for performing the RAA. WMMS 2.0 has the capability of representing wet and dry weather flow discharges, although based on a variety of factors, dry weather flows were not modeled using WMMS 2.0 as part of this effort. For dry weather, a revised semi-quantitative approach was implemented to update the dry weather portion of the original RAA.
The RAA was completed for the full geographic domain of the Beach Cities EWMP area, as described in the updated Beach Cities EWMP. Unless otherwise noted, all Water Body 1 Order No. R4-2012-0175 NPDES Permit No. CAS004001 Waste Discharge Requirements for Municipal Separate Storm Sewer System (MS4) Discharges within the Coastal Watersheds of Los Angeles County, except those Discharges Originating from the City of Long Beach MS4.
App D. Beach Cities EWMP RAA Report 2 May 2021
Pollutant Combinations (WBPCs) identified in the EWMP have been addressed as part of this updated RAA.
2. WATER BODY POLLUTANT COMBINATIONS
The WBPCs defined in the original Beach Cities EWMP were revised based on the most recent updates to applicable TMDLs and 303(d) listings, as well as available Coordinated Integrated Monitoring Program (CIMP) monitoring data. 2 The updated WBPC list is summarized in Table 1 and Table 2 for the Santa Monica Bay watershed management area (WMA) and Dominguez Channel WMA, respectively. These tables include the applicable water quality-based effluent limitations (WQBELs) and the receiving water limitations (RWLs).
As with the original Beach Cities EWMP, the RAA was performed to address all Category 1 WBPC interim and final MS4 waste load allocations (WLAs), and all Category 2 and 3 WBPCs where the Beach Cities WMG may have caused or contributed to historical exceedances. For Category 2 and 3 pollutants that do not have a TMDL WLA, various water quality objectives extracted from California Toxic Rule, LARWQCB Basin Plan Objective and California Ocean Plan Objective were selected and utilized for analysis purposes.
The WQBELs and RWLs for Dominguez Channel Estuary are included in Table 2 because the City of Torrance portion of the Beach Cities EWMP WMA drains to Dominguez Channel Estuary via Torrance Lateral. This conveyance connectivity makes the City of Torrance a responsible permittee with discharges to the Dominguez Channel Estuary as indicated in the MS4 Permit Attachment K.
It should be noted that the table does not imply that compliance can only be achieved and demonstrated via strict attainment of the listed TMDL WLAs. Other compliance pathways (e.g., full retention of the 85th percentile 24-hour design storm capture) also are viable options.
2 “Available data” includes all data collected through June 30, 2020 by the Beach Cities WMG. As this date marks the end of the 2019-2020 reporting year, it is the most recent complete year of CIMP monitoring that includes data that has been analyzed, verified, and reported according to the Beach Cities standard for quality assurance and quality control (QA/QC). Monitoring data collected after this time has not yet been QA/QC’d in accordance with this protocol, and so has not been used in the updated RAA and EWMP.
App D. Beach Cities EWMP RAA Report 3 May 2021
Table 1. Updated Waterbody Pollutant Combinations – Santa Monica Bay Category Water Body Pollutant –
Applicable Condition
Reason for
Categorization Interim TMDL WLA Final TMDL WLA or Other Water Quality Objective 1: Highest
Priority Santa Monica
Bay (including
SMB Beaches)
Bacteria – Wet and
Dry Weather
SMB Beaches
Bacteria TMDL
50% cumulative
percentage reduction
from total required
exceedance day
reduction[2]
Summer-Dry: Single Sample Allowable
Exceedance Days (AEDs)
Winter-Dry: Single Sample AEDs
Wet - Single Sample AEDs[1] and
Geometric Mean targets
Trash/Debris – Wet
and Dry Weather
SMB Debris
TMDL
Incremental reduction
from baseline waste
load allocation[3]
(6815.6 gals/year)
100% reduction from baseline waste
load allocation[3] (6815.6 gals/year)
DDTs – Wet and Dry
Weather SMB PCBs and
DDT TMDL
n/a 0.88 g/yr[4]
PCBs – Wet and Dry
Weather
n/a 4.56 g/yr[4]
2: High
Priority
Mercury– Wet and Dry
Weather 303(d) list
n/a 0.4 ug/L[5]
Arsenic– Wet and Dry
Weather
n/a 80 ug/L[5]
3: Medium
Priority Analysis of monitoring data from outfalls and receiving waters do not currently result in the identification of any Category 3 WBPCs [1] Basin Plan Objective REC1 Water Bodies Limit for Bacteria. Please refer to Beach Cities EWMP Appendix B for allowable exceedance day limits for each subwatershed.
[2] Total required exceedance day reduction is defined as the difference between historical exceedance day and the allowable exceedance day for each subwatershed.
[3] Baseline WLA is the sum of baseline WLA from Manhattan Beach, Redondo Beach, Hermosa Beach, and Torrance. [4] This mass-based WLA presented in the TMDL is applicable for all Los Angeles County MS4 permittees draining to Santa Monica Bay. WLA applicable to Beach Cities WMG is apportioned based on Beach Cities WMG’s tributary area to Santa Monica Bay. [5] California Ocean Plan Water Quality Objective (instantaneous maximum).
App D. Beach Cities EWMP RAA Report 4 May 2021
Table 2. Updated Waterbody Pollutant Combinations – Dominguez Channel WMA Category Water Body Pollutant Reason for
Categorization
WLA/Standard/Target
Basis Interim TMDL WLA Final TMDL WLA or Other Target
1: Highest
Priority
Dominguez
Channel
Freshwater]
Toxicity
Dominguez
Channel and
Greater Los
Angeles and
Long Beach
Harbor Toxics
TMDL
Monthly Average 2 TUc 1 TUc
Total Copper Wet Weather Single Event 207.51 ug/L 9.7 ug/L 205.5 g/day[3]
Total Lead Wet Weather Single Event 122.88 ug/L 42.7 ug/L 906.3 g/day[3]
Total Zinc Wet Weather Single Event 898.87 ug/L 69.7 ug/L 1,478.6 g/day[3]
Dominguez
Channel Estuary
Total Copper
Wet Weather Single Event[1] 220 mg/kg sediment
3.73 ug/L
31.6 mg/kg sediment
Annual Average[2] n/a 2.1 kg/yr[4]
Total Lead
Wet Weather Single Event[1] 510.0 mg/kg sediment 8.52 ug/L
35.8 mg/kg sediment
Annual Average[2] n/a 5.1 kg/yr [4]
Total Zinc
Wet Weather Single Event[1] 789.0 mg/kg sediment 85.6 ug/L 121 mg/kg sediment
Annual Average[2] n/a 25.5 kg/yr[4]
Total Cadmium
Wet Weather Single Event[1] n/a 1.2 mg/kg sediment
Annual Average[2] n/a
Total DDTs
Wet Weather Single Event[1] 1.727 mg/kg sediment 0.00059 ug/L Annual Average[2] n/a 0.02 g/yr[4]
Total PAHs Wet Weather Single Event[1] 31.60 mg/kg sediment 0.049 ug/L Total PAHs Annual Average[2] n/a 0.013 kg/yr[4]
App D. Beach Cities EWMP RAA Report 5 May 2021
Category Water Body Pollutant Reason for
Categorization
WLA/Standard/Target
Basis Interim TMDL WLA Final TMDL WLA or Other Target
Total PCBs
Wet Weather Single Event[1] 1.490 mg/kg sediment 0.00017 ug/L Annual[2] n/a 0.019 g/yr [4]
Torrance Lateral
Total Copper Wet Weather Single Event 207.51 ug/L 9.7 ug/L
31.6 mg/kg sediment
Total Lead Wet Weather Single Event 122.88 ug/L 42.7 ug/L
35.8 mg/kg sediment
Total Zinc Wet Weather Single Event 898.87 ug/L 69.7 ug/L 121 mg/kg sediment
2: High
Priority
Dominguez
Channel
(including
Freshwater,
Estuary, and
Torrance Lateral)
Indicator
Bacteria 303(d) List Basin Plan Objective n/a See Footnote 5 3:
Medium
Priority
Dominguez
Channel
Freshwater
Benzo(a)pyrene
CIMP
monitoring data
showing WQO
exceedance in
receiving water
and MS4 outfall
California Toxics Rule
(CTR) Human Health
Standard
n/a 0.049 ug/L[6]
[1] Basis for water column- or sediment-based concentration receiving water limit. [2]Basis for mass-based WLA. [3] Daily MS4 WLA apportioned to Beach Cities WMG draining to the Dominguez Channel Freshwater area. [4] Annual MS4 WLA apportioned to Beach Cities WMG draining to the Dominguez Channel Estuary area. [5] Per the LARWQCB Basin Plan Objective REC1 Water Bodies Limit for Indicator Bacteria, the statistical threshold value of E. coli (320/100 mL) is not to be exceeded by more than 10 percent of the samples collected in a calendar month. [6] The CTR Human Health criteria (for consumption of organisms only) is not applicable at outfalls but was utilized as an evaluative metric in this case.
App D. Beach Cities EWMP RAA Report 6 May 2021
3. MODEL SELECTION AND OVERVIEW
While the original RAA leveraged the strengths of the Structural BMP Prioritization and Analysis Tool (SBPAT) to perform the wet weather modeling analysis, the updated RAA uses the newly-released WMMS 2.0 modeling platform to maintain consistency with the majority of RAAs across Los Angeles County. Developed by LACFCD and publicly released in May 2020, WMMS 2.0 utilizes remote sensing, water quality, and hydrology data collected through 2018 to simulate contaminant loading, runoff volume, and flow rate. WMMS 2.0 contains two major components: a Loading Simulation Program in C++ (LSPC) to determine hydrology and pollutant loading, and a System for Urban Stormwater Treatment and Analysis Integration (SUSTAIN) to assist in BMP selection and performance. Detailed descriptions of each model component are provided below.
An advantage of using the WMMS 2.0 model is the extensive regional calibration effort that has gone into the recent update of the model.
3.1. WMMS 2.0 LSPC
WMMS 2.0 LSPC (version 6.0) is capable of simulating watershed hydrology, sediment erosion and transport, and water quality processes from both upland contributing areas and receiving streams. Long-term, hourly rainfall data and average monthly evapotranspiration values are used along with land use-linked catchment imperviousness, soil properties, and land use-specific pollutant buildup/wash off rates to estimate wet weather runoff volumes and pollutant loading. LSPC utilizes the following spatial and temporal data to conduct the simulation:
• Hydrologic response unit (HRU), which is a combination of:
o Soils
o Land cover
o Groundwater recharge potential
o Topography
o Land use
• Hydraulic network (dams, debris basins, spreading grounds, water reclamation plants, storm drains, open channels)
• Subwatershed/subbasin
• Hourly and spatially interpolated precipitation and evapotranspiration data.
Figure 1 illustrates the HRU of the Beach Cities EWMP area, Figure 2 illustrates the hydraulic network, and subwatershed boundary and the weather station coverage for the Beach Cities EWMP area.
App D. Beach Cities EWMP RAA Report 7 May 2021
Figure 1. HRU Overview
App D. Beach Cities EWMP RAA Report 8 May 2021
Figure 2. Hydraulic Network, Drainage Delineation, and Weather Station Overview
App D. Beach Cities EWMP RAA Report 9 May 2021
The default3 WMMS 2.0 LSPC model has been configured, calibrated, and validated through a regional approach against flow and water quality monitoring data collected at all Mass Emission Stations (MES) in Los Angeles County. The following pollutants are included in the downloaded version of the WMMS 2.0 platform:
• Total Nitrogen
• Total Phosphorus
• Total Zinc
• Total Lead
• Total Copper
• Total Cadmium, and
• Total Suspended Solids (TSS)
The application of this model provides an estimate of the target load reduction (TLR), a numerical expression of the Permit compliance metrics that serves as a basis for confirming, with reasonable assurance, that implementation of the proposed BMPs will result in attainment of the applicable TMDL WLA-based WQBELs in the Permit for Category 1 pollutants, or the Water Quality Objectives for Category 2 and Category 3 pollutants.
The subsections below summarize the modifications to the default WMMS 2.0 LSPC model that were used to conduct the updated RAA.
3.1.1. Updating Weather Data
The default WMMS 2.0 LSPC model database includes precipitation data up to September 2018. Hourly rainfall data between September 2018 and June 2020 from Los Angeles County operated Automatic Local Evaluation in Real Time (ALERT) rain gauges were requested and amended to the model database in accordance with the default WMMS 2.0 rain gauge coverage assignment.
3.1.2. Adding Fecal Indicator Bacteria as a Modeled Constituent In the original Beach Cities EWMP RAA, fecal indicator bacteria (FIB) compliance demonstration (where the TMDL permit limits are expressed in exceedance days) was performed via using load reductions as the modeled surrogate compliance metric. To maintain consistency with the LARWQCB Basin Plan, fecal coliform4 was used as the 3 The term “default” refers to the “as-downloaded” model released in May 2020. 4 While the LARWQCB Basin Plan established water quality objectives of total coliform, fecal coliform and enterococcus for marine water, historic monitoring data for a representative beach that demonstrated fecal coliform loads (discharged from the watershed outlets) were significantly correlated with total observed wet weather exceedance days for all FIBs for marine water. Hence, fecal coliform was selected as the representative FIB for marine water.
App D. Beach Cities EWMP RAA Report 10 May 2021
representative FIB for marine waters, and E. coli was used as the FIB for freshwaters.
Because none of the default constituents in WMMS 2.0 LSPC model can be used as surrogate pollutants for FIB, a representative FIB had to be added to the model. For the Santa Monica Bay LSPC model, fecal coliform was used, with model input parameters calibrated using fecal coliform monitoring data collected at Santa Monica Bay Beaches Bacteria (SMBBB) TMDL Compliance Monitoring Locations (CMLs) within the Beach Cities EWMP area. For the Beach Cities Dominguez Channel LSPC model, E. coli was used, with model input parameters calibrated using E. coli monitoring data collected at outfall monitoring locations draining to Dominguez Channel.
3.1.3. Use of Surrogate Pollutants
Pollutant load rate and concentration for WBPCs involving the seven default WMMS 2.0 LSPC model pollutants and the added FIB were obtained from the WMMS 2.0 LSPC output files directly. A subset of the directly modeled pollutants was used as surrogate pollutants to establish pollutant loading and concentration of pollutants not directly modeled in the WMMS 2.0 LSPC model. Details on surrogate pollutant selection and assignment in the Santa Monic Bay and Dominguez Channel watersheds are presented in Section 6.1 and 6.2, respectively.
3.1.4. Model Calibration and Validation
The default WMMS 2.0 LSPC model is calibrated on a regional basis using data through September 2018. This model was further calibrated and validated using Beach Cities CIMP monitoring data collected up to June 30, 2020 to best reflect the baseline hydrology and water quality conditions within the Beach Cities EWMP area. This date was selected as it marks the most-recently complete CIMP annual reporting year, and therefore is inclusive of the latest available data that have been properly QC’d by the Beach Cities WMG. Detailed information on the model calibration can be found in Section 4.
3.1.5. Revising LSPC Sub-Basin Boundaries
Since the default LSPC subwatershed boundaries were developed at a regional scale and covers the entire Los Angeles Basin, they were found to contain some minor inaccuracies at the finer spatial resolution used for the RAA. As part of the updated RAA process, the subwatershed boundaries were refined to more accurately reflect the drainage boundaries of the Beach Cities EWMP WMA.
3.2. WMMS 2.0 SUSTAIN
Utilizing hourly hydrograph and pollutograph outputs from LSPC, SUSTAIN (version
2.1) provides estimates of water balance such as volumes: evapotranspired, diverted, captured, treated, and/or released by various BMPs, as well as a conceptually optimal
App D. Beach Cities EWMP RAA Report 11 May 2021
spatial distribution based on cost effectiveness to achieve TLR goals. WMMS 2.0 SUSTAIN also includes a batch-processing framework to inform selection, configuration, and placement of BMPs throughout a watershed based on defined evaluation criteria, such as cost and TLR. The default WMMS 2.0 SUSTAIN model supports estimated performance of BMPs summarized in Table 3.
Table 3. Default BMPs Modeled in SUSTAIN
BMP Type Performance Type
Distributed BMP
Bioretention/biofiltration (with
optional underdrain) Volume reduction and flow through treatment Pervious pavement Volume reduction and flow through treatment Cistern/Rain barrel Volume reduction
Drywell Volume reduction
Proprietary treatment unit Flow through treatment
Regional BMP
Infiltration gallery Volume reduction
Retention/detention basin Volume reduction and flow through treatment Constructed wetland Volume reduction and flow through treatment Sewer diversion Volume reduction
Regional treatment facility Flow through treatment
For the updated RAA, WMMS 2.0 SUSTAIN was used to estimate the performance of existing and proposed distributed and regional BMPs, thereby assuring that an effective and suitable suite of stormwater management BMPs is implemented to meet applicable interim and final TLR goals. This approach is therefore used to demonstrate a reasonable assurance of compliance for all modeled WBPCs. Details on modeled BMPs in the Beach Cities EWMPs are presented in Section 8.3.
App D. Beach Cities EWMP RAA Report 12 May 2021
4. RAA APPROACH
Consistent with the original Beach Cities EWMP RAA, the updated RAA was performed per analysis region. An analysis region is defined by one of the following conditions:
1. A subwatershed tributary to a shoreline CML (e.g. SMB-5-01)
2. A subwatershed tributary to the open beach between two CMLs (SMB-03_04)
3. A subwatershed tributary to an EWMP area outlet (e.g. DC-N-MB)
4. A subwatershed to an existing flood control basin or sump (e.g. Wylie Basin) As shown in Figure 3, there are 20 analysis regions in the Santa Monica Bay WMA and four in the Dominguez Channel WMA. Among the four Dominguez Channel WMA analysis regions, DC-N-MB, DC-N-RB and DC-S are tributary to Dominguez Freshwater. DC-TL is tributary to Dominguez Channel Estuary via Torrance Lateral. The Machado Lake Watershed is being addressed in a separate EWMP/RAA by the City of Torrance.
Figure 3. Analysis Region Overview
App D. Beach Cities EWMP RAA Report 13 May 2021
4.1. Wet Weather RAA Approach
The approach for representing wet weather flows and pollutant management for the RAA, including model determination and calibration, data inputs, critical condition selection, calibration performance criteria, and output types, have all been selected for consistency with the RAA Guidance Document (LARWQCB, 2014b), as well as functionality of WMMS 2.0. The process for the wet weather RAA included the following steps and were applied to the wet weather RAA for both Santa Monica Bay and Dominguez Channel (including Torrance Lateral) WMA.
1. Identify current WBPC list, including all quantifiable parameters requiring model simulation.
2. Revise, as needed, the contributing MS4 service areas to represent the WMA (e.g., remove lands or areas not required to be analyzed and adjust boundaries to match at a more detailed scale). This includes various full 85th percentile 24-hour storm capture basins under existing and proposed conditions (Wylie Basin, Torrance Basins Enhancement and Expansion Project, Beach Cities Green Streets Project), land owned and operated by Caltrans, and facilities operating under their own NPDES permit (e.g., the Torrance Refinery).
3. For analysis regions draining to a CML, review the Beach Cities CIMP and SMBBB TMDL monitoring data and assess if the analysis region is achieving compliance based on water quality history. For these analysis regions, no RAA is needed; compliance is already demonstrated based on monitoring data.
4. Perform hydrologic and water quality calibration on the LSPC model using Beach Cities CIMP outfall monitoring data.
5. Identify WBPC-specific critical condition.
6. Develop interim and final TLRs for identified WBPCs during the respective critical condition. Local surf zone CML fecal indicator bacteria were used to compute the TLRs.
7. Identify the following with respect to structural and non-structural BMPs:
a. Significant variations to BMPs accounted for in the original Beach Cities EWMP (e.g., differences in LID implementation levels)
b. New BMPs that have been implemented since 2014 and were not accounted for in the original EWMP
c. New BMPs that are planned for implementation and were not accounted for in the original EWMP.
8. Evaluate the pollutant load reductions of existing and proposed BMPs.
9. Compare these estimates with the final TLRs.
10. Revise the BMP implementation scenarios until all final TLRs are met, thereby reasonably assuring compliance with wet weather permit goals.
App D. Beach Cities EWMP RAA Report 14 May 2021
4.2. Dry Weather RAA Approach
Consistent with the original Beach Cities EWMP RAA, a semi-quantitative approach was implemented to perform the dry weather RAA and demonstrate reasonable assurance of meeting applicable permit goals.
Within the Santa Monica Bay WMA, for larger outfalls, low flow diversions (to the sanitary sewer) have been implemented and maintained along the coast to effectively prevent significant non-stormwater discharges to the ocean. Similarly at smaller outfalls, due in part to setbacks from the high tide line, non-stormwater discharges infiltrate in outfall scour ponds, again effectively preventing surface discharges to the ocean. The continued effectiveness of these measures and outfall conditions has been consistently confirmed through annual inspection and monitoring programs. Therefore, compliance with the permit’s receiving water limits during dry weather is achieved for the Beach Cities Santa Monica Bay WMA via the “no discharge” compliance pathway.
Additionally, for smaller outfalls, due in part to setbacks from the shoreline, nonstormwater MS4 infiltrates at the open beaches, preventing discharges from reaching the ocean. The effectiveness of these measures and outfall conditions has been consistently confirmed through monitoring. Therefore, compliance with TMDL objectives during dry weather is demonstrated for the Beach Cities Santa Monica Bay WMA via the no discharge permit compliance pathway.
Within the Beach Cities Dominguez Channel WMA, the dry weather RAA is only required for Category 2 and 3 WBPCs for the Dominguez Channel freshwater and Torrance Lateral and for Category 1 WBPC for the Dominguez Channel estuary. The approach outlined in Figure 4 was utilized to perform the dry weather RAA for the Beach Cities Dominguez Channel WMA. In subwatersheds containing proposed BMPs that address wet weather pollutants, it was assumed that dry weather flows would be completely captured and retained by these projects as well and result in no dry weather discharge from their drainage areas to the Dominguez Channel.
App D. Beach Cities EWMP RAA Report 15 May 2021
Figure 4. Dry Weather RAA Process
App D. Beach Cities EWMP RAA Report 16 May 2021
5. MODEL CALIBRATION AND VALIDATION
The default WMMS 2.0 LSPC watershed model has been configured, calibrated, and validated by LACFCD through a regional approach against flow and water quality monitoring data collected at all Los Angeles County Mass Emission Stations (MES) between water years 2008 and 2018 (LACFCD, 2020a). Geosyntec further calibrated the model using Beach Cities CIMP wet weather outfall flow and water quality data collected through June 2020. The calibrated Beach Cities LSPC model is used as the foundation for performing the wet weather RAA. Figure 5 shows CIMP monitoring locations utilized for the Beach Cities LSPC watershed model calibration and validation.
Figure 5. Locations of Monitoring Stations Utilized for Calibration and Validation
App D. Beach Cities EWMP RAA Report 17 May 2021
Calibrations were performed to meet specifications of the RAA Guidelines (LARWQCB, 2014b), which are summarized in Table 4 below. Consistent with the regional WMMS
2.0 calibration process, percent bias (PBIAS) is the primary statistic used to evaluate agreement between modeled-predicted and observed data. PBIAS quantifies systematic over- or under-prediction. Low values of PBIAS indicate better fit and predictive capability of the model. The lower bound of the “Fair” threshold is considered the minimum acceptable criteria for the model calibration process. If a “Fair” threshold is not achieved during the model validation process, additional model adjustments are made to attain the threshold at the validation site. If such effort is not successful, additional investigations will be performed to examine the modeled and monitored data at the validation site to justify the calibration effort.
Table 4. Calibration Metrics
Category
Percent Difference Between Model-Predicated and Observed Data (PBIAS) Very Good Good Fair
Hydrology /
Flow ±0 – 10% ≥ ±10% - 15% ≥ ±15% - 25%
Sediment ±0 – 20% ≥ ±20% - 30% ≥ ±30% - 40%
Water Quality ±0 – 15% ≥ ±15% - 25% ≥ ±25% - 35%
Pesticides /
Toxics ±0 – 20% ≥ ±20% - 30% ≥ ±30% - 40%
Details of the calibration and validation approach and results are presented in the following subsections.
5.1. Hydrologic Calibration
The objective of hydrologic calibration is to compare observed and model-predicted wet weather flow rates at monitoring sites and demonstrate a PBIAS of 25% or less. While continuous flow data is collected at all outfall monitoring sites, the following outfall monitoring sites were excluded from the hydrologic calibration. Reasons for exclusion are also provided:
• OF-BCEG-01 and OF-BCEG-04a: Drainage areas to these monitoring sites includes large, manually controlled flood control detention basins. Since the objective of the hydrology calibration is to determine modeling parameters that will be globally applied to the entire Beach Cities EWMP area, monitoring data collected at monitoring sites with existing regional stormwater BMPs represent controlled discharges and were therefore excluded.
• OF-BCEG-02: the monitoring site is consistently influenced by tidal impacts, such that the collected flow data do not accurately represent MS4 discharges
App D. Beach Cities EWMP RAA Report 18 May 2021
coming from the upstream drainage area. Therefore, this site was excluded from calibration.
• OF-BCEG-06: Initial comparison between measured and modeled flow rates revealed that that the measured flow rates were consistently lower than the modeled flow rates by an order of magnitude. Such discrepancy was not observed for other outfalls. The Beach Cities WMG plans to perform further investigation to assess such discrepancy as part of the CIMP. Although there is currently no reason to believe the flow data collected at this site are inaccurate, data from the outfall monitoring site were excluded from the current hydrologic calibration to avoid overly reducing runoff flow rates in the LSPC model.
After screening out data from the outfall monitoring location described above, one site in the Santa Monica Bay WMA was determined to have acceptable flow monitoring data available for hydrologic calibration. A combined hydrologic calibration effort was then conducted to utilize wet weather flow monitoring data collected at OF-BCEG-03 and OFBCEG-05 to set modeling parameter values applicable to both the Beach Cities Santa Monica Bay and Dominguez Channel LSPC models. Wet weather flow monitoring collected at OF-BCEG-07 was used to validate the calibration effort.
In maintaining consistency with the WMMS 2.0 model regional calibration process, the hydrologic calibration required the evaluation of subsurface storage, infiltration, and groundwater recession modeling parameters. The calibration was performed by iteratively applying multipliers to HRU specific modeling parameters. The resulting hydrology parameters ranges are presented in Table 5 alongside with default value ranges from the WMMS 2.0 LSPC model database and guidance.
Table 5. Summary of Calibrated Hydrology Modeling Parameters Parameter[1] Description Unit Beach Cities
Model Values
INFILT Index to Infiltration Capacity in/hr 0.23-4.0
AGWRC Base groundwater recession none 0.95-0.99
CEPSC Interception storage capacity inches 0.2-0.75
[1] For hydrologic parameters not listed in the table, the default WMMS 2.0 LSPC model values were used without modification.
Table 6 presents a summary of results for hydrology calibration. PBIAS calculations were based on comparison of modeled and observed daily flow at each outfall monitoring site.
For the PBIAS metric, modeled flows achieved “Very good” (green shaded) agreement with observed data at OF-BCEG-05 and OF-BCEG-07, and achieved “Fair”(orange
App D. Beach Cities EWMP RAA Report 19 May 2021
sahded) agreement with observation at OF-BCEG-03 according to the Regional Board RAA Guidance metric summarized in Table 4.
Table 6. Model Performance Summary - Hydrology
Calibration Metrics
Comparison Locations
Calibration Site Validation Site
OFBCEG-03OFBCEG-05OFBCEG-07
PBIAS (%) 16.9 -0.2 2.6
To further evaluate the temporal trends of the hydrology calibration, comparisons between modeled and observed monthly flows were evaluated by examining the time series plots and the average monthly flows between November 2016 and June 2020. The resultant plots were shown in Figure 6 through Figure 8.
App D. Beach Cities EWMP RAA Report 20 May 2021
Figure 6. Flow Comparison at OF-BCEG-03
App D. Beach Cities EWMP RAA Report 21 May 2021
Figure 7. Flow Comparison at OF-BCEG-05
App D. Beach Cities EWMP RAA Report 22 May 2021
Figure 8. Flow Comparison at OF-BCEG-07
App D. Beach Cities EWMP RAA Report 23 May 2021
5.2. Water Quality Calibration
The RAA Guidelines require water quality calibration based on available monitoring data from each analysis region over the most recent 10 years (LARWQCB, 2014). The default WMMS 2.0 LSPC watershed model has been regionally calibrated and validated using data collected at Los Angeles County MES and CIMP receiving water monitoring stations throughout the County between water year 2008 and 2018. Building upon the regional calibration and validation efforts, Geosyntec further calibrated the LSPC model using water quality data collected at the Beach Cities CIMP outfall monitoring locations shown in Figure 5. Modeling was peformed for the following constituents:
• Fecal Coliform (For the Santa Monica Bay model only)
• E. coli (For the Dominguez Channel model only)
• Total Suspended Solids (TSS), which served as a surrogate for numerous other WBPCs
• Metals – Total copper, total lead, total zinc, and total cadmium The results of the modeling are discussed in the following subsections.
Fecal Coliform and E. coli: As discussed in Section 3.1.2, FIB representation was added to the WMMS 2.0 LSPC model to demonstrate compliance to TMDL permit limits that are expressed in exceedance days. HRU-specific land use bacteria EMCs from WMMS
1.0 were adopted as the starting point of the calibration. The next step in the calibration process was an iterative application of multipliers to EMCs across all HRUs. For the Santa Monica Bay watershed model, the EMCs were calibrated and validated against wet weather fecal coliform monitoring data collected OF-BCEG-03. For the Dominguez Channel model, the FIB modeling parameters were calibrated and validated against E. coli monitoring data collected at outfall sites OF-BCEG-07 and OF-BCEG -05, respectively. OF-BCEG-07 was used as the calibration site because it had more sampled data points (12 events) compared to OF-BCEG-05 (6 events). The calibrated range of parameters are summarized in Table 7.
App D. Beach Cities EWMP RAA Report 24 May 2021
Table 7. Summary of Calibrated FIB Modeling Parameters
Parameter Description Units
Santa Monica
Bay Model
Values (Fecal
Coliform)
Dominguez
Channel Model
Values (E. coli)
SOQC
Concentration of
constituent in surface
outflow
MPN/
100mL 1,500– 136,500 1,300 – 118,300
IOQC
Concentration of
constituent in interflow
outflow
MPN
/100mL 1,500– 136,500 1,300 – 118,300
TSS: Although TSS is not a pollutant of concern for the Beach Cities WMG, it is an important driver for sediment-associated pollutant simulation within LSPC. In addition, TSS loads are used as a surrogate for organic pollutants of concern that are not modeled directly in LSPC (e.g., benzo[a]pyrene, total chlordane). TSS calibration was performed by iteratively applying multipliers to HRU-specific parameter associated with sediment load buildup on the land surface. The range of calibrated buildup is summarized in Table
8. TSS was not modeled (and hence not calibrated) in the Santa Monica Bay LSPC model as there are no WBPCs that are sediment-associated in the watershed. For the Dominguez Channel watershed model, the TSS modeling parameters were calibrated and validated against TSS monitoring data collected at outfall sites OF-BCEG-07 and OF-BCEG-05, respectively.
Table 8. Summary of Calibrated Sediment Loading Parameters Parameter[1] Description Units Beach Cities
Model Values
ACCSDP
Rate at which solids
accumulate on the land
surface
lb/acre/day 0 – 0.002
Metals: Calibration for metals was performed by iteratively applying HRU specific multipliers to LSPC model parameters associated with metal potency factors in order to maintain the same relative ratios among HRUs determined in the regionally calibrated WMMS 2.0 LSPC model. The calibration results are summarized in Table 9. No metals were modeled (and hence were not calibrated) in the Santa Monica Bay model since there are no metals WBPCs for the Santa Monica Bay WMA. For the Dominguez Channel watershed model, metal-related modeling parameters were calibrated and validated against monitoring data collected at outfalls OF-BCEG-07 and OF-BCEG -05, respectively.
App D. Beach Cities EWMP RAA Report 25 May 2021
Table 9. Summary of Calibrated Pollutant Loading Parameters Pollutant Parameter
Name Description Units
Beach
Cities
Model
Values
Total
Copper
POTFW Pollutant wash-off potency
factor per mass of sediment lb/ton 0-1.5
POTFS Pollutant scour potency factor
per mass of sediment lb/ton 0-1.9
Total Lead
POTFW Pollutant wash-off potency
factor per mass of sediment lb/ton 0-0.28
POTFS Pollutant scour potency factor
per mass of sediment lb/ton 0-0.28
Total Zinc
POTFW Pollutant wash-off potency
factor per mass of sediment lb/ton 0-13.8
POTFS Pollutant scour potency factor
per mass of sediment lb/ton 0-13.8
Total
Cadmium
POTFW Pollutant wash-off potency
factor per mass of sediment lb/ton 0.001-0.025
POTFS Pollutant scour potency factor
per mass of sediment lb/ton 0.001-0.025
Table 10 presents a summary of results for water quality calibration for all WBPCs.
Calculations of PBIAS were based on a comparison of modeled and observed daily average concentration at each outfall monitoring site. To further evaluate the temporal trends of the water quality calibration, comparisons between modeled and observed pollutant concentration were evaluated examining the time series plots. An example of the time series plots for total zinc concentration was shown in Figure 9. The remaining time series plots are included in Attachment D.1.
In reference to the RAA Guideline calibration metrics summarized in Table 4, modeled pollutant concentrations achieved “Fair” (orange shaded), “Good”(light green shaded), or “Very Good” (green shaded) agreement with observed data at all comparison sites. It should be noted that the TSS concentration measured at OF-BCEG-05 on 1/9/2018 was deemed as an outlier due to noted laboratory QA/QC flags and was therefore excluded from the model calibration process.
Table 10. Water Quality Model Calibration Summary
Calibration
Metric
Constituent
Group
Santa Monica Bay
Model
Dominguez Channel Model
OF-BCEG-03 OF-BCEG-05 OF-BCEG-07
PBIAS (%)
Indicator
Bacteria[2] -27.7 -3 +7
TSS n/a[1] -25 +23
Total Copper n/a[1] -21 +35
App D. Beach Cities EWMP RAA Report 26 May 2021
Calibration
Metric
Constituent
Group
Santa Monica Bay
Model
Dominguez Channel Model
OF-BCEG-03 OF-BCEG-05 OF-BCEG-07
Total Lead n/a[1] +23 +18
Total Zinc n/a[1] -11 +10
Total Cadmium n/a[1] +28 +35
[1] No WBPCs associated with this constituent in Santa Monica Bay watershed. [2] Fecal coliform for the Santa Monica Bay model; E. coli for the Dominguez Channel model.
Figure 9. Example Concentration Comparison Plot (Total Zinc)
App D. Beach Cities EWMP RAA Report 27 May 2021
6. CRITICAL CONDITION DEFINITION
6.1. Santa Monica Bay WMA
6.1.1. Bacteria (Fecal Coliform)
Consistent with the critical condition definition in the Wet Weather SMBBB TMDL and the Regional Board RAA Guidance (LARWQCB, 2014b), the Santa Monica Bay RAA for bacteria was completed utilizing the 90th percentile wet year. Water Year 20115 was previously identified for all watersheds in Los Angeles County using WMMS 2.0 hydrologic analysis of the most recent 10-years of rainfall data to define the 90th percentile representative “water year” (LACFCD, 2020c). Water Year 2011 then served as the basis for determination of wet weather bacteria critical condition in the Beach Cities Santa Monica Bay WMA.
6.2. Dominguez Channel WMA
6.2.1. Indicator Bacteria (E. coli)
Similar to all existing Los Angeles region bacteria TMDLs for rivers, as well as the Regional Board RAA Guidance (LARWQCB, 2014b), the Dominguez Channel RAA for bacteria used the 90th percentile wet year. As discussed in Section 6.1.1, the 90th percentile wet year timeframe was identified to be Water Year 2011 for the Dominguez Channel WMA (LACFCD, 2020c).
6.2.2. Metals and Organic Pollutants
According to the Dominguez Channel and Greater Los Angeles and Long Beach Harbor Toxics TMDL (herein referred as the Dominguez Channel Toxics TMDL), the critical condition for metals and organic pollutants discharging to Dominguez Channel and Torrance Lateral were defined as the 90th percentile daily pollutant load. The calibrated Beach Cities Dominguez Channel LSPC watershed model was used to compute the daily metals and TSS loads 6 on wet days between 2008 and 2018. The daily loads were calculated and ranked for each pollutant, with the 90th percentile daily load (summarized in Table 11) selected as the defining condition representing the required TLR that must be achieved.
5 October 2010 to September 2011
6 Since organic pollutants cannot be modeled directly in WMMS 2.0, TSS is used as a surrogate to calculate the 90th pollutant load day for organic pollutants
App D. Beach Cities EWMP RAA Report 28 May 2021
Table 11. Dominguez Channel WMA 90th Percentile Daily Load Summary Analysis
Region
(Receiving
Water)
Pollutant
90th
Percentile
Load
Load
Unit
90th
Percentile
Load Day
Runoff
Volume
During the 90th
Percentile
Load Day
(ac-ft)
DC-N-MB
(Dominguez
Channel
Freshwater)
TSS 1,904 lb/day 3/17/2012 5.5
Total Copper 1.3 lb/day 12/12/2011 8.4
Total Lead 0.2 lb/day 12/12/2011 8.4
Total Zinc 6.9 lb/day 12/12/2011 8.4
DC-N-RB
(Dominguez
Channel
Freshwater)
TSS 5,936 lb/day 10/30/2010 19.2
Total Copper 4.1 lb/day 12/17/2010 30.1
Total Lead 0.6 lb/day 12/17/2010 30.1
Total Zinc 22.0 lb/day 12/17/2010 30.1
DC-S
(Dominguez
Channel
Freshwater)
TSS 7,706 lb/day 11/30/2012 34.3
Total Copper 4.0 lb/day 11/6/2011 35.4
Total Lead 0.5 lb/day 11/6/2011 35.4
Total Zinc 18.4 lb/day 11/30/2012 34.3
DC-TL
(Torrance
Lateral and
Dominguez
Channel
Estuary[1])
TSS 15,299 lb/day 4/11/2012 50.8
Total Cadmium[2] 0.15 lb/day 1/21/2012 40.6
Total Copper 11.5 lb/day 1/21/2012 40.6
Total Lead 1.6 lb/day 1/21/2012 40.6
Total Zinc 65.1 lb/day 1/21/2012 40.6
[1] DC-TL drains to Dominguez Channel Estuary via Torrance Lateral. [1]Cadmium is a pollutant of concern for Dominguez Channel Estuary only. However analysis region DC-TL discharges to the Dominguez Channel Estuary and is shown in the TMDL for this WMA.
App D. Beach Cities EWMP RAA Report 29 May 2021
7. TARGET LOAD REDUCTIONS
The following subsection documents the development of wet weather TLRs for the Beach Cities EWMP area. The dry weather RAA approach described in Section 4.2 does not require TLRs. See Section 10 for the dry weather RAA result.
7.1. Santa Monica Bay WMA
Wet weather pollutants of concern for the Santa Monica Bay WMA include fecal coliform, PCBs, DDT, mercury, arsenic, trash, and marine debris. The following sections describe the TLR development for each pollutant, or the justifications on why a modeled TLR is not required to demonstrate reasonable assurance of compliance.
7.1.1. Bacteria (Fecal Coliform)
Utilizing the calibrated Beach Cities Santa Monica Bay LSPC watershed model, the bacteria TLR was established by following the same modeling approach developed in the original Beach Cities EWMP, which accounted for site-specific monitoring data at each shoreline CML. As discussed in Section 3.1.2, the modeling methodology correlates the bacteria load to the expected annual bacteria exceedance days, which is the Permit’s WQBEL expression for the SMBBB TMDL.
The fecal coliform TLR was estimated by modeling a hypothetical detention basin at each analysis region outlet. As the first step in this process, the allowable discharge days for each analysis region was calculated as the TMDL-specified allowable exceedance days, divided by the 10-year wet weather exceedance rate at the shoreline CML. This approach makes use of site specific wet weather beach bacteria monitoring data to determine the number of discharge days that result in the number of allowable exceedance days at the shoreline. For analysis regions with anti-degradation-based allowable exceedance days, a target load reduction of zero is assumed. This approach is consistent with the SMBBB TMDL which acknowledges that historic bacteria exceedance rates for each of these analysis regions are lower than that of the reference beach, on average, and therefore no additional load reduction is required. This assumption applies for seven of the 11 total SMBBB TMDL CMLs in Beach Cities Santa Monica Bay WMA – i.e., SMB-5-1, SMB5-3, SMB-5-4, SMB-5-5, SMB-6-2, SMB-6-5, and SMB-6-6. Historic wet weather monitoring data at these sampling locations through TMDL Year 2019 confirm this understanding, as the long-term exceedance rate at all seven sites varies between 7% and 24%. This is below the long-term wet weather exceedance rate at the reference beach (26%) allowing the conclusion that no additional load reduction is required at these locations.
App D. Beach Cities EWMP RAA Report 30 May 2021
For analysis regions without anti-degradation-based allowable exceedance days, a hypothetical basin was iteratively sized until discharge frequency at the outfall is less than or equal to the allowable exceedance days at that monitoring location. Each hypothetical downstream retention BMP included a diversion with a calculated hydraulic capacity that provides full capture of flows and results in a model-derived bypass frequency (or number of discharge days) for Water Year 2011 that achieves the allowable exceedance day criteria. Each diversion for these conceptual BMPs was separately modeled to determine the hydraulic capacity that results in full capture of discharge. The net load reduction resulting from this conceptual BMP scenario (i.e., baseline analysis region load minus the analysis region load with the diversion system and full capture retention BMP in place) for Water Year 2011 is the TLR. For the RAA, reasonable assurance of compliance is achieved when modeled load reductions associated with proposed BMPs is greater than or equal to the TLR for each analysis region.
In summary, the following approach was implemented to calculate a TLR for each SMB modeled analysis region without anti-degradation-based allowable exceedance days:
1. Each analysis region that does not currently comply with applicable TMDL limits was modeled in LSPC for the 90th percentile wet year (Water Year 2011).
2. The existing, baseline condition (i.e., without an outlet retention BMP) was modeled for each analysis region, resulting in a determination of the baseline fecal coliform load for the 90th percentile water year (baseline load).
3. The 10-year historical wet weather exceedance percentage was determined by dividing the total number of wet weather exceedance days by the total number of discharge days in which wet weather was sampled.
4. The allowable number of discharge days for each analysis region was calculated by dividing the total number of allowable exceedance days (17, per the TMDL) by the exceedance percentage calculated in Step 3.
5. An in-stream diversion to a large hypothetical retention BMP at the outlet of each analysis region was iteratively sized to reduce the number of discharge days to be less than or equal to the allowable discharge days determined in Step 4.
6. Each diversion and hypothetical retention BMP was then modeled to produce a mean fecal coliform load for the 90th percentile year (allowed load).
7. For each analysis region, the difference between the baseline load (Step 2) and the allowed load (Step 6) resulted in a TLR for the 90th percentile year, which was the target load reduction required to meet the 17 allowable TMDL exceedance days for wet weather.
8. A TLR-equivalent 24-hour runoff management volume was estimated as the maximum daily diverted volume during the critical condition (i.e. throughout the modeled year). Both load-based TLR and the equivalent 24-hour runoff
App D. Beach Cities EWMP RAA Report 31 May 2021
management volume are considered eligible Beach Cities EWMP compliance metrics.
7.1.2. Pesticides and PCBs
Consistent with the original EWMP as well as the SMB PCBs and DDT TMDL, the WLAs for the entire Santa Monica Bay WMA were set equal to the existing estimates of annual loads for DDT and PCBs. Both outfall and receiving water monitoring data collected as part of the Beach Cities CIMP demonstrate that discharges of PCBs and DDTs from the Beach Cities Beach Cities EWMP area into Santa Monica Bay are below the TMDL limits (Beach Cities WMG, 2020). Therefore, the current required additional load reduction to meet TMDL WLAs is zero for PCBs and DDTs, and no BMP modeling analysis is required to demonstrate compliance. For more information, see the Source Assessment portion of the updated Beach Cities EWMP, Appendix B.
7.1.3. Mercury and Arsenic
Mercury and arsenic were recently added to the 303(d) list for Santa Monica Bay WMA.
However, CIMP monitoring data collected by the Beach Cities to date demonstrate that outfall concentrations were consistently below the Ocean Plan objectives for these parameters. As a result, no modeling was conducted for mercury or arsenic as part of the resvised RAA. For more information, see the Source Assessment portion of the updated Beach Cities EWMP, Appendix B.
7.1.4. Trash and Marine Debris
Compliance with the SMB Debris TMDL will be met through a phased retrofit of fullcapture or partial capture systems throughout the Beach Cities Santa Monica Bay WMA in combination with institutional measures (e.g., street sweeping with posted no-parking on street sweeping days) to meet each interim and final compliance deadline. Hence, these constituents do not require a TLR to be calculated and were not modeled as part of the revised RAA.
7.1.5. Final Wet Weather TLR Summary for Santa Monica Bay TLRs for each analysis region draining to a Santa Monica Bay CML are listed in Table
12. Consistent with the original EWMP, non-zero TLRs were only identified in two SMB analysis regions – SMB-5-02 and SMB-6-01. Based on the number of anti-degradation sites within the Beach Cities Santa Monica Bay WMA, coupled with the water quality history at the other sites, these results are expected.
App D. Beach Cities EWMP RAA Report 32 May 2021
Table 12. Santa Monica Bay WMA Wet Weather TLR
Analysis
Region
Critical
Condition
Baseline Load
(1012 MPN/
year)
Final Target Load Reduction
Absolute
(1012 MPN/
year)
% of
Baseline
Load
TLR
Equivalent 24-
Hour
Management
Volume (ac-ft)
SMB-5-1
90th percentile
water year
6.4 Anti-Degradation 0% 0
SMB-5-2 311.3 167.5 54% 67.1
SMB-5-3 19.7 Anti-Degradation 0% 0
SMB-5-4 9.4 Anti-Degradation 0% 0
SMB-5-5 97.1 Anti-Degradation 0% 0
SMB-6-1 277.8 137.1 49% 51.2
SMB-6-2 42.3 Anti-Degradation 0% 0
SMB-6-3 27.5 CIMP data shows compliance with final allowable exceedance days. Hence no RAA required to
SMB demonstrate compliance. -6-4 11.2
SMB-6-5 36.5 Anti-Degradation 0% 0
SMB-6-6 3.9 Anti-Degradation 0% 0
7.2. Dominguez Channel WMA
Wet weather pollutants of concern in the Dominguez Channel WMA include toxicity, total copper, total lead, total zinc, indicator bacteria, and benzo(a)pyrene. Total PCBs, total DDTs, total cadmium, and total PAHs are additional WBPCs for Beach Cities EWMP area tributary to Torrance Lateral and Dominguez Channel Estuary7 . While the
default WMMS 2.0 LSPC model represents a subset of these WBPCs, TLRs and target loads for the other WBPCs were established using surrogate pollutants in order to comply with the State Board’s requirement to demonstrate reasonable assurance of attainment of all applicable water quality TMDL WLAs (SWRCB, 2020).
7.2.1. Metals
Total copper, total lead, and total zinc are Category 1 WBPCs in the Dominguez Channel WMA due to the Dominguez Channel Toxics TMDL . Total cadmium is an additional Category 1 WBPCs in Dominguez Channel Estuary due to the Toxics TMDL. Zero TLRs were set for total lead since CIMP monitoring data from contributing outfalls have consistently met the respective TMDL WLAs.
7 For the Beach Cities EWMP area, analysis region DC-TL drains to Dominguez Channel Estuary via Torrance Lateral. No other Beach Cities EWMP area drains to the Dominguez Channel Estuary or the Torrance Lateral.
App D. Beach Cities EWMP RAA Report 33 May 2021
Per the MS4 Permit, permittees shall be deemed in compliance with TMDL WLAs for total copper, total lead and total zinc if loads are less than the allocation when using one of the following calculations:
1. For analysis regions tributary to Dominguez Channel freshwater and Torrance Lateral - Daily loading of pollutants calculated as the water-column WQBEL concentration8 multiplied by the daily flow volume during the 90th percentile loading day. The TMDL water-column WQBELs in the TMDL are based on California Toxics Rule (CTR) aquatic life criteria maximum concentration.
2. For analysis regions tributary to Dominguez Channel - Daily mass-based MS4 WLA apportioned to Beach Cities WMG tributary area
3. For analysis region(s) tributary to Torrance Lateral - Daily loading of pollutants calculated as the sediment-column WQBEL concentration multiplied by the daily TSS load during the 90th percentile loading day.
As such, the method that resulted in the least restrictive daily loading of pollutants was used to determine the allowable load in TLR calculations.
According to the Beach CIMP outfall data, the Beach Cities WMG has been meeting all the applicable interim MS4 WLAs for total copper, total lead and total zinc. Hence, zero interim TLRs were assumed.
For total cadmium, the final MS4 WLA in the TMDL is expressed as the daily loading of pollutants calculated as the sediment-based WQBEL multiplied by the daily sediment load during the 90th percentile load day. The TMDL WQBEL is based on the sediment numeric targets in the Screening Quick Reference Tables (SQuiRTs) developed by National Oceanic and Atmospheric Administration (NOAA).
The following approach was implemented to calculate a TLR for each metal in the Beach Cities Dominguez Channel WMA:
1. The analysis region was modeled in LSPC for the 90th percentile load day defined in Table 11 to obtain the baseline pollutant load.
2. The allowable load was calculated using the applicable metal TMDL WLA. For pollutants with multiple WLAs, the WLA that resulted in the least restrictive allowable load was selected for calculation of the TLR.
3. The difference between the baseline load (Step 1) and the allowable load (Step 2) determined the absolute TLR for the 90th percentile load day, the load reduction 8 The Dominguez Channel Toxics TMDL is currently being reconsidered and may introduce the concept of site-specific water-effect ratios for copper and lead, which have been adopted in other freshwater metal TMDLs in the Los Angeles Region. The adoption of site-specific water-effect ratios may result in significant deviation from the current WQBELs, requiring an update to the Beach Cities EWMP.
App D. Beach Cities EWMP RAA Report 34 May 2021
required to meet the TMDL WLA. A percentage TLR was also calculated by dividing the absolute TLR by the baseline pollutant load.
4. The TLR equivalent 24-hour volume was calculated as the average daily runoff volume multiplied by the percentage TLR.
7.2.2. Pesticides, Organics, and PCBs
Total DDTs, total PCBs, benzo[a]pyrene and total PAHs are Category 1 WBPCs in Dominguez Channel Estuary due to the Dominguez Channel Toxics TMDL.
Benzo[a]pyrene is a Category 3 WBPC for Beach Cities WMA tributary to the Dominguez Channel freshwater due to CIMP monitoring results indicating potential contribution towards water quality standard exceedances in the estuary. Zero TLRs were set for total DDTs, total PCBs and total PAHs since the Beach Cities WMG has continuously met the respective numeric targets according to Beach Cities CIMP outfall monitoring data.
When representing Benzo[a]pyrene and total PAHs for the Dominguez Channel Estuary and Benzo[a]pyrene for the Dominguez Channel freshwater segments, these constituents cannot be modeled directly in WMMS 2.0 LSPC. Instead, TSS was modeled and used as a surrogate to compute TLR for these organic pollutants. For representing benzo[a]pyrene contributions to the Dominguez Channel freshwater segments, daily loading was calculated as the TMDL water-column WQBELs multiplied by the daily flow volume during the 90th percentile TSS loading day. For representing Benzo[a]pyrene and total PAH contributions to the Dominguez Channel Estuary, the final MS4 WLA in the Permit were expressed as the daily loading of pollutants calculated as the marine sediment-based WQBEL multiplied by the average daily sediment load.
The following approach was implemented to calculate a TLR for each pesticide or PCB in the Dominguez Channel portion of the Beach Cities WMA:
1. The analysis region was modeled in LSPC for the 90th percentile TSS load day as defined in Table 11 to obtain the baseline TSS load
2. Particulate strength (pollutant-to-TSS ratio) for Benzo[a]pyrene and total PAHs were calculated using paired wet weather monitoring data (e.g. pollutant concentration and TSS concentration from the same sample) collected at outfall monitoring locations in the Dominguez Channel watershed (OF-BCEG-05, OFBCEG-06, and OF-BCEG-07).
3. The baseline pollutant load was computed by multiplying the baseline TSS load and the organic pollutant particulate strength.
4. The allowable load was calculated using applicable TMDL WLAs.
5. The difference between the baseline load and the allowable load resulted in a TLR for the 90th percentile load day, the load reduction required to meet the applicable
App D. Beach Cities EWMP RAA Report 35 May 2021
water quality standard. A percentage TLR was also calculated by dividing the absolute TLR by the baseline pollutant load.
6. The TLR equivalent 24-hour was calculated as the daily runoff volume multiplied by the percentage TLR.
7.2.3. Indicator Bacteria (E. coli)
Within the Beach Cities Dominguez Channel WMA9
, a TLR approach was developed
based on allowable exceedance days. Dominguez Channel is 303(d)-listed for bacteria and its targets were developed consistent with the reference system allowable exceedance approach implemented for other Los Angeles region freshwater TMDLs. The DC has a REC-2 beneficial use designation and a High Flow Suspension (HFS) Day allowance.
The Dominguez Channel TLR calculations for bacteria followed a similar methodology as the Santa Monica Bay TLR calculations for fecal coliform. It was assumed that 19% of non-high flow suspension days could exceed 4000 MPN/100mL based on the historical exceedance rates observed at other freshwater bodies in the Los Angeles region (Schiff, Griffith & Lyon, 2005.). This approach is consistent with the Malibu Creek Watershed Bacteria TMDL approach for developing waste load allocations expressed as allowable exceedance days (LARWQCB, 2012b)
7.2.4. Toxicity
According to Beach Cities and Dominguez Channel CIMP data, receiving water monitoring from within the Dominguez Channel has not exceeded the interim and final toxicity WQBELs to date. Hence, reasonable assurance is demonstrated and a TLR was not developed for toxicity for the Beach Cities WMG.
9 Includes area tributary to Dominguez Channel Freshwater, Torrance Lateral and Dominguez Channel Estuary.
App D. Beach Cities EWMP RAA Report 36 May 2021
7.2.5. Final Wet Weather TLR Summary
By implementing the steps described above, TLRs were developed for each modeled pollutant. TLRs for each pollutant are listed in Table 13. A representative 24-hour management volume was selected for each analysis region. For each analysis region, the largest 24-hour management volume was selected as the target compliance metric, since management of the largest volume will result in management of all others10. 10 Total copper was not included in the assessment of the largest 24-hour management volume, since significant load reductions will be achieved via the copper brake pad reduction (see Section 8.2.1). As a result, the management volumes needed to meet applicable copper TLRs using structural BMPs are significantly reduced
App D. Beach Cities EWMP RAA Report 37 May 2021
Table 13. Dominguez Channel WMA Wet Weather TLRs
Analysis
Region
(Receiving
Water)
Pollutant Critical Condition Baseline Load
Target Load Reduction
Absolute
% of
Baseline
Load
TLR Equivalent 24-
Hour Management
Volume (ac-ft)
DC-N-MB
(Dominguez
Channel
Freshwater)
Total Copper 90th percentile daily load 1.3 lb/day 1.1 lb/day 82% 7.3 Total Lead CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance Total Zinc 90th percentile daily load 6.9 lb/day 5.3 lb/day 76% 6.7[1] E. coli 90th percentile water year 46.1 1012 MPN/yr 19.0 1012 MPN/yr 41% 2.4 Benzo[a]pyrene 90th percentile daily load 2.6E-03 lb/day 1.8E-03 lb/day 70% 4.0 Toxicity CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance
DC-N-RB
(Dominguez
Channel
Freshwater)
Total Copper 90th percentile daily load 4.1 lb/day 3.3 lb/day 81% 24.3 Total Lead CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance Total Zinc 90th percentile daily load 22.0 lb/day 16.3 lb/day 74% 22.3[1] E. coli 90th percentile water year 149.8 1012 MPN/yr 53.0 1012 MPN/yr 35% 9.7 Benzo[a]pyrene 90th percentile daily load 7.7E-03 lb/day 5.2E-03 lb/day 67% 12.8 Toxicity CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance DC-S
(Dominguez
Channel
Freshwater)
Total Copper 90th percentile daily load 4.0 lb/day 3.0 lb/day 76% 27.1 Total Lead CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance Total Zinc 90th percentile daily load 18.4 lb/day 11.9 lb/day 65% 22.2[1] E. coli 90th percentile water year 393.8 1012 MPN/yr 179.1 1012 MPN/yr 45% 15.3 Benzo[a]pyrene 90th percentile daily load 1.0E-02 lb/day 5.5E-03 lb/day 55% 18.7 Toxicity CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance DC-TL
(Torrance
Lateral and
Dominguez
Channel
Estuary)
Total Copper 90th percentile daily load 11.5 lb/day 10.4 lb/day 91% 36.8 Total Lead CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance Total Zinc 90th percentile daily load 65.1 lb/day 57.4 lb/day 88% 35.8[1] Total Cadmium 90th percentile daily load 0.15 lb/day 0.13 lb/day 87% 35.2 E. coli 90th percentile water year 360.8 1012 MPN/yr 175.3 1012 MPN/yr 49% 16.2 Benzo[a]pyrene 90th percentile daily load 2.0E-02 lb/day 1.3E-02 lb/day 67% 34.1 Total PAHs CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance Toxicity CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance Total PCBs CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance Total DDTs CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance [1]Bold value is the representative 24-hour management runoff volume for each analysis region.
App D. Beach Cities EWMP RAA Report 38 April 2021
8. STORMWATER CONTROL OVERVIEW
8.1. Methods to Select and Prioritize BMPs
To demonstrate reasonable assurance, BMPs were identified in a prioritized manner to meet the TLRs. Prioritization was based on cost (lower cost BMPs were prioritized first); BMP effectiveness for the pollutants of concern (BMPs that provided greater load reduction for the pollutant of concern in a particular analysis region were prioritized over other BMPs); and implementation feasibility as determined by the Beach Cities WMG.
It was assumed that the baseline model calibration accounted for existing BMPs that are universally implemented in the Beach Cities EWMP area (e.g., street sweeping, catch basin and storm drain cleaning, low impact development prior to June 2020, etc.). As discussed in Section 5.1, monitoring data from watersheds with existing regional stormwater BMPs and green streets were not used for calibration. The effectiveness of existing regional BMPs outside the calibration areas has been quantified in this updated RAA.
The RAA was performed according to the following steps:
1. Calculate load reductions associated with future, quantifiable non-structural BMPs (e.g., copper reductions due to brake pad phase-out);
2. Calculate load reductions associated with existing structural BMPs.
3. Calculate load reductions for proposed regional and distributed BMPs that were identified in existing plans; and
4. If necessary, identify new regional or distributed BMPs to meet any remaining TLR.
8.2. Non-Structural BMPs
In accordance with the State Board Order (SWRCB, 2020), all non-structural BMP load reductions that are taken credit for in a RAA are required to be adequately justified. Since data are limited with respect to load reductions achieved by most non-structural BMPs, the Beach Cities RAA assumed that any effects of non-structural BMPs implemented prior to June 2020 (including enhanced minimal control measures [MCMs]) are already reflected in the outfall monitoring data used in the calibration. As a result, no other explicit non-structural BMP load reduction credit has been incorporated into the revised RAA.
Source controls implemented by the Beach Cities WMG include new or enhanced pet waste controls (e.g., ordinance, signage, education/outreach, mutt mitts); Clean Bay Restaurant Program; human waste illicit discharge source tracking and remediation (e.g., leaking sewer investigations and implementation of each agency’s Sanitary Sewer
App D. Beach Cities EWMP RAA Report 39 April 2021
Management Plan consistent with Statewide WDRs); enhanced street sweeping (e.g., 100% vacuum sweepers, increased frequency, posting of ‘No Parking’ signs for street sweeping); catch basin and storm drain cleaning; and other new or enhanced nonstructural BMPs that target the pollutants addressed in the original EWMP.
One specific non-structural legislative BMP program was accounted for in the revised Beach Cities EWMP RAA for which a load reduction could be quantified and forecasted based on phased implementation – reduction of copper in brake pads.
8.2.1. Copper Brake Pad Reduction
As was the case in the original Beach Cities EWMP, a load reduction was assumed for copper due to the phased reduction of copper in brake pads. In 2010, California Senate Bill 346 (SB 346) was enacted to eliminate nearly all use of copper in brake pad manufacturing. In 2013, TDC Environmental prepared a technical study for the California Stormwater Quality Association (CASQA) describing the expected percent reduction for copper as a result of the passage of SB 346 (TDC Environmental, 2013). The TDC study identified three possible implementation scenarios, the least aggressive of which estimated that a 52% load reduction in copper will be achieved by 2032 due to the brake pad phase-out.
Since the referenced study found a 21.2% reduction in urban runoff copper by 2020, and the RAA model was calibrated with local water quality data through June 2020, the load reduction accounted for in the updated RAA was estimated. The difference in estimated total load reduction between 2032 and 2020 (i.e., 52% - 21.2%, or 30.8%). This was divided by the assumed remaining load in 2020 (100% - 21.2%, or 78.8%) to estimate the remaining expected load reduction due to the copper brake pad phase-out. Therefore, a
39.1% load reduction was assumed for copper in the Beach Cities Dominguez Channel WMA.
To avoid double-counting load reductions, this reduction was applied to the copper load before accounting for future BMP load reductions (i.e., 39.1% was applied to the baseline loads before all other BMP load reductions were accounted for, since BMP performance is dependent on influent loads).
8.3. Modeling Structural BMPs
To represent structural BMPs, WMMS 2.0 SUSTAIN was used to account for BMP storage, infiltration, inflow, and outflow capacities using available BMP as-built drawings or conceptual drawings provided by the Beach Cities WMG. For structural BMPs that provide flow-through treatment, the treatment efficacy was represented as either fixed effluent concentration or as a percentage of influent concentration reduction extracted from the WMMS 2.0 Phase II Report: BMP Model and Optimization
App D. Beach Cities EWMP RAA Report 40 April 2021
Framework (LACFCD, 2020b), which includes effluent concentrations of BMPs included in the default WMMS 2.0 SUSTAIN model.
Several existing regional projects were sized (or planned to be sized) to capture runoff from at least the 85th percentile, 24-hour storm event. Since the MS4 Permit states that controls that fully capture the 85th percentile, 24-hour storm are an alternative means of achieving compliance with TMDL WLAs and other WQS, reasonable assurance is assumed to be achieved in these project drainage areas based on this 85th percentile capture demonstration. These projects and their tributary drainage areas were excluded from this RAA analysis. Table 14 summarizes the 85th percentile 24-hour projects with their locations shown in Figure 10.
Table 14. Summary of Full 85th-Percentile, 24-Hr Design Storm Capture Project Analysis Region Project Name
SMB-5-2
Wylie Basin
Beach Cities Green Streets 1 (Manhattan Beach 19th Street) SMB-6-1
Torrance Basin Enhancement and Expansion Project (Henrietta, Amie, and Entradero)
Beach Cities Green Streets 2 (Manhattan Beach Artesia Blvd.) Beach Cities Green Streets 3 (Redondo Beach Anita Street) Beach Cities Green Streets 4 (Redondo Beach Ford Ave.)
Beach Cities Green Streets 5 (Torrance 191st Street)
Beach Cities Green Streets 6 (Torrance Northwest)
Beach Cities Green Streets 7 (Hermosa Beach)
DC-N-MB Manhattan Village Mall LID
App D. Beach Cities EWMP RAA Report 41 April 2021
Figure 10. Overview of 85th-Percentile, 24-Hour Storm Capture Projects
8.3.1. Regional and Distributed Structural Projects
Through the project screening and evaluation process, a total of eight projects, beyond those capturing the 85th percentile, 24-hr storm described above, are proposed in this RAA. Table 15 summarizes the project types and key modeling parameters. The project locations are shown in Figure 11. Project fact sheets are included in the EWMP within Appendix E.
App D. Beach Cities EWMP RAA Report 42 April 2021
Figure 11. Modeled Regional and Distributed Projects
App D. Beach Cities EWMP RAA Report 43 May 2021
Table 15. Summary of Modeled Projects
Analysis
Region Project Lead WMG Member BMP Type
Drainage
Area
(ac)
Static BMP
Volume
(ac-ft)
Infiltration
/Treatment Rate
(cfs)
SMB-5-2
28th Street Storm Drain Infiltration
Project
Manhattan
Beach
Subsurface Infiltration 1480 1.2 71.5
SMB-6-1
Fulton Playfield Infiltration Project Redondo
Beach
Subsurface Detention
Basin & Infiltration
Wells
465 7.4 13
Hermosa Beach Distributed Drywells Hermosa
Beach
Distributed Infiltration
Wells
118 0.1 11
Redondo Beach Herondo Distributed
Infiltration Project
Redondo
Beach
Distributed Infiltration
Wells[1]
342 0.3 22
Hermosa Beach 8th Street Green
Infrastructure Project
Hermosa
Beach
Bioretention 8 <0.01 <0.01
DC-N-MB Manhattan Beach Dominguez Channel
Distributed Infiltration Project
Manhattan
Beach
Distributed Infiltration
Wells[1]
255 0.1 11
DC-N-MB/
DC-N-RB
Alondra Park Stormwater Capture
Project
Los Angeles
County
Subsurface Detention
& Treatment
1445 7.1 0.9
DC-N-RB
Glen Anderson Park Regional
Infiltration Project
Redondo
Beach
Subsurface Retention
and Infiltration
483 0.3 20
DC-N-RB
Redondo Beach Dominguez Channel
Distributed Infiltration Project
Redondo
Beach
Distributed Infiltration
Wells[1]
292 0.2 14
DC-S
Torrance Parkway BMP Torrance
Bioretention,
Treatment, and
Infiltration Facilities
This project was not modeled due to uncertainty of
its future design and performance. TLRs for DC-S
and DC-TL will be used as performance metrics
during project siting and design. DC-TL
[1] Drywells were modeled as a representative BMP in the updated RAA. Other infiltration BMPs with equivalent performance may be considered at project design phase.
App D. Beach Cities EWMP RAA Report 44 May 2021
8.3.2. Low Impact Development Applied to New and Redevelopment The 2012 MS4 Permit established new criteria for redevelopment projects, requiring certain sized projects to capture, retain, or infiltrate 100% of, or treat 150% of the 85th percentile, 24-hr design storm or the 0.75-inch design storm, whichever is greater, or treat 150% of the implementation of low impact development (LID) BMPs. All LID BMPs constructed through June 2020 were assumed to be accounted for in the model via the monitoring and calibration process. Moving forward, LID was assumed to be implemented at the annual redevelopment rate of 0.08% per year, assuming implementation from July 2020 until the applicable final TMDL deadline. In accordance with this projected redevelopment rate, the basis for which was documented in the 2019- 20 Beach Cities Annual Watershed Report (Beach Cities WMG, 2020), redevelopment that is subject to an LID ordinance was modeled assuming an annual redevelopment of
0.08% per year across all Beach Cities agency jurisdictions for residential, commercial, industrial, institutional, and transportation land uses. To estimate load reductions associated with these redevelopment BMPs, the land use percentages were multiplied by the respective land use areas in each analysis region. This resulted in a calculated area that would be treated by LID BMPs each year. This area was multiplied by the applicable number of years until the TMDL final deadlines, as LID BMPs will be implemented each year at the assumed rate. The total land use area assumed to be redeveloped for each analysis region was then modeled as being treated by assumed required BMPs and the total load reduction was quantified.
To maintain consistency with the BMP types observed in redevelopment activities todate in the watershed, 96% of the redeveloped land is projected to implement bioretention or similarly functioning systems that fully capture the 85th percentile, 24-hour storm runoff. The remaining 4% of the redeveloped area will implement biofiltration systems that treat 1.5 times the 85th percentile, 24-hour storm storm runoff.
Modeling parameters of the bioretention and biofiltration units are summarized in Table
16.
App D. Beach Cities EWMP RAA Report 45 May 2021
Table 16. Redevelopment LID BMP Modeling Parameters
Bioretention Biofiltration
Max Years of
Redevelopment
Modeled
5 years[1] (Santa Monica Bay)
12 years[2] (Dominguez Channel)
Pond Depth 12 inches[3]
Infiltration Rate 5 in/hr[3] n/a
Soil Depth (in) 36
Effluent Concentration
Total Cadmium n/a 0.07 ug/L[3]c
Total Copper n/a 5.7 ug/L[3]c
Total Lead n/a 0.32 ug/L[3]c
Total Zinc n/a 12 ug/L[3]
TSS n/a 10 mg/L[3]
Indicator Bacteria n/a See Footnote 4
[1] The Beach Cities WMG joined the County of Los Angeles’s request for a 5-year Time Schedule Order (TSO) for the SMBBB Wet Weather TMDL. Hence, it is assumed that the Beach Cities WMG will have to meet the final WLAs by July 2026.
[2] Based on the effect year of the final Dominguez Channel Toxics TMDL (2032). [3] Default WMMS 2.0 SUSTAIN parameters for bioretention/biofiltration BMPs (LACFCD, 2020b) [4] A 40% reduction in influent concentration is assumed based on peer reviewed publication (Clary et al. 2020.)
App D. Beach Cities EWMP RAA Report 46 May 2021
9. WET WEATHER RAA RESULTS
9.1. Santa Monica Bay WMA
Load reduction calculations for the Beach Cities Santa Monica Bay WMA are summarized in Table 17. The predicted load reductions summed for all existing and proposed BMPs met or exceeded all the TLRs within the analysis region. Hence, reasonable assurance of meeting TMDL WLAs was demonstrated.
As discussed in Section 7.1.5, a TLR-equivalent 24-hour stormwater management volume was computed for each non-zero TLR. The 24-hour management volume achieved by a project was computed as the representative volume apportioned to the load reduction that was or would be achieved by the project. The resultant 24-hour management volume of a project may or may not be equal to its static detention capacity shown in Table 15. The approach of evaluating the 24-hour management volume metric to the TLR resulted in prioritizing more efficient BMPs that provide greater load reduction per BMP capacity per day (24-hour period). The 24-hour management volume of each project is shown in Figure 12.
The 24-hour management volume results are mapped in Figure 13. Analysis regions with zero TLR (e.g., anti-degradation areas, areas demonstrating compliance based on water quality data) were also assigned zero 24-hour stormwater management volume. The 24- hour management volume of a regional project was spatially represented by its drainage area. Drainage areas to a regional project designed to capture the 85th percentile, 24-hour storm (i.e., areas that achieve alternative compliance, separate from the RAA) are designated in the figure by cross-hatchings.
App D. Beach Cities EWMP RAA Report 47 May 2021
Table 17. Beach Cities SMB WMA RAA Summary
Analysis
Region
Fecal Coliform Target Load Reduction
(TLR) BMP Load Reduction (LR) Summary
1012
MPN/yr
% of
Baseline
Load
TLR
Equivalent
24-Hour
Management
Volume
(ac-ft)
LID Redevelopment Regional Project Distributed Project Cumulative LR Assurance
Achieved?[1]
% of
Baseline
Load
24-Hour
Volume
(ac-ft)
% of
Baseline
Load
24-Hour
Volume
(ac-ft)
% of
Baseline
Load
24-Hour
Volume
(ac-ft)
% of
Baseline
Load
24-Hour
Volume
(ac-ft)
SMB-5-
01 No RAA needed to demonstrate compliance for anti-degradation sites (WLAs already met) n/a SMB-5-
02 167.5 54% 67.1 0.3% 0.4 65% 82.7 0% 0 65.2% 83.1 Yes SMB-5-
03 No RAA needed to demonstrate compliance for anti-degradation sites (WLAs already met) n/a SMB-5-
04 No RAA needed to demonstrate compliance for anti-degradation sites (WLAs already met) n/a SMB-5-
05 No RAA needed to demonstrate compliance for anti-degradation sites (WLAs already met) n/a SMB-6-
01 137.1 49% 51.2 0.3% 0.3 27.5% 28.9 23.5% 24.6 51.3% 53.8 Yes SMB-6-
02 No RAA needed to demonstrate compliance for anti-degradation sites (WLAs already met) n/a SMB-6-
03 No RAA needed to demonstrate compliance, as monitoring data show WLAs are being met n/a SMB-6-
04 No RAA needed to demonstrate compliance, as monitoring data show WLAs are being met n/a SMB-6-
05 No RAA needed to demonstrate compliance for anti-degradation sites (WLAs already met) n/a SMB-6-
06 No RAA needed to demonstrate compliance for anti-degradation sites (WLAs already met) n/a [1] Reasonable assurance is achieved if cumulative load reduction is greater than the TLR.
App D. Beach Cities EWMP RAA Report 48 May 2021
Note: Due to comparatively low volumes, LID redevelopment is not shown in the figure Figure 12. 24-Hour Management Volume Breakdown in Santa Monica Bay WMA
App D. Beach Cities EWMP RAA Report 49 May 2021
Figure 13. 24-Hour Management Mapping in Santa Monica Bay WMA.
App D. Beach Cities EWMP RAA Report 50 May 2021
9.2. Dominguez Channel WMA
Load reduction calculations for the Beach Cities Dominguez Channel WMA are summarized in Table 18. Reasonable assurance was demonstrated in all analysis regions.
As discussed in Section 7.2.5, a representative 24-hour stormwater management volume was determined for each analysis region. The 24-hour management volume of the projects are shown in Figure 14. It should be noted that, the Torrance Parkway Stormwater BMPs are not explicitly modeled in the RAA. The Beach Cities WMG has submitted a Safe, Clean Water Technical Resource Program application titled “Prioritize Parkway BMPs for Dominguez Channel Toxics TMDL” to assist in project siting. The Beach Cities WMG intends to use the EWMP compliance metrics summarized under the “Regional Project” column in Table 18 as the design criteria. The WMG expects to deploy a combination of catch basin inserts, green streets and parkway stormwater capture project to meet the TLR and the 24-hour management volume need through the Technical Resources Study.
The 24-hour management volume results are mapped in Figure 15. The 24-hour management volume of each regional project was applied to its drainage area. The volume assigned to areas draining to multiple projects were the cumulative volumes from all projects. Drainage areas to a regional project designed to capture the 85th percentile, 24- hour storm (i.e., areas that achieve alternative compliance, separate from the RAA) are designated in the figure by cross-hatchings. In addition, area covered under separate stormwater permits (e.g. Caltrans right-of-way, Torrance Refinery plant) are also shown as cross-hatched areas.
App D. Beach Cities EWMP RAA Report 51 May 2021
Table 18. Beach Cities DC WMA RAA Summary
Analysis
Region[1]
Pollutant
Final Target Load
Reduction
BMP Load Reduction Summary
Non-Structural BMP LID Redevelopment Regional Project Distributed Projects Total Load Reduction Assurance
Achieved?[3]
Absolute % Absolute % Absolute % Absolute % Absolute % Absolute %
DC-N-MB
(DC Freshwater)
Total Copper 1.1 lb/day 82% 0.5 lb/day 39% 0.01 lb/day 0.9% 0.2 lb/day 16% 0.4 lb/day 33% 1.1 lb/day 89% Yes Total Lead CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance n/a Total Zinc 5.3 lb/day 76% 0 lb/day 0% 0.1 lb/day 0.9% 1.6 lb/day 23% 3.7 lb/day 54% 5.4 lb/day 78% Yes E. coli 19.0
1012
MPN/y
r
41% 0 1012
MPN/yr 0% 0.3 1012MPN/y 0.7% 8.7 1012MPN/yr 19% 19.5 1012MPN/yr 42% 28.5 1012
MPN/
yr
62% Yes
Benzo[a]
pyrene
1.8 E-03 lb/day 70% 0 lb/day 0% 2.4E-05 lb/day 0.9% 4.9E-04 lb/day 19% 1.4E-03 lb/day 56% 2.0E-03 lb/day 76% Yes 24-Hour
Management
Need
6.7[2] ac-ft 100% 0 ac-ft 0% 0.1 ac-ft 0.9% 1.9 ac-ft 29% 5.2 ac-ft 77% 7.2 ac-ft 100 % Yes
DC-N-RB
(DC Freshwater)
Total Copper 3.3 lb/day 81% 1.6 lb/day 39% 0.04 lb/day 0.9% 0.5 lb/day 13% 1.3 lb/day 32% 3.4 lb/day 85% Yes Total Lead CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance n/a Total Zinc 16.3 lb/day 74% 0 lb/day 0% 0.2 lb/day 1.0% 4.1 lb/day 19% 12.4 lb/day 56% 16.7 lb/day 76% Yes E. coli 53.0 1012
MPN/ 35% 0 1012MPN/y 0% 1.1 1012MPN/y 0.7% 49.5 1012MPN/yr 33% 19.1 1012MPN/yr 13% 69.7 1012
MPN/
yr
47% Yes
Benzo[a]pyre
ne
5.2 E-03 lb/day 67% 0 lb/day 0% 7E-05 lb/day 1.0% 2E03 lb/day 25% 4E-03 lb/day 48% 6E-03 lb/day 73% Yes 24-Hour
Management
Need
22.3[2] ac-ft 100% 0 ac-ft 0% 0.2 ac-ft/ 1.0% 15.5 ac-ft 69% 8.3 ac-ft 37% 24.0 ac-ft 100 % Yes
DC-S
(DC
FreshwateTotal Copper 3.0 lb/day 76% 1.5 lb/day 39% 0.1 lb/day 0.9% 0 lb/day 0% 1.4 lb/day 36% 3.0 lb/day 76% Yes Total Lead CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance n/a Total Zinc 11.9 lb/day 65% 0 lb/day 0% 0.2 lb/day 1.0% 0 lb/day 0% 11.7 lb/day 64% 11.9 lb/day 65% Yes
App D. Beach Cities EWMP RAA Report 52 May 2021
Analysis
Region[1]
Pollutant
Final Target Load
Reduction
BMP Load Reduction Summary
Non-Structural BMP LID Redevelopment Regional Project Distributed Projects Total Load Reduction Assurance
Achieved?[3]
Absolute % Absolute % Absolute % Absolute % Absolute % Absolute % E. coli 179.1 1012
MPN/y 45% 0 10^12 MPN/yr 0% 2.2 1012 MPN/yr 0.6% 0 10^12 MPN/yr 0% 176.9 10^12 MPN/yr 45% 179.1 1012
MPN/
yr
45% Yes
Benzo[a]pyre
ne
5.5 E-03 lb/day 55% 0 lb/day 0% 9.4E-05 lb/day 0.9% 0 lb/day 0% 5.5E-03 lb/day 54% 5.5E-03 lb/day 55% Yes 24-Hour
Management
Need
22.2[2] ac-ft 100% 0 ac-ft 0% 0.3 ac-ft 1.1% 0 ac-ft 0% 21.9 ac-ft 99% 22.2 ac-ft 100 % Yes
DC-TL
(DC Estuary and Torrance Lateral)
Total Copper 10.4 lb/day 91% 4.5 lb/day 39% 0.1 lb/day 1.0% 0 lb/day 0% 5.8 lb/day 51% 10.4 lb/day 91% Yes Total Lead CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance n/a Total Zinc 57.4 lb/day 88% 0 lb/day 0% 0.6 lb/day 1.0% 0 lb/day 0% 56.8 lb/day 87% 57.4 lb/day 88% Yes Total
Cadmium 0.13 lb/day 87% 0 lb/day 0% 1.0E-3 lb/day 0.7% 0 lb/day 0% 0.13 lb/day 87% 0.13 lb/day 87% Yes E. coli 175.3
1012
MPN/y
r
49% 0 1012
MPN/y 0% 2.1 1012MPN/yr 0.6% 0 1012MPN/yr 0% 173.2 1012MPN/yr 49% 175.3 1012
MPN/
yr
49% Yes
Benzo[a]pyre
ne
1.3 E-02 lb/day 67% 0 lb/day 0% 2E-04 lb/day 0.9% 0 lb/day 0% 1.3E-02 lb/day 66% 1.3E-02 lb/day 67% Yes Total PAHs CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance n/a 24-Hour
Management
Need
35.8[2] ac-ft 100% 0 ac-ft 0% 0.3 ac-ft 1.0% 0 ac-ft 0% 35.5 ac-ft 99% 35.8 ac-ft 100 % Yes
Total DDT CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance n/a Total PCB CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance n/a [1] Corresponding receiving water is also listed. DC = Dominguez Channel. [2 ]
Please see Table 13 on how the representative 24-hour management volume was selected for each analysis region. [3] Reasonable assurance is achieved if cumulative load reduction is greater than the TLR
App D. Beach Cities EWMP RAA Report 53 May 2021
Note: Due to comparatively low volumes, LID redevelopment is not shown in the figure Figure 14. 24-Hour Management Volume Breakdown in Dominguez Channel WMA
App D. Beach Cities EWMP RAA Report 54 May 2021
Figure 15. 24-Hour Management Volume Mapping in Dominguez Channel WMA
App D. Beach Cities EWMP RAA Report 55 May 2021
10. DRY WEATHER RAA RESULT
The dry weather RAA was performed in accordance with the semi-quantitative approach outlined in Section 4.2. A summary of the analysis is shown in Table 19. WMA-specific discussion of the dry weather RAA is presented in the following subsections.
Table 19. Dry Weather RAA Summary for Dominguez Channel WMA.
WMA Analysis
Region
Is non-exempt dry
weather flow
currently non-existent
and/or sufficiently
treated or diverted?
Are sufficient
structural BMP
proposed to intercept
100% of dry weather
runoff?
Is dry weather
reasonable
assurance
demonstrated?
Santa Monica Bay All Yes n/a Yes
Dominguez
Channel
(including
Torrance Lateral)
DC-N-RB Yes Proposed Yes
DC-N-MB Yes Proposed Yes
DC-S Yes Proposed Yes
DC-TL Yes Proposed Yes
10.1. Santa Monica Bay WMA
According to monitoring and observation data collected through the Beach Cities CIMP, existing low flow diversions consistently intercept and divert 100% of non-exempt dry weather MS4 flow from the receiving water. Therefore, reasonable assurance of compliance during dry weather is demonstrated for the Beach Cities Santa Monica Bay WMA.
10.2. Dominguez Channel WMA
For Beach Cities DC (including Torrance Lateral) WMA, a dry weather RAA was performed in accordance with the approach outlined in Section 4.2. The Beach Cities WMG has attempted to eliminate non-exempt dry weather MS4 discharges using a suite of structural BMPs and non-structural source controls (e.g., water conservation incentives, enhanced IDDE efforts, enhanced education/outreach, and inspection/enforcement to prevent sources of non-stormwater flow). To date, monitoring has shown that the WMG has been successful at this endeavor, and although dry weather flows do still exist in some outfalls draining to the DC, particularly within Torrance Lateral, the WMG has successfully demonstrated that these discharges are considered conditionally exempt.
In parallel to the ongoing effort of fully eliminating non-exempt dry weather MS4 discharges, the Beach Cities WMG has also planned to utilize structural BMPs to intercept additional dry weather runoff. The Alondra Park Stormwater Capture Project will intercept and capture 100% of dry weather runoff from both the DC-N-RB and DCPage 2511 of 2658 App D. Beach Cities EWMP RAA Report 56 May 2021
N-MB analysis regions. In addition, the City of Torrance plans to provide significant parkway BMP retrofits throughout the DC-S and DC-TL analysis regions, with a particular focus on areas that consistently discharge to the Dominguez Channel during dry weather. For the purposes of this EWMP, and consistent with the original EWMP, it has been assumed that such parkway BMP retrofits will be sufficient to handle the dry weather bacteria loads tributary to the discharge locations. Therefore, reasonable assurance of compliance during dry weather is demonstrated for the Beach Cities Dominguez Channel WMA.
App D. Beach Cities EWMP RAA Report 57 May 2021
11. CONCLUSIONS
To update the RAA for the updated Beach Cities EWMP, a modeling approach that utilized WMMS 2.0 was developed to conform to the original RAA guideline developed by the LARWQCB. The updated RAA:
1. Applied an acceptable model tailored to the Beach Cities WMG based on available outfall and receiving water data collected through June 2020.
2. Calculated TLRs necessary to achieve applicable compliance targets.
3. Demonstrated that the existing and proposed suite of projects will attain the TLRs.
App D. Beach Cities EWMP RAA Report 58 May 2021
12. REFERENCES
Beach Cities WMG (Watershed Management Group). 2020. Annual Watershed Report – Reporting Year 2019 – 20.
Clary, J., Pitt, R., Steets, B. eds. Pathogens in Urban Stormwater Systems. Urban Water Resources Research Council Pathogens in Urban Stormwater Systems Technical Committee. ASCE Accessed Jan 2021 from <link>
Schiff, K.C., J.F. Griffith, G. Lyon. 2005. Microbiological water quality at reference beaches in southern California during wet weather. Technical Report 448. Southern California Coastal Water Research Project. Westminster, CA.
LACFCD (Los Angeles Flood Control District). 2020a. WMMS 2.0 Average and 90th Percentile Water Year Simulation. Accessed December 2020 from <link> LACFCD (Los Angeles Flood Control District). 2020b. WMMS 2.0 Phase II Report:
BMP Model and Optimization Framework. Accessed December 2020 from <link> LACFCD (Los Angeles Flood Control District). 2020c. WMMS 2.0 Average & 90th Percentile Water Year. Accessed January 2021 from <link> LARWQCB (Los Angeles Regional Water Quality Control Board). 2011. Attachment A to Resolution No. R11-009. Amendment to the Water Quality Control Plan - Los Angeles Region to Incorporate the TMDL for Toxic Pollutants in Dominguez Channel and Greater Los Angeles and Long Beach Harbor Waters. Adopted May 5 LARWQCB (Los Angeles Regional Water Quality Control Board). 2012. Attachment A to Resolution No. R12-009. Amendment to the water quality control plan for the Los Angeles Region to revise the TMDL for bacteria in the Malibu Creek Watershed. Adopted June 7.
LARWQCB (Los Angeles Regional Water Quality Control Board). 2014a. Guidelines for Conducting Reasonable Assurance Analysis in a Watershed Management Program, Including an Enhanced Watershed Management Program. Los Angeles, CA.
LARWQCB (Los Angeles Regional Water Quality Control Board). 2014b. Water Quality Control Plan: Los Angeles Region Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties. Accessed January 2021 from <link>.
SWRCB (State Water Resources Control Board). 2020. In the Matter of Review of Approval of Watershed Management Programs and an Enhanced Watershed
App D. Beach Cities EWMP RAA Report 59 May 2021
Management Program Submitted Pursuant to Los Angeles Regional Water Quality Control Board Order R4-2012-0175. SWRCB/OCC FILES A-2386, A-2477 & A-2508.
Sacramento, CA.
TDC Environmental. 2013. Estimate of Urban Runoff Copper Reduction in Los Angeles County from the Brake Pad Copper Reductions Mandated by SB 346. Prepared for Richard Watson & Associates, Inc. Accessed January 3, 2021.
Attachment D.1
Supplementary Calibration Exhibits
Water Quality Calibration
Bacteria
Water Quality Calibration
Total Cadmium
Water Quality Calibration
Total Copper
Water Quality Calibration
Total Lead
Water Quality Calibration
Total Copper
Appendix E
Project Concept
Fact Sheets
The City of Manhattan Beach (City) is implementing the 28th Street Storm Drain Infiltration Project (Project) to improve water quality at the beach and in Santa Monica Bay by reducing discharges from the storm drain system. The Project will capture and infiltrate runoff and is split into two phases. Phase 1 includes approximately 48 drywells at the 26th Street Parking Facility and Phase 2 includes an infiltration system on the beach.
The 26th Street Parking
Facility is one block East of
Manhattan Beach and
bounded by 26th Street, 27th
Street, Manhattan Avenue,
and Ocean Drive. Surface
runoff from the tributary
area enters the storm drain
network and discharges to
Santa Monica Bay.
Existing Site Conditions
Infiltration
Bypass
27th Street
Storm
Drain
Routed Flow
Impervious
Area to 28th
Street
Storm
Drain
Infiltration: Drywells
*Products shown above were used as examples for sizing and cost analyses; other equivalent treatment systems may be used.
Proposed BMP Project
City: Manhattan Beach Latitude: 33.894050 Longitude: -118.416294 Phase 1 BMP Treatment Process
Planning- Level Cost
Estimate 1
Tributary Area (ac) 1,520 24-Hour Treatment
Volume (ac-ft) 83.11
No. of Proposed
Drywells 48
Bacteria Load
Reduction During
Critical Condition
202 x 1012 MPN/year
(66% of Baseline Bacteria Load)
Capital Cost
Construction
$16M
Planning &
Design $1.7M
Annual Costs
O&M
$155k
Monitoring
$50k
Multiple Benefits
Dry Well Typical Details
Site Configuration
Model Design & Performance
Community Investment Benefits
• Improved flood management and
water quality
• Enhanced beach conditions
• Reduced potential for beach
closures
• Create opportunities for education
and outreach in local communities
Nature-Based Solutions
• Provide an enhanced
environment for marine life
• Improve 26th Street Parking with
native landscaping and
permeable pavement
• Reduce impermeable area
flowing to existing drainage
system
28th Street Storm Drain Infiltration
Project
1Estimates based on drywells.
2Monitoring is only required for 3 years.
Phase 2 BMP Treatment Process
Infiltration
Bypass
Santa
Monica
Bay
Routed Flow
Impervious
Area 27th &
28th Street
Storm
Drain
Infiltration System
28th Street Storm Drain Infiltration Project
June 2021
2 1 Phase 1 only
This project will improve the three flood control basins to reduce bacteria levels in receiving waters during the dry season and to capture the 85th percentile storm event. The project deepens the Henreitta and Entradero Basins to provide additional detention capacity, adds passive wetland treatment and drywells at all basins to increase the runoff management capacity. The project also includes a variety of efforts to improve the recreational opportunities and aesthetics of the parks.
Herondo Drain collects stormwater from portions of the cities of Torrance, Redondo Beach, Hermosa Beach, and Manhattan Beach. Three basins within Torrance that are connected to the Herondo Drain including Amie, Henrietta, and Entradero Basins.
Existing Site Conditions
Infiltration
Bypass Herondo
Storm
Routed Flow Drain
Impervious
Surface
Runoff to
Storm
Drain
Basin
*Products shown above were used as examples for sizing and cost analyses; other equivalent treatment systems or products may be used.
Proposed BMP Project
City: Torrance Latitude: 33.853378 Longitude: -118.371828 BMP Treatment Process
Planning- Level Cost
Estimate 1
Total Tributary Area
(ac) 1,407 24-Hour Capture
Volume (ac-ft) 46.5*
Basin Footprint (ac)
4.3 (Amie)
6.9 (Henrietta)
24 (Entradero)
Effective Drawdown
Rate (in/hr) 0.8
Capital Cost
Construction
$4.5M
Planning &
Design $735k
Annual Costs
O&M
$30k
Monitoring
$80k
Multiple Benefits
Typical Details
Site Configuration
Model Design & Performance
Community Investment
Benefits
• Improved flood management and
water quality
• Enhanced park space via multipurpose recreational area. • Create new recreational
opportunities via walking trail
Nature-Based Solutions
• Implements natural processes to
slow, detain, capture, and
infiltrate water
• Utilize natural vegetation
• Reduce directly connected
impermeable area flowing to
existing drainage system
Torrance Basins Enhancement &
Expansion Project
1Costs from SCW application
2Monitoring is only required for 3 years.
*Equivalent to the 85th percentile, 24-hour design storm runoff from the entire drainage area.
Torrance Basins Enhancement & Expansion
Project
June 2021
2
The Fulton Playfield Infiltration Project proposes to add infiltration elements to the existing flood control basin to transform it into a multi-benefit regional project. This will enhance the flood control capacity of the existing basin while adding significant water quality benefits through volume loss via infiltration. Infiltration will be accomplished using drywells. The project will provide full capture of dry weather volume and controlled wet weather releases with improved inlet-outlet control structures to manage and optimize the storage and infiltration capacity of the project. Park enhancements including outdoor exercise and playground equipment are also planned.
Adding features that can better capture runoff from the adjacent school along with green water quality features such as
bioretention and ocean friendly gardens in the park and along Rindge Lane will provide additional benefits to the community.
The site is an open green
space in the City of
Redondo Beach. The park
includes a 1.25-acre
recreational field with an
existing underground
storage basin that has
280,000 gallons of passive
storage beneath the
western half of the park.
Existing Site Conditions
Infiltration
Bypass Existing
Storm
Routed Flow Drain
Impervious
Area Draining
to the
Existing
Underground
Storage Basin
Infiltration:
13 Drywells
*Drywells were used for sizing and cost analyses; other equivalent products or treatment systems may be used but have not been included in costs.
Proposed BMP Project
City: Redondo Beach Latitude: 33.861774 Longitude: -118.372308 BMP Treatment Process
Planning- Level Cost
Estimate 1
Tributary Area (ac) 465 24-Hour Treatment
Volume (ac-ft) 28.6
No. of Proposed
Equivalent Drywells 13 Treatment Rate (cfs) 13
Bacteria Load
Reduction During
Critical Condition
76 x 1012 MPN/year
(27% of Baseline Bacteria Load)
Capital Cost
Construction
$2.0M
Planning &
Design $395k Annual Costs
O&M
$30k
Monitoring
$14k
Multiple Benefits
Typical Details
Site Configuration
Model Design & Performance
Community Investment Benefits
• Improved flood management
• Enhanced park via playground
• Cooperation with greening of Valor
Christian Academy
• Potential for recreational workout
stations per community
preferences
Nature-Based Solutions
• Utilize natural vegetation and
other nature-based processes
such as ocean friendly gardens to
capture, slow, and filter runoff
• Reduce directly connected
impermeable area flowing to
existing drainage system
Fulton Playfield Infiltration Project
1Estimates based on representative drywells and
previous project estimates for piping.
* Nature-based BMPs may 2Monitoring is only required for 3 years. include bioretention, pervious pavement, and biofilters.
Fulton Playfield Infiltration Project
June 2021
2
Existing Site Conditions
*Products shown above were used as examples for sizing and cost analyses; other equivalent products or treatment systems may be used.
Hermosa Beach Distributed
Drywells
Infiltration
Bypass
Existing
Storm
Drain
Routed
Flow
Impervious
Surface
Runoff Infiltration:
Drywells
Overflow
Proposed BMP Project
City: Hermosa Beach Latitude: 33.857054 Longitude: -118.390251 BMP Treatment Process
Planning- Level Cost
Estimate 1
Multiple Benefits
Typical Detail
Site Configuration
Model Design & Performance
Untreated surface runoff enters the storm drain network through surface catch basins in this area as the neighborhood transitions from residential in the higher areas to commercial areas near the Pacific Coast Highway (PCH). A typical example is shown on 3rd Street, east of PCH.
The City of Hermosa Beach is planning to implement a series of drywells east of PCH between 1st Street and 10th Street to capture stormwater and dry weather flows within 118 acres of the Herondo Drain (SMB-6-1) watershed. The drywells will be placed strategically upstream of existing catch basins to maximize infiltration.
Capital Cost Construction of
Drywells
$1.4M
Planning &
Design $250k
Annual Costs
O&M
$35k
Monitoring
$25k
1Estimates based on drywells.
2Monitoring only required for 3 years.
2 Tributary Area (ac) 118 24-Hour Treatment
Volume (ac-ft) 8.1
No. of Proposed
Drywells 11 Treatment Rate (cfs) 11
Pollutant Load
Reduction Bacteria 21.6 x 1012 MPN/year
(7.7% of Baseline Bacteria Load)
Community Investment Benefits
• Improved flood management
Nature-Based Solutions
• Utilize natural vegetation and other nature-based processes to slow, detain, capture, and filter water
• Reduce directly connected impermeable area flowing to existing drainage system
Source: Google Maps
Hermosa Beach Distributed Drywells
Existing Site Conditions
*Products shown above were used as examples for sizing and cost analyses; other equivalent infiltration systems may be used.
Redondo Beach Herondo
Distributed Infiltration Project
Infiltration
Bypass
Existing
Storm
Drain Routed
Flow
Impervious
Surface
Runoff
Infiltration:
Targeted
Infiltration
Systems
Overflow
Proposed BMP Project
City: Redondo Beach Latitude: Various Longitude: Various BMP Treatment Process
Planning- Level Cost
Estimate 1
Typical Detail
Site Configuration
Model Design & Performance
Surface runoff enters the storm drain network through various catch basins, as seen below on Armour Lane. The drainage area is mostly residential, with limited commercial development.
The City of Redondo Beach is planning to implement a series of targeted infiltration BMPs to collect surface runoff from a 342- acre area of Redondo Beach within the Herondo Storm Drain watershed (SMB-6-1). The infiltration BMPs will be placed strategically upstream of existing catch basins to maximize infiltration; see site configuration map for potential infiltration areas. Drywells are one example of a potential infiltration BMP.
Capital Cost
Construction
$2.8M
Planning &
Design $460k
Annual Costs
O&M
$70k
Monitoring
$55k
1Estimates based on drywells.
2Monitoring only required for 3 years.
2 Tributary Area (ac) 342 24-Hour Treatment
Volume (ac-ft) 16.3
No. of Proposed
Infiltration BMPs 22 Treatment Rate (cfs) 22
Pollutant Load
Reduction Bacteria 43.6 x 1012 MPN/year
(16% of Baseline Bacteria Load)
Multiple Benefits
Community Investment Benefits
• Improved flood management
Nature-Based Solutions
• Utilize natural vegetation and other nature-based processes to slow, detain, capture, and filter water
• Reduce directly connected impermeable area flowing to existing drainage system
Redondo Beach Herondo Distributed
Infiltration Project
The Glen Anderson Park Regional Infiltration Project will provide infiltration via a single underground infiltration basin, a series of drywells, or a combination of both. Wet and dry weather runoff from City of Redondo Beach travels north in the 78-inch reinforced concrete pipe storm drain (LACFCD BI 0729) that runs under Vail Ave. The Project will divert runoff from this storm drain into a pretreatment system, before flows continue into the infiltration-based BMP.
Glen Anderson Park is a 12.4-acre multi-use park in the City of Redondo Beach, located adjacent to Lincoln Elementary School between Rindge Lane, Farrell Avenue, and Vail Avenue. The park has significant green space in addition to baseball fields, tennis courts, basketball courts, and a playground.
Existing Site Conditions
Infiltration
Bypass
Existing
Storm
Drain Flow Routed
Impervious
Area Draining
to Vail
Avenue
Infiltration
*Products shown above were used as examples for sizing and cost analyses; other equivalent products or treatment systems may be used.
Glen Anderson Park Regional
Infiltration Project
Overflow
Proposed BMP Project
City: Redondo Beach Latitude: 33.882775 Longitude: -118.370948 BMP Treatment Process
June 2021
Planning- Level Cost
Estimate 1
Multiple Benefits
Typical Details
Site Configuration
Model Design & Performance
Capital Cost
Construction
$2.8M
Planning & Design
$460k
Annual Costs
O&M
$65k
Monitoring
$50k
Tributary Area (ac) 483 24-Hour Treatment
Volume (ac-ft) 9.4
Potential Footprint for
Infiltration (ac) 0.45 Design Treatment
Rate (cfs) 20
Pollutant Load
Reduction Range
(% of Baseline Load)
Copper 81%
Zinc 74%
Bacteria 44%
Benzo [a] pyrene 67%
Community Investment
Benefits
• Improved flood management
• Enhanced park
Nature-Based Solutions
• Utilize natural vegetation and
other nature-based processes to
slow, detain, capture, and filter
water
• Reduce directly connected
impermeable area flowing to
existing drainage system
1Estimates based on representative drywells and previous project estimates for piping.
2Monitoring only required for 3 years.
Glen Anderson Park Regional Infiltration Project
2
Existing Site Conditions
*Products shown above are referenced as examples for sizing and cost analyses; other equivalent products or treatment systems may be used.
Manhattan Beach Dominguez Channel
Distributed Infiltration Project
Infiltration
Bypass
Existing
Storm
Drain
Routed
Flow
Surface
Runoff from
Impervious
Surfaces Infiltration Overflow
Proposed BMP Project
City: Manhattan Beach Latitude: 33.898811 Longitude: -118.381272 BMP Treatment Process
Manhattan Beach Dominguez Channel
Distributed Infiltration Project
June 2021
Planning- Level Cost
Estimate 1
Tributary Area (ac) 225 24-Hour Treatment
Volume (ac-ft)* 5.2
Pollutant Load
Reduction Range
(% of Baseline Load)
Copper 83%
Zinc 77%
Bacteria 43%
Benzo [a] pyrene 71%
Typical Detail
Site Configuration
Model Design & Performance
The majority of Manhattan Beach’s tributary area within the Dominguez Channel Watershed flows through a 27-inch storm drain under 33rd St before turning south down Aviation Blvd. The storm drain is downstream of a detention pond at a nearby golf course.
The City of Manhattan Beach is planning to implement
infiltration practices along 33rd Street and/or Aviation Blvd to capture and infiltrate stormwater flows from a 255-acre mixeduse area of Manhattan Beach and within the Dominguez Channel watershed. Multiple types of BMPs are under
consideration to provide required treatment.
Source: Google Maps
Capital Cost
Construction
$1.4M
Planning &
Design $250k
Annual Costs
O&M
$35k
Monitoring
$25k 1Estimates based on representative drywells.
2Monitoring only required for 3 years.
2 Multiple Benefits
Community Investment Benefits
• Improved flood management
Nature-Based Solutions
• Utilize natural vegetation and other nature-based processes to slow, detain, capture, and filter water
• Reduce directly connected impermeable areas flowing to existing drainage system
*Includes static storage capacity and 24-hour infiltration capacity
Existing Site Conditions
*Products shown above were used as examples for sizing and cost analyses; other equivalent products may be used.
Redondo Beach Dominguez Channel
Distributed Infiltration Project
Infiltration
Bypass
Existing
Storm
Drain
Routed
Flow
Impervious
Surface
Runoff Infiltration
BMPs
Overflow
Proposed BMP Project
City: Redondo Beach Latitude: 33.882775 Longitude: -118.370948 BMP Treatment Process
Planning- Level Cost
Estimate 1
Typical Detail
Site Configuration
Model Design & Performance
Surface runoff enters the storm drain network through a variety of surface catch basins, as seen below on Redondo Beach Blvd within the drainage area.
The City of Redondo Beach is planning to implement a series of targeted and distributed infiltration BMPs to collect surface runoff from a portion of a 292-acre industrial area within the Dominguez Channel watershed. Implementation of targeted infiltration BMPs will fully capture dry weather flows in addition to treating stormwater flows from the tributary areas. The infiltration BMPs will be placed strategically upstream of existing catch basins; see site configuration map for potential infiltration areas. Drywells are one example of a potential infiltration BMP.
Capital Cost
Construction
$1.8M
Planning &
Design $320k
Annual Costs
O&M
$40k
Monitoring
$30k
1Estimates based on drywells.
2Monitoring only required for 3 years.
2 Tributary Area (ac) 292 24-Hour Treatment
Volume (ac-ft) 8.3
No. of Proposed
Infiltration BMPs* 14 Treatment Rate (cfs) 14
Pollutant Load
Reduction Range
(% of Baseline Load)
Copper 81%
Zinc 74%
Bacteria 44%
Benzo [a] pyrene 67%
Multiple Benefits
Community Investment Benefits
• Improved flood management
Nature-Based Solutions
• Utilize natural vegetation and other nature-based processes to slow, detain, capture, and filter water
• Reduce directly connected impermeable area flowing to existing drainage system
Redondo Beach Dominguez Channel
Distributed Infiltration Project
The City of Torrance is committed to implementing distributed parkway BMPs within the Dominguez Channel watershed
management area (analysis regions Dominguez Chanel – South [DCS] and the Torrance Lateral draining to the Dominguez Chanel [DCTL]) to meet the RAA requirements. Specific BMP technologies are currently being evaluated to best address pollutants of concern, but may include catch basin inlet filters, bioretention units, or drywells, where deemed feasible. The City of Torrance has applied for Safe Clean Water funding under the Technical Resources Program to prioritize catch basins for implementation. Collectively, the Torrance Parkway BMPs will be implemented by the City of Torrance at a level that meets the EWMP compliance requirements.
Infiltration
Bypass
Existing
Storm
Drain
Routed
Flow
Stormwater
and Dry
Weather
Runoff
Distributed BMPs
(inlet filters,
bioretention
units, or drywells)
*Products shown above were used as examples for sizing and cost analyses; other equivalent treatment systems may be used.
Proposed BMP Project
City: Torrance Latitude: Various Longitude: Various
BMP Treatment Process Multiple Benefits
Typical Details
BMP Coverage Overview
Design Criteria for EWMP Compliance
Community Investment Benefits
• Improved flood management and
water quality
• Reducing local heat island effect
and increasing shade
• Increasing vegetation at site
locations to increase carbon
reduction and improve air quality
Nature-Based Solutions
• Implement natural processes to
slow detain, capture, and infiltrate
runoff
• Utilize natural vegetation
• Reduce impermeable area flowing
to existing drainage system
Torrance Parkway BMPs
Analysis
Region
24-Hour
Management
Volume
(ac-ft)
Pollutant Load Reduction
(% of Baseline Load)
Copper Zinc E.coli Benzo
[a]pyrene
DC-S 21.9 36% 64% 45% 54%
DC-TL 35.4 51% 87% 48% 66%
Bioretention
Drywell
Catch Basin Inlet Filter
DC-S
DC-TL
Treated
Flow
Torrance Parkway BMPs
Appendix F
Background
Information on
the LACFCD
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BACKGROUND INFORMATION ON THE LACFCD
This attachment provides background information pertaining to the Los Angeles County Flood Control District (LACFCD), and their involvement in the Beach Cities Enhanced Watershed Management Program (EWMP) Plan.
In 1915, the Los Angeles County Flood Control Act established the LACFCD and empowered it to manage flood risk and conserve stormwater for groundwater recharge. In coordination with the United States Army Corps of Engineers, the LACFCD developed and constructed a comprehensive system that provides the regulation and control of flood waters through the use of reservoirs and flood channels. The system also controls debris, collects surface storm water from streets, and replenishes groundwater with stormwater and imported and recycled waters. The LACFCD covers the 2,753 square-mile portion of Los Angeles County south of the east-west projection of Avenue S, excluding Catalina Island. It is a special district governed by the County of Los Angeles Board of Supervisors, and its functions are carried out by the Los Angeles County Department of Public Works.
For the Beach Cities EWMP, the LACFCD service area is shown in Figure 1.
Unlike cities and counties, the LACFCD does not own or operate any municipal sanitary sewer systems, public streets, roads, or highways. The LACFCD operates and maintains storm drains and other appurtenant drainage infrastructure within its service area. The LACFCD has no planning, zoning, development permitting, or other land use authority within its service area. The Permittees that have such land use authority are responsible under the MS4 Permit for inspecting and controlling pollutants from industrial and commercial facilities, development projects, and development construction sites. (MS4 Permit, Part II.E, page 14.) The MS4 Permit language clarifies the unique role of the LACFCD in storm water management programs: “[g]iven the LACFCD’s limited land use authority, it is appropriate for the LACFCD to have a separate and uniquely-tailored storm water management program. Accordingly, the storm water management program minimum control measures imposed on the LACFCD in Part VI.D of this Order differ in some ways from the minimum control measures imposed on other Permittees. Namely, aside from its own properties and facilities, the LACFCD is not subject to the Industrial/Commercial Facilities Program, the Planning and Land Development Program, and the Development Construction Program. However, as a discharger of storm and non-storm water, the LACFCD remains subject to the Public Information and Participation Program and the Illicit Connections and Illicit Discharges Elimination Program. Further, as the owner and operator of certain properties, facilities and infrastructure, the LACFCD remains subject to requirements of a Public Agency Activities Program.” (MS4 Permit, Part II.F, page 15).
Consistent with the role and responsibilities of the LACFCD under the MS4 Permit, the EWMPs and Coordinated Integrated Monitoring Programs (CIMPs) reflect the opportunities that are available for the LACFCD to collaborate with Permittees having land use authority over the subject watershed area. In some instances, the opportunities are minimal; however, the LACFCD remains responsible for compliance with certain aspects of the MS4 Permit as discussed above.
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In some instances, in recognition of the increased efficiency of implementing certain programs regionally, the LACFCD has committed to responsibilities above and beyond its obligations under the 2012 MS4 Permit. For example, although under the 2012 MS4 Permit the Public Information and Participation Program (PIPP) is a responsibility of each Permittee, the LACFCD is committed to implementing certain regional elements of the PIPP on behalf of all Permittees at no cost to the Permittees. These regional elements include:
• Maintaining a countywide hotline (888-CLEAN-LA) and website (www.888cleanla.com) for public reporting and general stormwater management information. Each Permittee can utilize this hotline and website for public reporting within its jurisdiction. • Broadcasting public service announcements and conducting regional advertising campaigns. • Facilitating the dissemination of public education and activity specific stormwater pollution prevention materials.
• Maintaining a stormwater website.
The LACFCD will continue to implement these elements on behalf of all Permittees during the current MS4 Permit term. With the LACFCD handling these elements regionally, Permittees can better focus on implementing local or watershed-specific programs, including student education and community events, to fully satisfy the PIPP requirements of the 2012 MS4 Permit.
Similarly, although water quality monitoring is a responsibility of each Permittee under the 2012 MS4 Permit, the LACFCD is committed to implementing certain regional elements of the monitoring program to help increase the efficiency and effectiveness of this program. These efforts include:
• Conducting monitoring at the seven existing mass emissions stations required under the previous Permit. This is in addition to the LACFCD’s contribution to individual CIMP groups. • Participating in the Southern California Stormwater Monitoring Coalition’s Regional Bioassessment Program on behalf of all Permittees.
In addition, the LACFCD is committed to developing tools and programs that benefit all Permittees in Los Angeles County. Some of these efforts include the following:
• The development and maintenance of Watershed Reporting Adaptive Management & Planning System (WRAMPS), which assists permittees in preparing their MS4 annual report. • The development and maintenance of Watershed Management Modeling System (WMMS), which is the primary model being used by watershed groups to meet reasonable assurance analysis (RAA) requirements or watershed modeling requirements in the development of their Watershed Management Program (WMP) or Enhanced Watershed Management Program (EWMP).
• The management/administration of Safe, Clean Water (SCW) Program, which provides a dedicated revenue source for all municipalities, including MS4 permittees, to implement multi-benefit stormwater projects and programs that improve water quality and either increase water supply through augmenting local groundwater and recycled water use or enhance communities.
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LACFCD Territory
Appendix G
Potential Funding
Sources and Financial
Strategy
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POTENTIAL FUNDING SOURCES AND FINANCIAL STRATEGY
The availability of funds is critical for the successful implementation of the Enhanced Watershed Management Plan (EWMP). This appendix provides an overview of potentially available funding sources for programs and projects proposed in the EWMP. The funding sources included in this section for consideration are Measure W (Safe, Clean Water Program), grants, interagency partnerships, bonds, State Revolving Funds, local funding opportunities, and public private partnerships. A summary of potential financial approaches for the Beach Cities Watershed Management Group (WMG) is provided in Table G-1, with additional details and discussion provided in the sections following.
Table G-1. Funding Approach Summary
Approach
Funding
Type Limitations
Potential Significance
(with Respect to
Overall Funding)
Safe, Clean
Water
Regional
Program
New
Revenue
• Highly Competitive
• Application preparation requires
significant effort/cost High
Grants New
Revenue
• Highly Competitive
• No guarantee of funding accessibility
• Infrastructure projects only
• Application preparation/submission
requires significant effort/cost
• Can only be used to pay for
infrastructure-related projects
• O&M costs are typically excluded
Medium
ProjectSpecific
Interagency
Partnerships
New
Revenue
• Requires coordination between agencies
• Varying project implementation
schedules between agencies limit the
viability of such an option
High
Local Bond
Issuance Financing
• GO bonds require approval by voters.
• Revenue bond requires to be backed by a
revenue stream
• There is a financing cost
• Infrastructure projects only
• O&M costs are typically excluded
Low
State
Revolving
Funds
Financing
• Revenue stream is needed to obtain loans
• There is a financing cost
• Infrastructure projects only
• O&M costs are typically excluded
High
Local Public
Funding
Opportunities
New
Revenue
• Requires voter approval
• Infrastructure projects only (except for
stormwater fee)
High
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Approach
Funding
Type Limitations
Potential Significance
(with Respect to
Overall Funding)
• O&M costs are typically excluded (except
for stormwater fee)
Public Private
Partnership
Financing
• Revenue stream is needed to allow the
private partner to recover their cost as
well as provide return on investment
High
Direct
Subsidies /
Cost-Sharing
• Funding source is needed to fund a
subsidy program
• Some projects may underperform due to
poor project implementation, O&M, and
monitoring
Low
RECENT FUNDING EXAMPLES WITHIN THE BEACH CITIES
The Beach Cities WMG has been working cooperatively to pursue funding for projects identified in the EWMP by leveraging multiple sources of funding. In 2018, the Beach Cities WMG secured $2M in Prop 12 Santa Monica Bay Restoration Grant funding by the California Coastal Conservancy and the Santa Monica Bay Restoration Commission to fund the design and construction of the joint Beach Cities Green Street Project. The Prop 12 grant funding provides approximately 39% of the total estimated Beach Cities Green Street Project cost of $5.1M with the balance to be matched by the Beach Cities WMG agencies through other sources. With the City of Torrance serving as lead agency for this project, Beach Cities WMG has executed a cost sharing MOU to jointly fund the matching design and construction costs not covered by the grant funding. The MOU details each city’s share of the project’s preliminary engineering and final design cost and will be amended following final design to apportion construction costs. This joint project has also been submitted for FY2122 Safe Clean Water Regional Program Infrastructure funding for construction.
The Beach Cities WMG members are committed to developing feasibility studies and project concepts for regional projects to be eligible for SCW infrastructure funding and to be competitive for grant funding. The City of Torrance has funded the design of the Torrance Basins Expansion Regional Project with a completed preliminary engineering and feasibility study and final design now underway. The City of Manhattan Beach has funded the preliminary engineering and feasibility study of the Manhattan Beach 28th Street Storm Drain Infiltration Project. The Beach Cities WMG members also plan to leverage the SCW Regional funding with the Municipal Returns to construct and maintain capital projects. The County of Los Angeles is leading the Alondra Park Multi-Benefit Stormwater Capture Project and has completed a preliminary design report and feasibility study for the project and was awarded $30 million in SCW Infrastructure funding and $2.1 million in Prop 1 Stormwater Grant funding for design and construction, while Caltrans is proposing to contribute $15 million. The remaining $13 million in capital costs needed for the project is being provided by the County of Los Angeles. However, financial contributions and partnerships are being solicited from the tributary agencies including the Cities of Manhattan Beach and Redondo Beach, if they should desire to obtain additional capture volume credits above their baseline allocation.
In addition, each City in the Beach Cities WMG is committed to the pursuit of funding for individual
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distributed EWMP implementation projects and programs related to water quality improvement within their respective cities, as demonstrated by the following examples:
• The City of Hermosa Beach has committed financial support for identifying and implementing strategies for the establishment of sustainable revenue sources to manage stormwater programs and implement water quality improvement projects. In June 2015, the City of Hermosa Beach passed a sanitary sewer fee for residents and commercial property owners to fund maintenance and rehabilitation of its aging sewer infrastructure that had previously been funded from the City’s general fund. This dedicated fee for sanitary sewers will allow the City to redirect part of those general fund dollars for capital improvements and maintenance of the City’s storm drain system, including green street projects. The City won multiple awards for its Pier Avenue green street project and the City recently was awarded funding by the Coastal Conservancy to reconstruct a municipal parking lot to include a suite of storm water BMPs.
Additionally, the City recently completed the Hermosa Beach 8th Street Improvement Project, which includes multi-benefit improvements along 8th Street between Valley Drive and Hermosa Avenue.
• The City of Manhattan Beach is committed to implementing its Green Street Policy for capital improvement projects in the public right-of-way, has established a minimum runoff capture design goal for such projects, and will also use the EWMP to identify opportunities for green street BMP retrofits in high priority areas. The City is also currently in the process of updating its Storm Drain Master Plan, which will identify locations for multi-benefit projects to facilitate compliance with the MS4 Permit. City staff has an excellent track record and appreciates the support of its Council in the pursuit of funding for and implementation of green infrastructure as evidenced by two previous example projects: a 130,000 square feet porous concrete paving project on seven municipal parking lots, and the Greenbelt Infiltration Project installed within the linear greenbelt parkland. The City is currently pursuing regional project funding for the Manhattan Beach Infiltration Project at 28th Street via the Safe, Clean Water Regional Program. • The City of Redondo Beach’s green streets policy requires green street BMPs to be integrated with capital improvement projects (CIPs), thereby ensuring that BMPs be funded as part of ongoing and future CIPs. An example of this policy is the Redondo Beach Street Rehabilitation Project, which includes several street rehabilitation projects that include green street features such as porous gutters and crosswalks and drywells. Four of these street rehabilitation projects were completed during the 2019-2020 reporting year, addressing a combined 22 acres of green street target land use area within the Beach Cities WMG’s high priority Herondo watershed (SMB 6-1 analysis region). The City also incorporates the required addition of catch basin trash screening devices into street resurfacing projects such as the Esplanade Street Resurfacing Project. In addition, the City has a successful track record of pursuing and implementing water quality improvements grant funding such as the Alta Vista Diversion and Re-use Project and the Sapphire Storm Drain Diversion and Infiltration Project. • The City of Torrance has appropriated funding for retrofit of 3% of catch basin BMPs in the Dominguez Channel Watershed and appropriated annual funding to complete their trash
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management and reporting plan (TMRP) implementation by the end of 2016 (four years ahead of the total maximum daily load [TMDL] compliance deadline). In addition, the City’s green streets policy requires green street BMPs to be integrated with street improvement CIPs. The City of Torrance has an established record for pursuing grant funds for Storm Water Quality Projects. Completed projects include Bioswales for City Yard ($150,000 State grant funds), Machado Lake Trash TMDL Project ($1,000,000 State grant funds), and the Stormwater Basin Enhancement Project ($3,300,000 State grant funds and $300,000 Federal grant funds). The City is currently pursuing multiple project funding awards via the Safe, Clean Water Regional Program.
The foregoing examples illustrate the willingness of Beach Cities’ staff and elected officials to pursue funding for EWMP implementation projects. Additional sources of funding will also continue to be investigated, as described below.
MEASURE W (SAFE, CLEAN WATER PROGRAM)
Measure W was successfully passed by Los Angeles County voters in November 2018, creating the Safe, Clean Water Program to provide local, dedicated funding for stormwater and urban runoff to increase local water supply, improve water quality, and protect public health within the Los Angeles Basin. The program currently generates approximately $285 million per year. The majority of this funding goes directly back to the cities via two programs:
• The Municipal Program - 40% of the annual revenue goes directly to cities via the Municipal Program, with city-specific revenue proportional to the revenues generated within its boundaries. The Municipal Program funding can be used for eligible activities such as project development, design, construction, effectiveness monitoring, operations and maintenance (including operation and maintenance of projects built to comply with the MS4 Permit), as well as for other programs and studies related to protecting and improving water quality in lakes, rivers, and the ocean. The total annual municipal revenue projected for the Beach Cities WMG is approximately $3.4M. • The Regional Program – 50% of the annual revenue is divided across nine watershed areas (including the South Santa Monica Bay Watershed Area, which includes the Beach Cities Area), and is devoted to funding regional watershed-based projects, project concepts, and scientific studies. The South Santa Monica Bay Watershed Area is estimated to receive up to $18.4 million annually to fund regional projects and programs. Funding for multi-benefit regional projects includes design, permits, CEQA compliance, grant-writing, right-of-way and land acquisition, construction, and long-term operations and maintenance of the facilities.
To apply for regional infrastructure funds, a Safe, Clean Water Feasibility Study is required to be submitted to the local Watershed Area Steering Committee (WASC) for evaluation. The WASC, comprised of representatives from cities, agencies, and community stakeholders, reviews proposed projects and develops an annual Stormwater Investment Plan (SIP) for their Watershed Area that identifies recommendations for funding. Recommended projects included in SIPs will also be reviewed by a Scoring Committee and ultimately a Regional Oversight Committee for recommendation to the Board of Supervisors.
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The process to receive regional funding is competitive, as numerous projects across entire watershed areas are considered. However, funding is significant, consistent, and flexible to be spent on all phases of qualifying stormwater infrastructure projects. The Safe, Clean Water Program is therefore the primary funding mechanism the Beach Cities WMG will pursue to fund their various projects.
GRANT OPPORTUNITIES
Grants have historically been a backbone for financing stormwater projects. The majority of waterrelated grants are designated for flood control, drinking water, and watershed protection and most recent grants have preferences for projects that benefit underserved communities; very few grants are made available for the sole purpose of stormwater permit compliance. In order to increase the likelihood of successful grant funding, a stormwater project might need to be added to a larger project or program that serves different purposes and has different objectives rather than just for stormwater management. Thus, collaboration and coordination between stormwater agencies and other public agencies is important to increase accessible grant funding opportunities for stormwater projects.
Recent Federal infrastructure funding may expand the opportunities for grants and debt forgiveness loans. H.R. 1319 entitled “The American Rescue Plan Act of 2021” is primarily a COVID relief bill, but includes funding for water, sewer, and broadband infrastructure. This legislation does not distinguish stormwater as separate from water. This bill has been passed by both houses and signed into law by the President. The funds have been both authorized and appropriated and are currently being transferred to municipal governments. The funds can also be used by special districts, such as water and sewer districts.
S. 914 entitled “Drinking Water and Wastewater Infrastructure Act of 2021” reauthorizes both the Drinking Water SRF and Clean Water SRF programs at current levels with annual increases through 2026. It also reauthorizes the WIFIA funding at current levels through 2026. This bill has passed the Senate and appears to have sufficient support to pass the House and be signed into law by the President. While this bill authorizes the funding through 2026, it does not appropriate the funds.
The funds will be appropriated on an annual basis through the regular annual federal budget appropriations.
Many grant funds do not cover 100% of the project costs, but instead, cost sharing from local governments (as much as 50%) is required under grant provisions. Furthermore, grants typically cover only project capital costs, but do not provide funding to cover ongoing operations and maintenance, and replacement costs of the infrastructure. Thus, alternative funding sources would be needed to provide stable O&M revenues as well as costs for replacement for implemented projects. Table G-2 presents some potential grant opportunities available that the Beach Cities can apply to fund the EWMP projects.1
1 Some information in Table G-2 has not been updated due to a lack of update to relevant websites. This is not surprising in light of the global COVID-19 pandemic that is still ongoing. All the information presented in Table G-2 is subject to change.
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The Beach Cities WMG has expressed commitment to pursue grant opportunities. Numerous grants have been sought in the past by the Group, including multiple Prop 1 Coastal Conservancy grants, a Prop 68 Urban Flood Protection grant, Prop 12 Coastal Santa Monica Bay Restoration Grant funding by the California Coastal Conservancy, and multiple rounds of Prop 1 Stormwater Grant funding.
Since SB-985-Stormwater Resource Planning became effective in 2014, local governments have been required to develop a stormwater resource plan and be in compliance with provisions of SB985 in order to receive grants for stormwater and dry-weather runoff capture projects from a bond act approved by the voters after January 1, 2014. In 2017, the Group received approval that the Beach Cities EWMP serves as a functionally equivalent stormwater resources plan. See Appendix H for related details.
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Table G-2. Relevant Grant Opportunities
Program Department Purpose Ineligible Uses Funding Limits WaterSMART:
Water and Energy
Efficiency
Grants
US Bureau of
Reclamation
Projects should seek to conserve and
use water more efficiently, increase
the use of renewable energy, mitigate
conflict risk in areas at a high risk of
future water conflict, facilitate water
markets, or carry out other activities
to address climate related impacts on
water or prevent any water-related
crisis or conflict.
Normal operations,
maintenance, and replacement
(OM&R). OM&R is described as
system improvements that
replace or repair existing
infrastructure or function
without providing increased
efficiency or effectiveness of
water distribution over the
expected life of the
improvement. Construction of a
building.
FY 2021 Funding is awarded at one
of two levels:
Funding Group I:
Up to $500,000 per agreement for a
project up to 2 years.
Funding Group II: Up to
$2,000,000 for an agreement for up
to 3 years for a small number of
projects.
WaterSMART:
Cooperative
Water
Management
Program (CWMP)
Grants
US Bureau of
Reclamation
The purpose is to improve water
quality and ecological resilience and
to reduce conflicts over water
through collaborative conservation
efforts in the management of local
watersheds. CWMP provides funding
to watershed groups to encourage
diverse stakeholders to form local
solutions to address their water
management needs. Funding is
provided on a competitive basis for:
1) watershed group development and
watershed restoration planning, and
2) implementation of watershed
management projects.
Please visit the following
website for evaluation criteria:
http://www.usbr.gov/WaterSM
ART/cwmp/docs/
CWMPEvaluationCriteria.pdf
Phase I funds shall be used to
establish or enlarge a watershed
group, to develop a mission
statement for the watershed group,
to develop project concepts, and to
develop a restoration plan.
Phase II funds shall be used to plan
and carry out watershed
management projects.
Phase III funds shall be used to plan
and carry out at least one
watershed management project.
IRWM
Implementation
Program
Proposition 84
(Chapter 2,
§75026)
Department
of
Water
Resources
Award funds for implementation of
projects consistent with IRWM Plans
to assist local public agencies in
meeting long-term water
management and resilience needs of
the state, including the delivery of
safe drinking water, and protection of
water quality and the environment.
Operation and
maintenance activities
Bond funding allocation for entire
program is $1 billion. Prop 84 allots
grant funding to 11 funding areas
defined by the hydrologic regions
of the state.
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Program Department Purpose Ineligible Uses Funding Limits Flood Corridor
Program
Propositions 1E,
84 and 13
Department
of
Water
Resources
Flood risk reduction through nonstructural projects that include wildlife habitat enhancement and/or
agricultural land preservation
components
Flood protection projects that do
not include wildlife habitat
enhancement or agricultural
land
preservation benefits
$5 million per eligible project. 10%
non-state, non-federal cost share
required; may be reduced to 5% or
no-cost share if serving
disadvantaged or severely
disadvantaged community
Flood Control
Subventions
Program
Propositions 1E
and 84
Department
of
Water
Resources
Implementation of federally
authorized flood control projects
(minor or major) and Watershed
Protection Flood Prevention Projects
Flood control projects without
federal authorization
Variable state cost-share
percentage based on multipurpose
objectives for projects, ranging
from a minimum of 50% to a
maximum of 70%
Statewide Flood
Emergency
Response
Program
Proposition 84
Department
of
Water
Resources
Preparing or updating local
emergency plan; Coordinating flood
emergency planning and
preparedness (including training &
exercise); Developing communication
& coordination response process;
Collecting & exchange of flood
information; Purchase & installing
equipment for interoperable
emergency communication.
Projects not included in
guidelines. Projects in the Legal
Delta.
$10 million for Statewide (outside
the legal Delta) for Prop 84.
California Coastal
Conservancy,
Prop 1 ($100.5
million allocated)
California
Coastal
Conservancy
Funding for multi-benefit water
quality, water supply, and watershed
protection and restoration projects.
Projects that do not comply with
the Proposition 1 Grant Program
Guidelines. Projects that
use potable water for irrigation.
O&M projects are not eligible.
$10 million per year grants will be
made available over the next 10
years.
Storm Water
Grant Program,
Prop 1 ($200
million),
approved as part
of the Water
Quality, Supply
and
Infrastructure
Improvement Act
(2014).
State Water
Resources
Control
Board and
Regional
Water
Quality
Control
Boards
Funding for multi-benefit storm
water management projects which
will improve regional water selfreliance, security, and adapt to the effects on water supply arising from
climate change.
Projects that 1) must seek
eminent domain as part of their
project implementation
timeline; 2) do not meet the
requirements of the Prop 1
Storm Water Grant Program
Guidelines, the Storm Water
Resources Plan Guidelines,
Water Code, and Prop 1; 3)
consist of only education and
outreach activities.
Planning projects: min. $50K and
max. $500K;
Implementation projections: min.
$250K and max. $10M.
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PROJECT-SPECIFIC INTERAGENCY PARTNERSHIPS
Stormwater management projects often overlap with the jurisdiction of other public agencies, including water and transportation agencies, as well as parks and schools. Interagency partnerships would not only allow agencies involved to leverage one another’s available funding resources to make cost intensive projects possible but would also improve local government funding efficiency.
These types of interagency partnership projects could also optimize the potential social, environmental, and economic benefits provided to the community. An interagency partnership also provides an alternative avenue for stormwater agencies to access to grant funding that would otherwise not be available to them. In addition to the above benefits, a partnership with public utility agencies, such as water and refuse collection services, might also provide a mechanism for cost transfer from stormwater agencies to these agencies. For example, the use of stormwater for nonpotable water may conserve drinking water. The cost for providing the infrastructure and the ongoing O&M could be partly funded through fees charged by water agencies as part of their cost for water conservation. Table G-3 provides a list of potentially viable partnerships and the benefits derived from management of stormwater runoff.
Table G-3. Added Benefits of Interagency Partnership for Stormwater Management Potential Partners Benefits Derived from Stormwater Management Flood control district • Flood protection
• Climate change mitigation
Caltrans • Surface water pollution prevention
• Increased project siting opportunities in transportation corridors Water agencies • Potable water conservation through stormwater use for non-potable water purposes
• Surface water pollution prevention
• Increase non-potable water storage through installation of underground cisterns
Parks, Coastal Commission • Terrestrial and marine habitat protection by reducing trash from entering the ocean and other terrestrial habitats
• Water pollution prevention
• Erosion reduction
LOCAL BOND ISSUANCE
Bonds have been utilized by local governments to provide funding for stormwater projects. There are two types of bonds that can be utilized. One of them is GO bonds. GO bonds are issued by local governments, which are repaid through a tax surcharge (e.g., property). The City of Los Angeles, for example, has used GO bonds to fund their stormwater projects. The City sold $440 million GO bonds under Proposition O Clean Water Bonds. The bond proceeds were used for implementation of 39 projects but could not be used for ongoing maintenance, operations, and replacement of these facilities (Farfsing and Watson, 2014). The challenge of utilizing GO bonds is that GO bond issuance and the amount to be issued must be approved by two-third of the voters. The main drawback of election approval requirement is that the cost of holding an election can be high and the chance of success is often unpredictable.
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The last decade has seen the emergence of a new category of bonds generically called “green” bonds.
A green bond is a type of fixed-income instrument that is specifically earmarked to raise money for climate and environmental projects. These bonds are typically asset-linked and backed by the issuing entity's balance sheet, so they usually carry the same credit rating as their issuers’ other debt obligations. Green bonds are designated bonds intended to encourage sustainability and to support climate-related or other types of special environmental projects. More specifically, green bonds finance projects aimed at energy efficiency, pollution prevention, sustainable agriculture, fishery and forestry, the protection of aquatic and terrestrial ecosystems, clean transportation, clean water, and sustainable water management. They also finance the cultivation of environmentally friendly technologies and the mitigation of climate change.
Green bonds come with tax incentives such as tax exemption and tax credits, making them a more attractive investment compared to a comparable taxable bond. These tax advantages provide a monetary incentive to tackle prominent social issues such as climate change and a movement to renewable sources of energy. To qualify for green bond status, they are often verified by a third party such as the Climate Bond Standard Board, which certifies that the bond will fund projects that include benefits to the environment.
Another type of bonds that can be used at the local level is revenue bonds. Revenue bonds are taxexempt securitized bonds that are issued by utility agencies, such as water agencies. These bonds are repaid through utility rate increases charged directly to customers. Recent enactment of AB-850- Public Capital Facilities: Water Quality allows local publicly owned water agencies to finance water quality and water conservation related projects by issuance of revenue bonds through a Joint Powers Authority (JPA). Under the provisions of AB-850, water agencies are allowed to use the bond proceeds to pay for construction, repair, maintenance, and operations of eligible projects. Both stormwater capture and water quality compliance projects are considered as eligible projects that can be financed through bond issuance under the AB-850 mechanism. Additionally, AB-850 authorizes water agencies to repay these bonds through water utility rate increases – the same way as other revenue bonds not issued under the SB-850 mechanism by water agencies. Such rate increases are also subject to Proposition 218 approval under the exempt category (i.e., only a public hearing is required).
SB-628–Enhanced Infrastructure Financing Districts (EIFD) will allow issuance of general obligation bonds within the EIFD inside a city or a county. The Bill authorizes a legislative body to establish an enhanced infrastructure financing district, adopt an infrastructure financing plan, and issue bonds upon approval by 55% of the voters to finance public capital facilities such as collection and treatment of water for urban uses and flood control projects. Under the provisions of SB-628, a City or a County can establish an EIFD of any size. If a defined EIFD has fewer than 12 registered voters, only a protest hearing is required to be conducted for landowners. The number of votes that each landowner gets will depend on the size of the land they own. The ballot will specify a vote per acre or a portion of an acre. The bonds issued under this bill will be repaid through property tax increase (i.e. tax increment financing). The district will cease to exist in no more than 45 years from the date on which bond issuance is approved.
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STATE REVOLVING FUNDS
The Clean Water Act (CWA) provided for the creation of Clean Water State Revolving Fund (CWSRF) program capitalized by federal and state funds which in turn provides municipalities with a permanent source of low-cost financing for a range of water quality infrastructure projects. The California CWSRF program is administered by the State Water Resource Control Board, Division of Financial Assistance.2 The “Policy for Implementing the Clean Water State Revolving Fund,”3 amended in 2019, provides guidance for applying for financial assistance from the CWSRF program and each year an “Intended Use Plan”4 is drafted to provide information about the current financing terms and fund availability.
The CWSRF finances water quality projects similar to those proposed in the EWMP, including nonpoint source, watershed protection or restoration, and estuary management projects (USEPA, 2014). The main advantage of CWSRF is that their interest rates are typically much lower than market rates (e.g. 3% for a 20-year loan instead of 6%). The loans are project-specific and can serve as a good financial resource for funding project design and construction.
The CWSRF program loans carry an interest rate set at one-half of the most recent state GO bond rate at time of funding approval and repayment begins one year after completion of construction with a term of up to 30 years or the useful life of the project. There is no maximum funding limit, but partial funding may be applied based on funds availability and the applicant’s ability to repay. Loan forgiveness is available via subsidy of up to 50% of eligible capital costs and 75% of eligible planning costs, up to a total cap of $4 million, through the Green Project Reserve (GPR). Congress’ intent in enacting the GPR is to direct State investment practices in the water sector to guide funding toward projects that utilize green or soft-path practices to address green infrastructure, water or energy efficiency improvements, or other environmentally innovative activities. 5 The GPR sets a new
precedent for the SRFs by targeting funding towards green infrastructure and water quality projects that states may not have funded in prior years. Any project eligible for GPR funding must also qualify for the CWSRF program.
Access to the State Revolving Funds is limited by the agencies’ ability to borrow due to repayment of other debt obligations (e.g. lease burden). It has been reported that a typical median net lease burden for a California county is 1.7% of general fund revenues while the total burden of lease and General Fund obligations is 1.9% (Moody, 2012). Loan repayment will require alternative funding sources if reliance on general fund resources is not an option.
A CWSRF program loan application consists of four packages - the General Information Package, the Technical Package, the Environmental Package, and the Financial Security Package. The application packages are submitted online via the Financial Assistance Application Submittal Tool (FAAST).6 When the General Information Package is submitted, a project manager will contact and support the 2 https://www.waterboards.ca.gov/water_issues/programs/grants_loans/srf/ 3 https://www.waterboards.ca.gov/drinking_water/services/funding/documents/srf/dwsrf_policy/final_policy_1219.pdf 4 https://www.waterboards.ca.gov/water_issues/programs/grants_loans/docs/cwsrf_iup_sfy2020_21_final.pdf 5 https://www.epa.gov/sites/production/files/2015-04/documents/green_project_reserve_eligibility_guidance.pdf 6 https://faast.waterboards.ca.gov
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applicant through the remaining steps of the application process. All submitted projects are evaluated annually to identify eligibility and receive a priority score for placement on the Fundable List.
LOCAL PUBLIC FUNDING OPPORTUNITIES AND APPROVAL PROCEDURES Stormwater charges are potentially the most critical local funding source to finance stormwater programs in California. These charges include stormwater fees and taxes, as well as other funds generated through general obligation and revenue bond issuance. Table G-4 provides an overview of potential local funding sources that may be utilized to provide funds to finance stormwater programs.
An important factor to consider when utilizing these funding mechanisms is the respective approval mechanisms as discussed below.
Table G-4. Local Funding Opportunities
Fees Taxes Bonds
• Fixed and volumetric
service fees
• Property
assessments or fees
• Developer fees or
connection fees (a
one-time fee)
• Permitting fees
General taxes
• Property, sales, and other activities
Special taxes
• Parcel taxes to pay for flood
protection, stormwater
management, watershed protection
• Sales tax add-ons
• Transient Occupancy Tax to pay for
creeks restoration and water quality
improvement projects
General bonds
• Repaid through a property
tax surcharge
Revenue bonds
• Issued by local utilities (e.g.
water)
• Repaid by service fees,
developer fees, plus
occasional special taxes
Local funding opportunities presented in Table G-4 are subject to approval mechanisms that can vary from holding a written protest hearing to an election, depending on the type of funding sought after (Table G-5). The types of charges that are deemed to be most suitable for stormwater-related services are property-related fees. For a property-based, flood control-related stormwater management fee, an election is required to be conducted under the provisions of Proposition 218. However, there are two categories under Proposition 218 that are exempt from the election approval requirements. They are water-related and refuse collection services. Although there are differing legal opinions on the matter, the approval of AB2403 has extended the definition of water in Proposition 218 to include stormwater capture projects for infiltration and direct non-potable uses, which means that these projects may be exempt from the election requirement under Proposition 218.
Even with the extended definition of water in the California Constitution, the existing form of Proposition 218 still requires voter approval for stormwater fees which has limited stormwater agencies’ ability to generate sufficient revenue to support stormwater projects related to permit compliance.
Given the existing unique regulatory framework and limitation of Proposition 218, some local governments have broken down the stormwater revenue requirements by functions instead of a single property-related fee. Some of them have utilized the exempt category under Proposition 218 to fund stormwater projects with success. The Cities of Signal Hill, Poway, and Solana Beach, for example, have utilized a surcharge on trash collection fees to cover the some of the cost for
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stormwater-related trash collection and management. A surcharge on water utility fees has also been used by the Cities of Del Mar, Oceanside, and Solana Beach to provide funding to fund stormwater operation as part of the drinking water pollution prevention effort (Farfsing and Watson, 2014).
Pollution prevention is an important component in stormwater management. Given that majority of the pollutants in stormwater runoff originate from vehicles, some local governments have used other non-property-related surcharges to provide funding for stormwater programs. For example, the Orange County Transportation Authority has used the County’s sales tax to provide some funding for a water quality improvement and environmental cleanup program. The San Mateo County has also added a surcharge on the vehicle license fee to provide funding for their stormwater pollution management program. It is also foreseeable that pollutant specific, such as a TMDL-related fee could be established to provide funding for TMDL compliance related programs in the future.
In addition to fees that provide steady revenue, another possible revenue source would be to charge fines to property owners that violate discharge limits (volumetric- or TMDL-based). Fines are not considered as a stable financial income; however, they discourage behavior or practices that will lead to non-compliance. Furthermore, fines are exempt from election requirements under Proposition 26 and have been commonly used by water agencies to discourage excessive water consumption behavior. The use of fines under Proposition 26 as a financial instrument to management stormwater discharge in urban areas is still uncommon but might worth exploring.
Table G-5. Local Funding Approval Mechanisms
Proposition 13
(1978)
Proposition 218
(1996)
Proposition 26
(2010)
General
taxes
Flexible Simple majority for cities and counties, not
available to special districts
(rules from the earlier
proposition remain in
place)
General
Obligation
Bonds
Two-thirds of
local voters
Two-thirds of local voters Two-thirds of local
voters
Special taxes Two-thirds of
local voters
(rules from the earlier proposition remain in
place)
(rules from the earlier
proposition remain in
place)
Property
taxes
1% of purchase
price + 2%
annual
increases
(rules from the earlier proposition remain in
place)
(rules from the earlier
proposition remain in
place)
Propertyrelated fees
and
assessments
Flexible 1. All water-related and refuse collection
services: strict cost-of-service
requirements
2. All water-related and refuse collection
services: property-owner protest hearing
3. Floods and stormwater: 50% of property
owners or two-third popular vote
(rules from the earlier
proposition remain in
place)
Nonpropertyrelated feesFlexible Flexible Stricter requirements (more likely to be a
tax)
Wholesale
fees
Flexible Flexible Stricter cost-ofservice requirements
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PUBLIC PRIVATE PARTNERSHIPS
Public private partnerships (P3) can be achieved through two approaches. The conventional approach will involve having the private partner to undertake design and construction, and sometimes even operation and maintenance of the facilities. The private partner will recover the cost plus their return-on-investment through a guaranteed revenue stream (e.g. a user fee) over a long period (e.g. 30- 40 years). The main advantage of such an approach is that the upfront financing costs are provided through the private partner while the project performance is guaranteed by the private partner. Also, P3 can be utilized when agencies have restrictions on the amount of debt that they can carry (e.g. agencies want to maintain low lease burden or have high lease burden). Potential cost saving can be achieved through higher financial efficiency during project implementation phase. P3 can also expedite project implementation by simplifying administrative procedures for financing as well as eliminating the need for tendering. The main challenge for implementation of P3 is to get voters to approve a longer revenue stream to repay the private partner. The amendment of Proposition 218 is expected to lower such hurdle for providing such a revenue stream.
The second P3 approach is through direct financial subsidies to local projects that do not contribute to cash revenue generation. However, subsidies can create a financial incentive to encourage local participation without providing the full cost for project implementation. Such an approach can increase financial efficiency by leveraging financial input from communities. A list of cities that utilize financial subsidies to maximize their local stormwater capture capacity is provided in Table G-6.
Based on these examples presented in Table G-6, subsidies can be given out in forms of 1) rebates per project with caps for stormwater runoff reduction projects, 2) rebate per rain barrel or cistern, 3) rebate per parcel, 4) stormwater fee reduction, and 5) cost sharing.
Among all the runoff capture subsidy programs listed in Table G-6, the approach adopted by the City and County of San Francisco is considered as the most progressive. The City and County adopted the onsite Water Reuse for Commercial, Multi-family, and Mixed-Use Development Ordinance which amended the San Francisco Health Code to allow for the collection, treatment, and use of alternative water sources (including stormwater runoff) for non-potable applications. The City and County has since developed a Non-potable Water Program that allows commercial, mixed use, and multifamily residential property owners to collect, treat and reuse water from various sources onsite, including stormwater runoff. The Program also allows the property owners to act as local non-potable water suppliers to provide non-potable water to buildings in the vicinity. Property owners or developers are required to comply with stringent monitoring and reporting requirements for 10 years in order to maintain such privilege. The San Francisco Public Utilities Commission (SFPUC) has created a grant assistant program that provides up to $250,000 for single building projects and up to $500,000 for district-scale projects meeting specific eligibility criteria to encourage participation.
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Table G-6. Select Cities that Subsidize Private Stormwater Infrastructure Reference Runoff Reduction Runoff Capture and Use
San Francisco, CA
(SFPUC, 2015)
Grants
• Up to $30,000 with 35% match
requirement
• Up to $100,000 with 25% match
requirement
Grants (treatment is required)
• Up to $250,000 for single
building projects
• Up to $500,000 for district-scale
projects
Palo Alto, CA (City of
Palo Alto, 2015)
Rebates
• Permeable pavement, ≤ $1,000 at
$1.5/sq. ft.
• Green roofs, ≤ $1,000 at $1.5/sq. ft.
Rebates (roof runoff)
• Rain barrel $50 each
• Cisterns ≤ $1,000 at $1.50/sq. ft.
Seattle, WA (Seattle
Public Utilities,
2015)
• Rebates for onsite facility
installation, e.g. rain garden
• Stormwater drainage fee reduction
• Rebates for onsite facility
installation, e.g. cistern (Roof
runoff)
• Stormwater drainage fee
reduction
Montgomery County,
MD (County of
Montgomery, 2015)
Rebates
• Residential, ≤ $2,500 per parcel
• Commercial, ≤ $10,000 per parcel
Rebates (roof runoff)
• Residential, ≤ $2,500 per parcel
• Commercial, ≤ $10,000 per
parcel
Washington, D.C.
(Washington D.C.,
2015)
Residential rebates
Trees, ≤ $50 or $100 per tree
Pervious surface, ≤ $2,500 at $1.25/sq. ft.
All customers:
Provide ≤55% stormwater fee discount
Residential rebates (roof runoff)
Cisterns, ≤ $500 at $1/gallons
All customers:
Provide ≤55% stormwater fee
discount
REFERENCES
California Financing Coordinating Committee (CFCC), 2015. 2015 Funding Fairs Handbook.
California Stormwater Quality Association (CASQA), 2015. Vision and Strategic Actions for Managing Stormwater in the 21st Century (Version 1). January.
City of Palo Alto, 2015. Innovative Stormwater Measures Rebate Program. http://www.cityofpaloalto.org/gov/depts/pwd/stormwater/rebates/default.asp) County of Montgomery, 2015. RainScapes Rewards Rebate Program. Environmental Protection.
County of Montgomery, MD. (http://www.montgomerycountymd.gov/DEP/water/rainscapesrebates.html) Farfsing and Watson, 2014. Stormwater Funding Options – Providing Sustainable Water Quality Funding in Los Angeles County. League of California Cities, Los Angeles County Division and California Contract Cities Association. October.
LADWP, 2015. Authorization to Establish a Joint Powers Authority for Water Financing. Los Angeles Department of Water and Power. [http://clkrep.lacity.org/onlinedocs/2015/15-0148_misc_02-05- 2015.pdf]
Public Policy Institute of California (PICC), 2014. Paying for Water in California.
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San Francisco Public Utilities Commission (SFPUC), 2015. San Francisco’s Non-potable Water Program. A Guidebook for Implementing Onsite Water Systems in the City and County of San Francisco. City and County of San Francisco, CA.
Seattle Public Utilities (SPU), 2015. RainWise Rebates for Cisterns and Rain Gardens. WA. (http://www.seattle.gov/util/environmentconservation/projects/drainagesystem/greenstormwat erinfrastructure/rainwise/rebates/)
USEPA, 2013b. The Importance of Operation and Maintenance for the Long-Term Success of Green Infrastructure. A Review of Green Infrastructure O&M Practices in ARRA Clean Water State Revolving Fund Projects. Office of Water. United State Environmental Protection Agency. PA-832-R12-007.
USEPA, 2014. Developing an Outreach Strategy. July 1.
(http://water.epa.gov/polwaste/npdes/swbmp/Developing-an-Outreach-Strategy.cfm) Washington D.C., 2015. RiverSmart Rebates. District Department of the Environment. Washington D.C. (http://ddoe.dc.gov/riversmartrebates)
Appendix H
Community
Involvement for
EWMP
Implementation
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COMMUNITY PARTICIPATION IN IMPLEMENTATION OF THE BEACH
CITIES EWMP
INTRODUCTION
As part of a previous Prop 1 Stormwater Implementation Grant application, the Beach Cities Watershed Management Group (Beach Cities WMG) submitted the required checklist and selfcertification to the State Water Resources Control Board Department of Financial Assistance (SWRCB DFA) staff to demonstrate that the Beach Cities EWMP, in combination with several other existing documents, is functionally equivalent to a Storm Water Resource Plan (SWRP) consistent with the SWRP Guidelines.1 The original checklist and self-certification is attached herein. SWRCB DFA staff reviewed the checklist and identified one item in the checklist, Item #44, that required further revision in order for the Beach Cities SWRP to receive approval as functionally equivalent. Item #44 of the checklist addresses the Water Code Section 10562(b)(4) requirement to include community participation during plan implementation. The SWRP Guidelines provide the following guidance statement with respect to the mandatory statutory requirement to provide for community participation in plan development and implementation [California Water Code 10562(b)(4)]:
To maximize community-based benefits, key stakeholders and the public should be involved in all appropriate implementation steps of the Storm Water Resource Plan.
Public education and opportunities for public participation in actions, decisions, and projects implemented through watershed-based storm water management should be provided.
SWRCB DFA staff requested the Beach Cities checklist and SWRP be revised to incorporate its plan for community participation during implementation of the SWRP. Accordingly, this memorandum was drafted to provide additional documentation on that element of the Beach Cities SWRP. As described in more detail below, the Beach Cities SWRP includes community participation on both the regional and local scale.
INTEGRATED REGIONAL WATER MANAGEMENT PLAN
The Greater Los Angeles County Integrated Regional Water Management Plan (GLAC IRWMP) is a collaborative effort to identify and implement water management solutions on a regional scale that increase regional self-reliance, reduce conflict, and manage water to concurrently achieve social, environmental, and economic objectives on a regional scale. The GLAC IRWMP crosses jurisdictional, watershed and political boundaries; involves many agencies, stakeholders, individuals and groups; and attempts to address the issues and differing perspectives of all the entities involved through mutually beneficial solutions. The GLAC IRWMP is a multi-year effort among water retailers, 1 SWRCB, 2015. Storm Water Resource Plan Guidelines, December 15, 2015.
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wastewater agencies, stormwater and flood managers, watershed groups, the business community, tribes, agriculture and non-profit stakeholders. The GLAC IRWMP provides a mechanism for: 1) coordinating, refining, and integrating existing planning efforts within a comprehensive, regional context; 2) identifying specific regional and watershed-based priorities for implementation projects; and 3) providing funding support for the plans, programs, projects, and priorities of existing agencies and stakeholders.
There are twelve (12) EWMPs and seven (7) individual Watershed Management Programs (WMPs) developed under the LA MS4 Permit that lie within the GLAC IRWM region. These EWMPs and WMPs have been incorporated into the GLAC IRWM and as such the GLAC IRWM provides a successful framework for reaching stakeholders and the public in implementing the programs and projects in the EWMPs and WMPs. By including the EWMPs and WMPs under the umbrella of the GLAC IRWMP, the region enjoys a unified approach in engaging the public in developing water projects for water quality, supply, habitat and recreation. The EWMP prepared by the Beach Cities WMG and approved by the Los Angeles Regional Water Quality Control Board is one of the EWMPs incorporated into the GLAC IRWMP. In addition, regional projects identified in the Beach Cities’ EWMP have been incorporated into the GLAC IRWMP. The GLAC IRWM Governance Structure creates a platform for water agencies, municipalities, environmental organizations and other stakeholder groups to discuss and share stormwater issues and ideas. The GLAC IRWMP meets periodically with stakeholders to discuss regional collaborative efforts, such as those included in the EWMPs. There are also five Subregional Steering Committees which coordinate local outreach efforts and planning, and the Beach Cities EWMP participates in the South Bay Steering Committee. GLAC IRWM outreach activities are posted on the LA Water Plan website (LAWaterPlan.org).
The GLAC IRWM includes a Steering Committee dedicated to facilitating and supporting efforts to provide outreach activities to disadvantaged communities. A Disadvantaged Community Coordinator position was created to lead outreach efforts within the GLAC Region. In 2015, the Disadvantaged Community Coordinator led a Water Dialogue speaker series across Los Angeles to initiate discussions on water issues and to educate the public on water policy. The Disadvantaged Community Coordinator also played an active role in shaping legislation and the development of IRWM-related grant programs to maximize disadvantaged community priorities. In 2016, the Department of Water Resources (DWR) released the Final Request for Proposals for the Disadvantaged Community Involvement Program (DACIP). DWR designated $9.8 million of Proposition 1 grant funding for the Los Angeles – Ventura Funding Area. The Purpose of the DACIP is to involve disadvantaged communities and economically distressed areas in the IRWM planning process. The Program seeks to increase understanding of water needs in these areas and develop long-term solutions to address these needs, including developing projects. In 2018, two contracts were awarded to develop community outreach public education materials and broad-based public education campaigns for the Program.
MEASURE W (SAFE, CLEAN WATER PROGRAM)
The Measure W parcel tax on the impermeable area of private parcels throughout Los Angeles County was successfully passed by Los Angeles County voters in November 2018, creating the Safe, Clean Water Program to provide local, dedicated funding for stormwater and urban runoff to increase local water supply, improve water quality, and protect public health within the Los Angeles Basin. The
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program currently generates approximately $285 million per year. The majority of this funding goes directly back to the cities via two programs:
• The Municipal Program - 40% of the annual revenue goes directly to cities via the Municipal Program, with city-specific revenue proportional to the revenues generated within its boundaries. The Municipal Program funding can be used for eligible activities such as project development, design, construction, effectiveness monitoring, operations and maintenance (including operation and maintenance of projects built to comply with the MS4 Permit), as well as for other programs and studies related to protecting and improving water quality in lakes, rivers, and the ocean. The total annual municipal revenue projected for the Beach Cities WMG is approximately $3.4M.
• The Regional Program – 50% of the annual revenue is divided across nine watershed areas (including the South Santa Monica Bay Watershed Area, which includes the Beach Cities Area), and is devoted to funding regional watershed-based projects, project concepts, and scientific studies. The South Santa Monica Bay Watershed Area is estimated to receive up to $18.4 million annually to fund regional projects and programs. Funding for multi-benefit regional projects includes design, permits, CEQA compliance, grant-writing, right-of-way and land acquisition, construction, and long-term operations and maintenance of the facilities.
The application process for regional program funds requires both local and regional outreach efforts.
First, project development requires significant buy-in from the local community, with a demonstration of outreach efforts and community support as a critical part of the project application score. Second, project applications are submitted to the local Watershed Area Steering Committee (WASC) for evaluation. The WASC, comprised of representatives from cities, agencies, and community stakeholders, reviews proposed projects and develops an annual Stormwater Investment Plan (SIP) for their Watershed Area that identifies recommendations for funding. The review process is a public process, with the general public able to attend meetings and provide comments on considered projects. Recommended projects included in SIPs are also reviewed by a Regional Oversight Committee consisting of LA County Board of Supervisor-appointed subject matter experts for recommendation to the Board of Supervisors. In addition, the WASC includes a Watershed Coordinator who assists the WASC with community and stakeholder education and engagement.
Therefore, projects are required to receive region-wide support for successful funding.
In addition to the programs listed above, ten percent of the total annual revenue generated from the Safe, Clean Water Program is allocated to the Los Angeles County Flood Control District. The District will oversee capacity building programs including a public education program, local workforce job training, and school education programs:
• Public Education Program – LA County’s Water for LA initiative is a trusted resource on all things water to educate the public and foster more sustainable behavior to help ensure the future of the region. Water for LA envisions an LA County where residents understand and nurture their relationship with water – where it comes from, its connection to the rivers and lakes upstream, and how their actions impact their neighbors, region, ocean, and planet.
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• Workforce Training Program – The District will implement a Workforce Training Program that will provide certification classes and vocational training at the community level for the construction, inspection, operation, and maintenance of stormwater management and multibenefit projects. • School Education Program - The District will develop and implement a School Education Program about the LA County region and its relationship with stormwater.
LOCAL COMMUNITY PARTICIPATION AND PUBLIC ENGAGEMENT
In addition to the outreach efforts related to the GLAC IRWM and Safe, Clean Water Program, the Beach Cities WMG conducts several local outreach programs as part of the SWRP implementation.
The Beach Cities have established a Memorandum of Understanding for the Administration and Cost Sharing for Coordination and Implementation of the Coordinated Integrated Monitoring Program (CIMP Implementation MOU), which supports the Beach Cities EWMP and drives the EWMP adaptive management process. The CIMP Implementation MOU became effective on April 14, 2016 and was unanimously extended by the Beach Cities WMG for two, 1-year terms. In December 2020, the CIMP MOU was amended to add additional services to the Scope of Services, authorize increased costs, and extend the term through December 31, 2023 with the option to further extend the term by unanimous written concurrence. The CIMP MOU includes funding and scope for watershed coordination activities including a number of tasks that facilitate public education and opportunities for public participation. The watershed coordination scope of work is adjusted annually to best address the watershed needs. The scope for reporting year 2020-2021, for example, included the following relevant tasks that support public education and participation:
• Development and implementation of watershed-specific stormwater outreach materials in the form of digital content and print materials for public dissemination. • Coordination and management of monthly WMG meetings.
• Representation at Los Angeles Regional Water Board meetings and workshops. • Participation in Regional EWMP and CIMP Coordination meetings on behalf of the WMG. • Assistance with the Adaptive Management Process and updating of the Beach Cities EWMP, which includes public outreach.
• Assistance aligning joint projects for funding opportunities such as Safe, Clean Water Regional funding and GLAC IRWMP Prop 1 funding.
• Preparation of Watershed Joint Annual Reports to the Los Angeles Regional Water Quality Control Board evaluating progress toward achievement of the EWMP targets and milestones.
PUBLIC PARTICIPATION DURING EWMP DEVELOPMENT
The Beach Cities WMG has conducted outreach to engage the public, Los Angeles Regional Water Quality Control Board staff, and other interested parties to support EWMP development. Input has been incorporated, as appropriate. These efforts are described in more detail below.
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Public Workshops – Original EWMP. For development of the original EWMP, public workshops were held on May 21, 2014 at the Joslyn Center in Manhattan Beach and on May 27, 2015 at the Redondo Beach Public Library. An informational presentation was provided followed by a question and answer period to encourage stakeholder input. Concerns were noted and considered during EWMP development by the Beach Cities WMG.
Technical Advisory Committee (TAC). The Beach Cities WMG actively participated in the Los Angeles region TAC and applicable subcommittees throughout the EWMP process.
LARWQCB Presentations. The Beach Cities WMG presented the proposed RAA approach to LARWQCB staff on April 9 and June 6, 2014. LARWQCB staff provided feedback during these meetings and in general they were supportive of the proposed approach. One additional meeting was held on July 31, 2014 to discuss Torrance-specific matters. In addition, the Beach Cities WMG presented the EWMP and progress on implementation to the LARWQCB in July 2018.
Public Website – Revised EWMP. As part of the revision process for the Beach Cities EWMP in 2021, the Beach Cities WMG created a website that highlighted the EWMP update process; provided details for each proposed project; and allowed for public comment to be submitted.
The website was launched in May 2021.
Public Virtual Webinar – Revised EWMP. The Beach Cities WMG held a public virtual webinar on May 19, 2021 to present the draft Revised EWMP to the Beach Cities communities and receive public input. The webinar was publicized in advance by each of the four Beach Cities.
City Council Review and Adoption. The cities of Hermosa Beach, Manhattan Beach, Redondo Beach, and Torrance each brought the draft Beach Cities EWMP (2015) and draft revised Beach Cities EWMP (2021) to their respective city councils for consideration and approval to submit to the Regional Board. This process is open to the public, and residents are encouraged and invited to share comments related to the EWMP at these council meetings. Voiced concerns and recommendations were noted and considered for inclusion in the final EWMP and final Revised EWMP.
PUBLIC PARTICIPATION DURING PROJECT IMPLEMENTATION
Separate MOUs will be developed as needed for each joint regional project undertaken by the Beach Cities WMG. These MOUs for cost-sharing of design and construction of regional projects will incorporate public engagement and participation at key points in the project design and construction including:
• City Council consideration and approval authorizing implementation of each regional project at award of design contract—City Council meetings are public and also can be viewed through public media feeds;
• Development of a CEQA-compliant evaluation of the project;
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• Public workshops at the preliminary design phase to share project design concepts and solicit public input and participation;
• Public groundbreaking event at the start of construction which are publicized via press release
• Coordination and outreach to the local community immediately adjacent and others that may be affected during construction of the project
• Ribbon cutting at the conclusion of construction which are publicized via press release Currently, multiple regional projects are being planned or developed by the Beach Cities WMG. Many of these projects involve more than one agency. In these cases, the relevant agencies have been coordinating outreach and community engagement efforts. For example, the Beach Cities Green Street Project involves all four Beach Cities. The four cities are coordinating outreach efforts, partnering with a local outreach firm to engage the community via both online and in-person events during project design.
In the case of individually implemented EWMP regional projects or distributed projects that do not require an MOU among the EWMP WMG members, the individual agency implementing the project will carry out appropriate public engagement elements for each project. One such multi-benefit regional project underway in the City of Torrance is highlighted below.
Torrance Stormwater Basins Enhancement and Expansion Project Following initial enhancements to the Amie, Henrietta, and Entradero Flood Control Basin network completed in 2015, the City of Torrance is moving forward with further improvements to expand the capacity of these basins to fully retain the 85th percentile, 24-hour design storm from their combined 1,407-acre tributary area, comprising approximately one half of the tributary area to the Herondo Storm Drain system. The scope of this basin expansion project includes:
• Deepening of the existing Henrietta and Entradero Basins to increase storage capacity; • Installation of drywells at Henrietta Basin to improve infiltration; and • Adjustment of pumping levels at Amie Basin to ensure retention of the 85th percentile design storm.
The project, which includes additional benefits such as walking trails and educational material, was recently submitted for funding under the Safe Clean Water Program. Preliminary design of the project is currently in process, with an estimated construction completion in 2024 (City of Torrance, 2020a).
For the first enhancement project, a community meeting was held prior to design of the project. The project design approach was also presented at the California Storm Water Quality Association conference in September 2014. At the completion of the project, an open house was held for the community on November 7, 2015. Ongoing outreach occurs through monthly docent-led tours of the Henrietta Basin.
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For the current expansion project, the City of Torrance held its first community outreach meeting at Entradero Park on October 10, 2020. Due to COVD-19-related restrictions and concerns, the meeting was safely held outdoors, with mask requirements and social distancing observed. 44 residents were registered as attendants at the meeting, and 23 comment cards were submitted by attendees.
Additionally, the City maintains a project-specific website that provides residents with project information and provides direction on how to provide feedback on the project.
PUBLIC ENGAGEMENT AND EDUCATION IN STORMWATER POLLUTION PREVENTION The Beach Cities WMG has been implementing a customized, collaborative Public Information and Participation Program (PIPP) consistent with Regional Board staff’s approval of this approach through adaptive management in March 2019. The PIPP has been adapted to address the Beach Cities WMG’s highest water quality priorities and to allow for more effective and targeted distribution of education and outreach materials to Beach Cities residents and businesses. This customized strategy includes the ongoing development of outreach materials promoting behavioral change in the DIY residential community that is a source of targeted pollutants of concern to the Beach Cities WMG and distribution of these materials using multiple methods, such as distribution of print materials at public offices and community events and the use of internet-based platforms. This customized strategy includes a variety of outreach efforts. Examples of the types of outreach methods which have been implemented to engage the public by the Beach Cities WMG members or in partnership with other local agencies are provided below.
Environmentally Friendly Landscaping, Gardening and Pest Control webpages The Beach Cities WMG along with the Peninsula WMG, has established and collaboratively maintains and periodically updates Sustainable Gardening and Landscaping and Integrated Pest Management (IPM) webpages to disseminate information on CA friendly landscaping, responsible irrigation, integrated pest management and the proper use and disposal of pesticides and fertilizers. The Beach Cities and Peninsula WMGs contract with the South Bay Environmental Services Center (SBESC) to host these pages on their website: http://www.southbaycities.org/programs/environmentallyfriendly-landscaping-gardening-and-pest-control. The South Bay Environmental Services Center (SBESC), a clearinghouse for energy efficiency, water conservation and environmental information.
The SBESC is a program of the South Bay Cities Council of Governments, a joint powers authority of 16 cities in the South Bay of Los Angeles along with the County of Los Angeles. The SBESC website is the central place for residents to explore information regarding environmental topics, and their Enewsletter has a circulation of nearly 15,500. The website also promotes visitation of the Beach Cities WMG’s several water-efficient demonstration gardens by listing their location and showcasing photos.
Residential Rainwater Harvesting Guide
The Beach Cities WMG in partnership with the Peninsula WMG developed the South Bay Homeowner’s Guide to Rainwater Harvesting. The concept and design for the guide were adapted from the City of Los Angeles Rainwater Harvesting Program – A Homeowner’s How-To Guide November 2009 1st Edition, and a similar guide prepared by the Santa Monica Bay Restoration Foundation for Culver City. The guide provides an introduction to residential rainwater harvesting and covers the topics of downspout disconnection and redirection to permeable surfaces, rain garden
Beach Cities EWMP | Appendix H | Community Participation H-8 | Page 2021
design and installation, selection of appropriate CA friendly plants, and rain barrel installation. The guide also provides a wealth of additional resources for homeowners looking to implement additional rainwater harvesting methods or seeking supplemental information. Multiple stakeholders were engaged in the development of this rainwater harvesting program with multiple city staffs, particularly building officials, as well as Los Angeles County Building & Safety staff involved in reviewing and commenting on the Guide to ensure that it would be consistent with local ordinances and policies. Several opportunities for input were provided and this constructive stakeholder feedback has improved the utility of the Guide. The Guide includes a section on maintenance and incorporates advice on periodic inspection and measures or adjustments to correct common problems.
Business Assistance Program for Food Service Establishments and Mobile Businesses The Beach Cities WMG conducts annual inspections of food service establishments during which onsite managers are educated about stormwater and non-stormwater pollution prevention requirements. The managers are advised of opportunities to become certified in one of several environmental certification programs (Bay Foundation Clean Bay Restaurant Certification, Surfrider Ocean Friendly Restaurant Certification, Green Business Certification).
The Beach Cities WMG also developed a “Flow on the Go” tip card to distribute to targeted mobile businesses that generate wastewater such as auto detailers, window washers, and pet groomers as potential sources of non-stormwater discharges containing pollutants of concern. The tip card covers site preparation and cleanup, spill prevention and response, storm drain inlet protection, and proper disposal of wastewater. The tip card also encourages the use of dry-cleaning methods and environmentally friendly cleaning products. While this outreach targets the mobile business sector, it will also reach residents and businesses that use these services and educate them on proper BMPs and the importance of proper waste disposal. The tip card was developed for both digital posting to agency websites as well as distribution through code enforcement interactions and at public counters.
Ocean Friendly Landscape Workshops
West Basin Municipal Water District, in partnership with Surfrider Foundation, provides free Ocean Friendly Landscape workshops for residents within the Beach Cities WMG to help them manage their landscapes more efficiently. The program consists of a classroom presentation along with a handson-workshop at a demonstration garden location. Topics covered in the workshops have addressed both stormwater and non-stormwater pollutant source reduction. Residents learn about permeable pavement, drought-tolerant and native plants, proper use of mulch and smart irrigation control equipment. The objective of these workshops is to teach participants to apply methods that will reduce water consumption, runoff, and ocean pollution. As part of the Ocean Friendly Landscape program, West Basin periodically holds weather-based irrigation controller exchange events where customers can attend a 30-minute training on how to install and operate the weather-based irrigation controllers and then trade in their old, inefficient controllers for a new free controller. This program is typically promoted by each of the Beach Cities agencies through their websites and edistribution channels.
Beach Cities EWMP | Appendix H | Community Participation H-9 | Page 2021
Rain Barrel Distribution
Rain barrel distribution or rebate programs engage and educate the community through active participation in stormwater capture and may serve as a stepping-stone to more significant residential stormwater capture retrofit projects such as downspout disconnection into cisterns or rain gardens.
The West Basin Municipal Water District program has distributed free rain barrels to residents within its service district; the program has included a 50-gallon capacity barrel equipped with overflow spout, built-in mosquito screen, and a rain gutter downspout flex arm hose connector. In a separate program, the Metropolitan Water District of Southern California (MWD) has provided $75 rebates to residents within its service district who purchased their own barrels. To date, an estimated total of 1,986 residences have been retrofit with rain barrels in the Beach Cities WMG area.
Irrigation Reduction Incentives
West Basin Municipal Water District offers a Landscape Irrigation Efficiency Program for large landscape water users (residents and businesses) within its service area, including the Beach Cities WMG members. The program provides outdoor water evaluations which identify leaks, broken sprinklers and pipes, unnecessary runoff, sprinkler controller issues, and other water wasting problems in landscapes. The program includes sprinkler nozzle retrofits and an outdoor water use report complete with recommendations on more efficient outdoor watering habits.
The Beach Cities agencies also maintain a number of California Friendly gardens and landscapes located throughout the Beach Cities WMG area that demonstrate to residents the beauty, utility and economy of native and drought-tolerant plants which require less water, fertilizer and pesticides than traditional landscape plantings. Most of these demonstration gardens are also equipped with interpretive signage. The Environmentally Friendly Landscaping, Gardening and Pest Control webpages hosted by the South Bay Environmental Services Center include a page dedicated to highlighting these demonstration gardens.
Community Events
Each of the Beach Cities typically hosts an annual Coastal Cleanup Day event on its respective beach in partnership with Heal the Bay, the Ocean Conservancy, and the California Coastal Commission.
Each agency also hosts at least one other public outreach event each year, such as a household hazardous waste roundup, an Earth Day event or Safety Fair, which provide opportunities to disseminate information about stormwater and urban runoff pollution.
Pet Waste Management Outreach
The Beach Cities WMG agencies maintain pet waste collection and clean-up stations in each of their respective municipal parks. In addition, the linear greenbelts that serve as jogging/walking paths through the cities of Hermosa Beach, Manhattan Beach and Redondo Beach are also equipped with pet waste collection stations, as are The Strands in Hermosa and Manhattan Beach and the Esplanade in Redondo Beach. These pet waste stations serve as a catalyst and reminder for behavior change by pet owners as well as a means of reducing pollutant loading.
Small Construction Site BMP Brochure
In order to enhance the effectiveness of the Beach Cities WMG agency’s individual construction programs and to provide a comprehensive and uniform set of expectations for building contractors
Beach Cities EWMP | Appendix H | Community Participation H-10 | Page 2021
across the EWMP area, the Beach Cities WMG developed a Small Site Construction brochure targeted at contractors working on construction sites less than 1-acre in disturbed area. The brochure is available in both English and Spanish and describes the BMPs required by the MS4 Permit, including an illustration of where and how to deploy these BMPs on a residential construction site. The brochure also includes information regarding material storage and handling as well as spill prevention, clean-up and disposal.
Regional Residential and Business Outreach
In addition to the development and distribution of outreach materials targeted at the local residential community, the Beach Cities WMG leverages successful existing statewide and regional outreach programs such as the CalRecycle Used Oil and Household Hazardous Waste Program (Used Oil Program) and many additional programs coordinated by the South Bay Environmental Services Center (SBESC) and promoted through SBESC via e-mail blasts to residents and businesses regarding opportunities to learn and become actively involved in water conservation and stormwater pollution prevention. These include Metropolitan Water District California Friendly Landscaping and Turf Removal workshops, Water Replenishment District’s Eco-Friendly Gardener Series, and West Basin water conservation workshops and classes.
Beach Cities EWMP | Appendix H | Community Participation H-11 | Page 2021
ATTACHMENT 1 – CHECKLIST AND SELF-CERTIFICATION
Offices in Principal Cities of the United States and Select International Locations geosyntec.com
CITY OF HERMOSA
BEACH RESOLUTION NO.
24-
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF HERMOSA BEACH
APPROVING THE CONSTRUCTION OF THE HERMOSA AVENUE GREEN
STREET PROJECT PURSUANT TO GOVERNMENT CODE SECTION 830.6
AND ESTABLISHING A PROJECT PAYMENT ACCOUNT
WHEREAS, CWE, a design firm, designed and prepared the plans to construct THE HERMOSA AVENUE GREEN STREET PROJECT (“Project”); and
WHEREAS, The City will solicit and award a single contract through a competitive bid process for the Project in accordance with the memorandum of understanding between the City of Torrance, The City of Hermosa Beach, the City of Manhattan Beach, and the City Of Redondo Beach or the Implementation of the Beach Cities Green Stret Project for the Beach Cities Watershed Management Group.
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF HERMOSA BEACH, CALIFORNIA, DOES HEREBY RESOLVE AS FOLLOWS:
SECTION 1. The City Council wishes to obtain the immunities set forth in Government Code § 830.6 with regards to the plans and construction of the Project. The City Engineer finds that the plans are complete and the Project may be constructed.
SECTION 2. Design Immunity; Authorization
A. The design, plans for the Project are determined to be consistent with the City’s standards and are approved;
B. The design approval set forth in this Resolution occurred before actual work on the Project construction commenced;
C. The approval granted by this Resolution conforms with the City’s General Plan;
D. The City Engineer, or designee, is authorized to act on the City’s behalf in approving any alterations or modifications of the design and plans approved by this Resolution; and
E. The approval and authorization granted by this Resolution is intended to avail the City of the immunities set forth in Government Code § 830.6.
SECTION 3. For purposes of the Contract Documents administering the Project, the City establishes an account containing sufficient monies from the current and following fiscal year budget to pay for the project. This Account is the sole sources of funds available for the Construction Sum as defined in the Contract Document administering the Project.
SECTION 4. The City Clerk is directed to certify the adoption of this Resolution.
SECTION 5. This Resolution will become effective immediately upon adoption.
PASSED, APPROVED and ADOPTED on this 12th day of November, 2024 Mayor Dean Francois
PRESIDENT of the City Council and MAYOR of the City of Hermosa Beach, CA ATTEST: APPROVED AS TO FORM:
Myra Maravilla Patrick Donegan
City Clerk City Attorney
VICINITY MAP
LOCATION MAP
SHEET NO. DRAWING NO. SHEET TITLE
C I T Y O F H E R M O S A B E A C H , C A
1 9 0 N7
CONSTRUCTION PLANS
FOR
CITY OF HERMOSA BEACH
CIP 164 HERMOSA AVENUE GREEN STREET
PROJECT
LOCATION
LEGEND / HATCH
ABBREVIATIONS
UTILITY COMPANIES
BASIS OF BEARINGS
BENCHMARK
PROJECT
LOCATION
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(PART OF BEACH CITIES GREEN STREETS)
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GENERAL CONSTRUCTION NOTES:
“ ” UTILITIES:
“ ”
”
”
TRAFFIC CONTROL:
“ ”
SITE CONTROL / SAFETY:
SURVEY / LAYOUT:
LANDSCAPE:
EROSION CONTROL:
CONSTRUCTION / MATERIALS:
Docusign Envelope ID: 29994776-45C2-4255-86BD-B089711C66B4 11/05/2024 | 13:09 PST
PALM DRIVE HERMOSA AVE
LYNDON ST LYNDON ST
1ST CT
HERONDO ST
HERONDO ST MONTEREY BLVD
C-3
C-4
C-5 C-6
C-7
C-8
C-3
C-9
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KEYMAP CONSTRUCTION NOTES:
Docusign Envelope ID: 29994776-45C2-4255-86BD-B089711C66B4 11/05/2024 | 13:09 PST
MANHATTAN AVE PALM DR
1ST ST HERMOSA AVE
BEACH DR PALM DR
1ST ST
C-3
C-4
C-5 C-6
C-7
C-8
C-3
C-9
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KEYMAP
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Docusign Envelope ID: 29994776-45C2-4255-86BD-B089711C66B4 11/05/2024 | 13:09 PST
2ND ST PALM DRIVE HERMOSA AVE MANHATTAN AVE
3RD CT
2ND ST
C-3
C-4
C-5 C-6
C-7
C-8
C-3
C-9
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KEYMAP
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Docusign Envelope ID: 29994776-45C2-4255-86BD-B089711C66B4 11/05/2024 | 13:09 PST
2ND ST MONTEREY BLVD CULPER COURT
2ND ST BAYVIEW DR
C-3
C-4
C-5 C-6
C-7
C-8
C-3
C-9
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KEYMAP
CONSTRUCTION NOTES:
Docusign Envelope ID: 29994776-45C2-4255-86BD-B089711C66B4 11/05/2024 | 13:09 PST
HERMOSA AVE PALM DR MANHATTAN AVE
4TH ST 4TH ST
4TH CT
3RD ST
C-3
C-4
C-5 C-6
C-7
C-8
C-3
C-9
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KEYMAP
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Docusign Envelope ID: 29994776-45C2-4255-86BD-B089711C66B4 11/05/2024 | 13:09 PST
HERMOSA AVE
4TH ST PALM DR MANHATTAN AVE MONTEREY BLVD BAYVIEW DR
4TH ST
5TH ST
5TH CT
C-3
C-4
C-5 C-6
C-7
C-8
C-3
C-9
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MATCH LINE - SEE SHEET C-9
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KEYMAP
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Docusign Envelope ID: 29994776-45C2-4255-86BD-B089711C66B4 11/05/2024 | 13:09 PST
6TH ST MANHATTAN AVEHERMOSA AVE PALM DR BAYVIEW DR
6TH CT
6TH ST
C-3
C-4
C-5 C-6
C-7
C-8
C-3
C-9
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KEYMAP
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Docusign Envelope ID: 29994776-45C2-4255-86BD-B089711C66B4 11/05/2024 | 13:09 PST
PRECAST PERVIOUS CONCRETE SLAB DETAIL
(2'W OR 4'W X 5'L X 6" THK.)
A
A
”
”
”
®
DETAIL B DETAIL A
TREE PLANTING DETAIL
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TABLE 1
SECTION A-A
Docusign Envelope ID: 29994776-45C2-4255-86BD-B089711C66B4 11/05/2024 | 13:09 PST
B
B
A A
SECTION A-A
SECTION B-B
PLAN VIEW
D
D
C
C
D
D
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PRECAST PERVIOUS CONCRETE RIBBON GUTTER PANEL
(3'W X 5'L X 8" THK.)
PRECAST PERVIOUS CONCRETE SLAB LAYOUT
ALONG CONCRETE DRIVE APRON AT 1ST ST. AND PALM DR.
(4'W X 5'L X 6" THK.)
1ST ST. PALM DR.
PRECAST PERVIOUS CONCRETE
RIBBON GUTTER DETAIL ON 2ND ST. AT PALM DR.
(3'W X 5'L X 8" THK.) PALM DR.
2ND ST.
CONSTRUCTION NOTES:
SECTION C-C SECTION D-D PALM DR.
6TH ST.
PRECAST PERVIOUS CONCRETE SLAB LAYOUT
ALONG CONCRETE DRIVE APRON AT 6TH ST. AND PALM DR.
(2'W X 5'L X 6" THK.)
Docusign Envelope ID: 29994776-45C2-4255-86BD-B089711C66B4 11/05/2024 | 13:09 PST
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Docusign Envelope ID: 29994776-45C2-4255-86BD-B089711C66B4 11/05/2024 | 13:09 PST
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EROSION AND SEDIMENT CONTROL NOTES:
WASTE AND MATERIALS MANAGEMENT CONTROL NOTES:
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) NOTES:
STORM WATER POLLUTION PLAN NOTES:
TEMPORARY SEDIMENT CONTROL:
WIND EROSION CONTROL:
EQUIPMENT TRACKING CONTROL:
NON-STORMWATER MANAGEMENT:
WASTE MANAGEMENT & MATERIAL
POLLUTION CONTROL:
EROSION CONTROL NOTES:
NOTES:
STREET MAINTENANCE:
EROSION CONTROL SYMBOLS:
Docusign Envelope ID: 29994776-45C2-4255-86BD-B089711C66B4 11/05/2024 | 13:09 PST
PALM DRIVE HERMOSA AVE
LYNDON ST
1ST CT
HERONDO ST
LYNDON ST
HERONDO ST MONTEREY BLVD
EC-2
EC-3
EC-4 EC-5
EC-6
EC-7
EC-2
EC-8
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KEYMAP
EROSION CONTROL SYMBOLS:
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EROSION CONTROL NOTES:
Docusign Envelope ID: 29994776-45C2-4255-86BD-B089711C66B4 11/05/2024 | 13:09 PST
MANHATTAN AVE PALM DR
1ST ST HERMOSA AVE
BEACH DR PALM DR
EC-2
EC-3
EC-4 EC-5
EC-6
EC-7
EC-2
EC-8
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MATCH LINE - SEE SHEET EC-4
MATCH LINE - SEE SHEET EC-2
KEYMAP
EROSION CONTROL NOTES:
EROSION CONTROL SYMBOLS:
Docusign Envelope ID: 29994776-45C2-4255-86BD-B089711C66B4 11/05/2024 | 13:09 PST
2ND ST PALM DRIVE HERMOSA AVE MANHATTAN AVE
3RD CT
EC-2
EC-3
EC-4 EC-5
EC-6
EC-7
EC-2
EC-8
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MATCH LINE - SEE SHEET EC-6
MATCH LINE - SEE SHEET EC-3 MATCH LINE - SEE SHEET EC-5 KEYMAP
EROSION CONTROL NOTES:
EROSION CONTROL SYMBOLS:
Docusign Envelope ID: 29994776-45C2-4255-86BD-B089711C66B4 11/05/2024 | 13:09 PST
2ND ST MONTEREY BLVD CULPER COURT
2ND ST BAYVIEW DR
EC-2
EC-3
EC-4 EC-5
EC-6
EC-7
EC-2
EC-8
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KEYMAP
EROSION CONTROL NOTES:
EROSION CONTROL SYMBOLS:
Docusign Envelope ID: 29994776-45C2-4255-86BD-B089711C66B4 11/05/2024 | 13:09 PST
HERMOSA AVE PALM DR MANHATTAN AVE
4TH ST
EC-2
EC-3
EC-4 EC-5
EC-6
EC-7
EC-2
EC-8
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MATCH LINE - SEE SHEET EC-7
MATCH LINE - SEE SHEET EC-4
KEYMAP
EROSION CONTROL NOTES:
EROSION CONTROL SYMBOLS:
Docusign Envelope ID: 29994776-45C2-4255-86BD-B089711C66B4 11/05/2024 | 13:09 PST
HERMOSA AVE
4TH ST PALM DR MANHATTAN AVE MONTEREY BLVD BAYVIEW DR
4TH ST
EC-2
EC-3
EC-4 EC-5
EC-6
EC-7
EC-2
EC-8
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MATCH LINE - SEE SHEET EC-8
MATCH LINE - SEE SHEET EC-6
KEYMAP
EROSION CONTROL NOTES:
EROSION CONTROL SYMBOLS:
Docusign Envelope ID: 29994776-45C2-4255-86BD-B089711C66B4 11/05/2024 | 13:09 PST
6TH ST MANHATTAN AVE HERMOSA AVE PALM DR BAYVIEW DR
EC-2
EC-3
EC-4 EC-5
EC-6
EC-7
EC-2
EC-8
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MATCH LINE - SEE SHEET EC-7
KEYMAP
EROSION CONTROL NOTES:
EROSION CONTROL SYMBOLS:
Docusign Envelope ID: 29994776-45C2-4255-86BD-B089711C66B4 11/05/2024 | 13:09 PST
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GENERAL NOTES:
Docusign Envelope ID: 29994776-45C2-4255-86BD-B089711C66B4 11/05/2024 | 13:09 PST
VALLEY DR. 2ND ST. 2ND ST. 2ND ST.
MAHATTAN AVE.
CULPER CT.
BAYVIEW DR.
MONTEREY BLVD. MONTEREY BLVD.
BAYVIEW DR. BAYVIEW DR.
MONTEREY BLVD.
MAHATTAN AVE.
MAHATTAN AVE. 4TH ST. 6TH ST.
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TRAFFIC CONTROL LEGEND:
TRAFFIC SIGN LEGEND: TRAFFIC CONTROL GENERAL NOTES:
MATCH LINE SEE SHEET 14
” ”
”
TRAFFIC CONTROL GENERAL NOTES: (CONTINUATION)
“ ”
“ ”
“ ”
“ ” “ ” “ ”
“ ” “ ”
NOTES:
Docusign Envelope ID: 29994776-45C2-4255-86BD-B089711C66B4 11/05/2024 | 13:09 PST
STOP STOP 2ND ST. 2ND ST.
MAHATTAN AVE.
BAYVIEW DR.
MONTEREY BLVD. MONTEREY BLVD.
BAYVIEW DR. BAYVIEW DR.
MONTEREY BLVD.
MAHATTAN AVE.
MAHATTAN AVE. 4TH ST. 6TH ST.
1ST ST.
PALM DR. PALM DR. PALM DR. 2ND ST. 4TH ST. 6TH ST.
HERMOSA AVE.
HERMOSA AVE.
BEACH DR. 4TH ST. 4TH CT. 3RD CT. 3RD ST. 5TH ST. 5TH CT. 6TH ST. 6TH CT.
BEACH DR.
MONTEREY BLVD. 1ST CT.
PALM DR.
HERMOSA AVE.
HERONDO ST. LYNDON ST. 1ST CT.
PALM DR.
HERMOSA AVE. LYNDON ST. 1ST CT.
PALM DR.
HERMOSA AVE. LYNDON ST.
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TRAFFIC CONTROL LEGEND:
TRAFFIC SIGN LEGEND:
MATCH LINE SEE SHEET 13
SEE PHASING
DETAIL HEREON
LYNDON ST. PHASE 1 LYNDON ST. PHASE 2
NOTES:
Docusign Envelope ID: 29994776-45C2-4255-86BD-B089711C66B4 11/05/2024 | 13:09 PST
City of Hermosa Beach | Page 1 of 3
Meeting Date: November 12, 2024
Staff Report No. 24-CA-008
Honorable Mayor and Members of the Hermosa Beach City Council
CITY MANAGER CONTRACT AMENDMENT
(City Attorney Patrick Donegan)
Recommended Action:
Staff recommends City Council approve a resolution (Attachment 1) approving the fifth amendment to the City Manager’s employment agreement increasing her compensation for her seventh year of employment and awarding her a one-time bonus pursuant to the terms of her employment agreement.
Executive Summary:
The City Council conducted the City Manager’s annual performance and directed a contract amendment be prepared providing for an increase in salary for her 2024–2025 year of service, as well as award a performance bonus pursuant to the terms of her employment agreement.
Background:
At its August 28, 2018 meeting, the City Council approved an Employment Agreement with Suja Lowenthal providing for her employment as City Manager. Section 5 of the Agreement provides that the Council will annually conduct a performance evaluation of the City Manager and consider a compensation adjustment at that time. At its July 14, 2020 meeting, the City Council approved the first amendment to the City Manager’s employment agreement as of her first anniversary of employment. At its February 23, 2021 meeting, the City Council approved the second amendment to the City Manager’s employment agreement. At its October 25, 2022 meeting, the City Council approved the third amendment to the City Manager’s employment agreement. At its January 23, 2024 meeting, the City Council approved the fourth amendment to the City Manager’s employment agreement.
Under the Brown Act, performance evaluations are conducted in closed session in order to protect the privacy interests of the employee. The privacy interests of public employees in their work performance are no different than those of employees in the private sector.
Past Board, Commission, and Council Actions
City of Hermosa Beach | Page 2 of 3
Meeting Date Description
August 28, 2018 City Council approved the City Manager’s employment agreement.
July 14, 2020 City Council approved the first amendment to the City Manager’s employment agreement.
February 23, 2021 City Council approved the second amendment to the City Manager’s employment agreement.
October 25, 2022 City Council approved the third amendment to the City Manager’s employment agreement.
January 23, 2024 City Council approved the fourth amendment to the City Manager’s employment agreement.
Discussion:
Among other terms, the City Manager’s existing employment agreement states that at the time of her annual performance evaluation the City Council will evaluate the City Manager’s salary and/or any other benefits received by the City Manager. Further, the City Manager may be awarded exceptional performance recognition in the form of a onetime payment up to ten percent (10%) of base salary for exceptional performance during the prior fiscal year. The City Manager’s salary for the 2023–2024 year of service was $273,180.72.
Last month, the City Council conducted the City Manager’s performance evaluation. The proposed results of that performance evaluation are as follows:
An annual salary of Two Hundred Eighty-One Thousand Three Hundred and Seventy-Six Dollars ($281,376.00) for the time period of August 28, 2024 through August 27, 2025.
A one-time performance bonus in the amount of Nineteen Thousand One Hundred and Twenty-Two Dollars and Sixty-Five Cents ($19,122.65) for the prior year.
General Plan Consistency:
This report and associated recommendation have been evaluated for their consistency with the City’s General Plan. Relevant Policies are listed below:
Governance Element
Goal 1. A high degree of transparency and integrity in the decision-making process.
Policies:
1.1 Open meetings. Maintain the community’s trust by holding meetings in which decisions are being made, that are open and available for all community members to attend, participate, or view remotely.
City of Hermosa Beach | Page 3 of 3
1.6 Long-term considerations. Prioritize decisions that provide long-term community benefit and discourage decisions that provide short-term community benefit but reduce long-term opportunities.
Goal 8. A performance-based management and benchmarking program.
Policy:
8.1 Community indicators. Utilize performance metrics, standards, and data collection procedures to evaluate progress towards goals.
Fiscal Impact:
The total cost of the negotiated changes, salary increase plus bonus, for Fiscal Year 2024–2025 is $27,317.93.
Attachments:
1. Resolution No. 24-XXXX
2. Fifth Amendment to the City Manager Employment Agreement
3. Fourth Amendment to the City Manager Employment Agreement
4. Third Amendment to the City Manager Employment Agreement
5. Second Amendment to the City Manager Employment Agreement
6. First Amendment to the City Manager Employment Agreement
7. 2018 City Manager Employment Agreement
Respectfully Submitted by: Patrick Donegan, City Attorney Concur: Myra Maravilla, City Clerk
Noted for Fiscal Impact: Brandon Walker, Administrative Services Director Legal Review: Patrick Donegan, City Attorney
Approved: Suja Lowenthal, City Manager
CITY OF HERMOSA BEACH
RESOLUTION NO. 24-XXXX
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF HERMOSA
BEACH, CALIFORNIA, APPROVING THE FIFTH AMENDMENT TO THE CITY MANAGER EMPLOYMENT AGREEMENT AND AWARDING A ONETIME PERFORMANCE BONUS FOR THE PRIOR FISCAL YEAR WHEREAS, the City of Hermosa Beach and Suja Lowenthal (hereinafter “Employee”) entered into a City Manager Employment Agreement (hereinafter the “Agreement”) as of August 28, 2018, providing for employment of the City Manager of City; and
WHEREAS, the City and Employee entered into four previous amendments to the Agreement; and
WHEREAS, the City Council conducted the Employee’s annual performance review and now the City and Employee desire to amend the Agreement for a fourth time to increase the annual salary paid to Employee; and
WHEREAS, pursuant to Section 5 of the Agreement, the Employee may be given an exceptional performance recognition in the form of a one-time check up to ten percent (10%) of base salary for exceptional performance during the prior fiscal year; and WHEREAS, the City Council desires to award a one-time performance bonus pursuant to the terms of the Agreement; and
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF HERMOSA BEACH, CALIFORNIA, DOES HEREBY RESOLVE AS FOLLOWS:
SECTION 1. The Fifth Amendment to City Manager Employment Agreement (attached as Exhibit “A”) is hereby approved and the Mayor is directed to execute.
SECTION 2. Pursuant to the terms of the Agreement, Employee is hereby awarded a one-time performance bonus in the amount of Nineteen Thousand One Hundred and
Twenty Two Dollars and Sixty-Five Cents ($19,122.65) for the prior fiscal year. This onetime performance bonus is only payable to the Employee via a mandatory contribution to Employee’s 401(a) plan.
SECTION 3. Environmental Review. Pursuant to CEQA Guidelines section 15061 (b) (3), it can be seen with certainty that there is no possibility that the activity contemplated by this resolution may have a significant effect on the environment.
SECTION 4. This resolution shall take effect immediately.
SECTION 5. Severability. If any section, subsection, subdivision, sentence, clause, phrase, or portion of this resolution is for any reason held to be invalid or unconstitutional by the decision of any court of competent jurisdiction, such decision will not affect the validity of the remainder of this resolution. The City Council hereby declares that it would have adopted this resolution, and each and every section, subsection, subdivision, sentence, clause, phrase, or portion thereof, irrespective of the fact that any one or more sections, subsections, subdivisions, sentences, clauses, phrases, or portions thereof is declared invalid or unconstitutional.
SECTION 6. Record of Proceedings. This resolution takes effect immediately and that the City Clerk shall certify to the passage and adoption of this resolution; shall cause the same to be entered among the original resolutions of said City; and shall make a minute of the passage and adoption thereof in the records of the proceedings of the City Council of said City in the minutes of the meeting at which time same is passed and adopted. The City Clerk shall keep a copy of same along with such other documents and records of proceedings as may be designated by the City Manager.
PASSED, APPROVED and ADOPTED on this 12th day of November, 2024.
Dean Francois
PRESIDENT of the City Council and MAYOR of the City of Hermosa Beach, CA
ATTEST: APPROVED AS TO FORM:
________________________________ ________________________________ Myra Maravilla Patrick Donegan
City Clerk City Attorney
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FIFTH AMENDMENT TO
CITY MANAGER EMPLOYMENT AGREEMENT
This FIFTH AMENDMENT TO CITY MANAGER EMPLOYMENT AGREEMENT (hereinafter “FIFTH Amendment”) is made and entered into as of the 12th day of November, 2024, by and between the CITY OF HERMOSA BEACH, a California general law city and municipal corporation (hereinafter “City”) and SUJA LOWENTHAL (hereinafter “Employee”).
R E C I T A L S
A. City and Employee entered into a City Manager Employment Agreement (hereinafter the “Agreement”) as of August 28, 2018 providing for employment of Employee as City Manager of City.
B. Pursuant to Section 5 of the Agreement, the City Council conducted an annual performance evaluation of Employee following her sixth full year of employment and further evaluated her salary to determine whether modifications are appropriate.
C. The parties now desire to modify the Agreement in order to increase Employee’s salary for the seventh year of her employment.
NOW, THEREFORE, in consideration of the foregoing, the parties agree to amend the Agreement as follows:
1. Section 5 of the Agreement is amended in its entirety to read:
“5. Compensation. City agrees to pay Employee for the services required by this Agreement a monthly base annual salary of Two Hundred Eighty-One Thousand Three Hundred and Seventy-Six Dollars ($281,376.00) from August 28, 2024 through August 27, 2025, payable in installments at the same time as other employees of the City are paid.
Employee shall not be entitled automatically to receive cost of living adjustments afforded
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to City’s classified employees or department head level executives, but the City Council may, in its discretion, take the cost of living index into consideration when adjusting Employee’s compensation.
At the time of her annual performance evaluation, or at any other time desired by the City Council, City agrees to evaluate Employee’s salary and/or any other benefits Employee receives under this Agreement and to make modifications in such amounts and to such an extent (whether in the nature of a cost of living adjustment, merit increase, bonus or other compensation enhancement or otherwise) as City Council in its discretion may determine that it is desirable to do so based on Employee’s performance and such other information as Employee may submit as Employee deems relevant to this determination, including evidence of salaries paid to city managers in comparable cities.
Commencing with Employee’s 2022/2023 work year, Employee may be given exceptional performance recognition in the form of a one-time check up to ten percent (10%) of base salary for exceptional performance during the prior fiscal year. Such bonus, if provided, may be paid as regular pay (non-PERSable), converted to deferred compensation (401A or 457 Plan, HSA or other allowed City plan) to the extent allowed by law or some other mechanism mutually agreed by the parties.”
2. The salary adjustments provided for by this Fifth Amendment shall take effect commencing August 28, 2024.
[Signature Page to Follow]
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Except as modified above, in all other respects the Agreement is hereby reaffirmed and in full force and effect.
IN WITNESS THEREOF, the parties have executed this Fifth Amendment as of the day and year first above written.
CITY OF HERMOSA BEACH
DEAN FRANCOIS
MAYOR
ATTEST:
CITY CLERK
EMPLOYEE
SUJA LOWENTHAL
CITY MANAGER
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FOURTH AMENDMENT TO
CITY MANAGER EMPLOYMENT AGREEMENT
This FOURTH AMENDMENT TO CITY MANAGER EMPLOYMENT AGREEMENT (hereinafter “Fourth Amendment”) is made and entered into as of the 23rd day of January, 2024, by and between the CITY OF HERMOSA BEACH, a California general law city and municipal corporation (hereinafter “City”) and SUJA LOWENTHAL (hereinafter “Employee”).
R E C I T A L S
A. City and Employee entered into a City Manager Employment Agreement (hereinafter the “Agreement”) as of August 28, 2018 providing for employment of Employee as City Manager of City.
B. Pursuant to Section 5 of the Agreement, the City Council conducted an annual performance evaluation of Employee following her fifth full year of employment and further evaluated her salary to determine whether modifications are appropriate.
C. The parties now desire to modify the Agreement in order to increase Employee’s salary for the sixth year of her employment.
NOW, THEREFORE, in consideration of the foregoing, the parties agree to amend the Agreement as follows:
1. Section 5 of the Agreement is amended in its entirety to read:
“5. Compensation. City agrees to pay Employee for the services required by this Agreement a monthly base annual salary of Two Hundred Seventy-Three Thousand One Hundred Eighty Dollars and Seventy-Two Cents ($273,180.72) from August 28, 2023 through August 27, 2024, payable in installments at the same time as other employees of the City are paid. Employee shall not be entitled automatically to receive cost of living DocuSign Envelope ID: E44759CE-5BB8-40C4-9AF2-5AB49A3151B5
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adjustments afforded to City’s classified employees or department head level executives, but the City Council may in its discretion take the cost of living index into consideration when adjusting Employee’s compensation.
At the time of her annual performance evaluation, or at any other time desired by the City Council, City agrees to evaluate Employee’s salary and/or any other benefits Employee receives under this Agreement and to make modifications in such amounts and to such an extent (whether in the nature of a cost of living adjustment, merit increase, bonus or other compensation enhancement or otherwise) as City Council in its discretion may determine that it is desirable to do so based on Employee’s performance and such other information as Employee may submit as Employee deems relevant to this determination, including evidence of salaries paid to city managers in comparable cities.
Commencing with Employee’s 2022/2023 work year, Employee may be given exceptional performance recognition in the form of a one-time check up to ten percent (10%) of base salary for exceptional performance during the prior fiscal year. Such bonus, if provided, may be paid as regular pay (non-PERSable), converted to deferred compensation (401A or 457 Plan, HSA or other allowed City plan) to the extent allowed by law or some other mechanism mutually agreed by the parties.”
2. The salary adjustments provided for by this Fourth Amendment shall take effect commencing August 28, 2023.
[Signature Page to Follow]
DocuSign Envelope ID: E44759CE-5BB8-40C4-9AF2-5AB49A3151B5
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Except as modified above, in all other respects the Agreement is hereby reaffirmed and in full force and effect.
IN WITNESS THEREOF, the parties have executed this Fourth Amendment as of the day and year first above written.
CITY OF HERMOSA BEACH
JUSTIN MASSEY
MAYOR
ATTEST:
CITY CLERK
EMPLOYEE
SUJA LOWENTHAL
CITY MANAGER
DocuSign Envelope ID: E44759CE-5BB8-40C4-9AF2-5AB49A3151B5
City of Hermosa Beach | Page 1 of 1
Meeting Date: November 12, 2024
Staff Report No. 24-CMO-055
Honorable Mayor and Members of the Hermosa Beach City Council
TENTATIVE FUTURE AGENDA ITEMS
Attached is the current list of tentative future agenda items for Council’s information.
The tentative future agenda provides a preliminary preview of topics planned for discussion at upcoming City Council meetings over a specified period, typically the next three months. The items listed in this document are "tentatively" scheduled, meaning they are subject to change and should not be considered final until the official agenda for each meeting is posted. This document is a work in progress and offers a glimpse into the City's priorities and planned discussions, allowing stakeholders to anticipate and prepare for potential topics of interest.
Key Features of a Tentative Future Agenda Document:
1. Tentative Schedule: Each agenda item is assigned a tentative date, indicating when it is expected to be discussed. These dates are provisional and may be adjusted based on various factors.
2. Work in Progress: The document is continuously updated as new items emerge, priorities shift, or additional information becomes available. This flexibility ensures City Council can address the most pressing issues in a timely manner.
3. Transparency and Communication: By publishing a tentative future agenda, the City aims to maintain transparency with residents, businesses, and other stakeholders. It helps the community stay informed about potential topics of discussion and provides an opportunity for public engagement and preparation.
4. Fluid Scheduling: The scheduling of agenda items is fluid until the official agenda for a specific City Council meeting is posted. Changes can occur due to various reasons, such as new developments, additional preparatory work required, or changes in workload or priority.
Attachment:
Tentative Future Agenda Items