Beach Cities EWMP | Section 2 | Santa Monica Bay Watershed 2-71 | Page 201 8
compliance schedule, additional non-structural or structural BMPs, or an evaluation of whether any newly proposed BMPs will provide a dry weather benefit.
Table 2-18. Dry Weather RAA Evaluation of Santa Monica Bay Watershed CMLs CML
Effective
Diversion/Disinfection at
Analysis Region Outlet?
WMG MS4
Outfall
Absent?
NSW MS4
Discharges
Absent?
Reasonable
Assurance
Demonstrated?
SMB-5-01 No Yes
To be determined
pending results of
non-stormwater
screening
Yes
SMB-5-02 Yes No Yes
SMB-5-03 Yes Yes Yes
SMB-5-04 No No TBD
SMB-5-05 Yes No Yes
SMB-6-01 Yes No Yes
BCSump Yes No Yes
SMB-6-02 Yes No Yes
SMB-6-03 Yes No Yes
SMB-6-04 No No TBD
SMB-6-05 Yes No Yes
SMB-6-06 No No TBD
2.8 MULTIPLE BENEFITS
Not only is reasonable assurance demonstrated for the water quality objectives, but some of the proposed projects also provide multiple benefits beyond pollutant load reduction. Such benefits are described per individual project in Section 2.6.4 and described in general below.
2.8.1 NEIGHBORHOOD GREENING
Increased green space can positively impact the aesthetics, and even the property value, of highly urbanized areas. Property value tends to increase when an urban neighborhood has green space or trees in sight (Center for Neighborhood Technology [CNT], 2010).
Green infrastructure and green space can also alleviate urban heat-island effects by reducing temperatures by about 5oF through shade and evaporation (CNT, 2010). Urban heat-island effects describe the process by which urbanized regions become warmer than their rural surroundings due to an increase in black top and hardscape surfaces, an increase in vehicular and industrial emissions, and a reduction in shade and green space. Reduced temperatures will in turn reduce both energy consumption needs and the heat and pollution-related risks to human health (CNT, 2010).
2.8.2 WATER CONSERVATION/SUPPLY
Stormwater retained in the regional structural BMPs can be reused for irrigation and other on-site, non-potable uses, thus promoting water conservation and offsetting reliance on the potable water supply.
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2.8.3 GROUNDWATER RECHARGE
Stormwater capture may increase groundwater supplies in cases where BMPs are designed for water supply augmentation and captured stormwater is recharged to groundwater basins that are used as drinking water sources. Green infrastructure allows captured runoff to infiltrate to useable groundwater basin storage. Due to the proximity to coastal aquifers, there may be limited groundwater recharge benefit in the proposed BMPs. However, this design option and potential benefit can be further explored as more site information is collected during the feasibility assessment and design phase for each BMP.
2.8.4 PUBLIC EDUCATION/AWARENESS
Public education and outreach engages the public’s interest in preventing stormwater pollution and is achieved most effectively through an understanding of the varying levels of public background knowledge about stormwater management and pollution prevention (USEPA, 2014).
Public outreach is a major facet of the public retrofit incentives element of the RAA approach, which is directed at incentivizing the public to decrease the amount of stormwater runoff from their property, specifically via downspout disconnects. Outreach for this incentive may occur in the form of direct conversations, a variety of media, and/or short training courses, for example. Structural BMPs proposed in the EWMP will also serve as public education opportunities in the form of onsite educational materials, such as signage posted at construction and completed sites.
2.8.5 FLOOD CONTROL
Flood control benefits can exist in the context of:
• Localized flooding, caused by runoff before it enters a drain, causing property damage or traffic hazards. Regional BMPs can have significant impact on mitigating risk to localized flooding issues.
• Riverine flooding, occurring when flow exceeds the carrying capacity of the river, resulting in risk of overbank flow. Large regional BMPs will reduce pressure on the flood control capacity of streams.
• Coastal Flooding, occurring when local drainage infrastructure is overwhelmed during coast storm surges. Regional BMPs can significantly reduce pressure on local drainage, reducing risk of flooding to low lying coastal neighborhoods during coastal storm surges.
Depending on the type, size and location of the BMP, multiple benefits for one or more of the flood control scenarios may be provided. Cities and towns are beginning to recognize that green infrastructure practices provide a feasible and cost-effective alternative that manages precipitation on-site and reduces loads in local storm sewers and waterways. These solutions can not only reduce localized flooding, but can also significantly reduce negative downstream impacts in a way that traditional grey infrastructure solutions are less able to do (American Rivers, et al., 2012).
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2.9 PARALLEL COMPLIANCE EFFORTS
During the remaining compliance period, the Beach Cities WMG may also elect to perform special studies to evaluate the SMBBB dry and wet weather WLAs. Various pathways are available to reopen the TMDL and modify the WLAs, including use of microbial source tracking to support a natural source exclusion, and quantitative microbial risk assessment to develop site specific objectives as allowed by the recent USEPA recreational criteria update. Furthermore, TMDL WLA changes are anticipated if the pending statewide bacteria objectives are adopted. The proposed changes for marine water include removal of the total coliform, fecal coliform, and fecal-to-total coliform ratio objectives, changing the enterococcus single sample maximum of 104 MPN/100ML to a statistical threshold value (10% allowed exceedances in a 30 day period) of 110 MPN/100mL, and other clarification and implementation guidance. Through the adaptive management process, the RAA may be reevaluated after any changes to the statewide objectives, TMDL WLAs, and/or Permit limits.
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3 DOMINGUEZ CHANNEL WATERSHED
3.1 BACKGROUND
3.1.1 GEOGRAPHICAL CONTEXT
The northeastern portion of the Beach Cities EWMP Area is tributary to Dominguez Channel 19 (including Torrance Carson Channel) and is comprised of approximately 7,380 acres of land (Figure 3-1), the majority of which is comprised of residential land uses (Figure 3-2). This watershed accounts for 48% of the total Beach Cities EWMP Area, and includes portions of the Cities of Manhattan Beach, Redondo Beach, and Torrance. Storm drains from the Cities of Manhattan Beach and Redondo Beach drain through the City of Lawndale before discharging to Dominguez Channel. The City of Torrance’s MS4 discharges directly to Dominguez Channel and Torrance Carson Channel (Torrance Lateral). Collectively, this portion of the study area is hereinafter referred to as the Dominguez Channel Watershed.
LACFCD is not responsible for land within the Beach Cities EWMP Area, but does own and maintain infrastructure within all three watersheds. Background information on the LACFCD is provided in Appendix G. Table 3-1 provides a breakdown of the Beach Cities EWMP Area by city and tributary watershed. This section of the EWMP focuses on the Dominguez Channel Watershed only.
Table 3-1. Beach Cities WMG Area Distribution by Participating Agency Participating Agency
Area (acres)
Santa Monica Bay
Watershed
Dominguez Channel
Watershed
Total EWMP Area
(% of total)
City of Redondo Beach 2,614 1,217 3,831 (25%)
City of Manhattan Beach 2,078 350 2,428 (16%)
City of Hermosa Beach 832 - 832 (5%)
City of Torrance 2,314 5,812 8,126 (53%)
Total 7,837 7,379 15,217 (100%)
19 Other portions of the Dominguez Channel Watershed, including Los Angeles County Unincorporated areas, are addressed by separate EWMP groups.
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Figure 3-1. Beach Cities WMG MS4 Infrastructure within the Dominguez Channel Watershed
Beach Cities EWMP | Section 3 | Dominguez Channel Watershed 3-3 | Page 201 8
Figure 3-2. Beach Cities WMG Land Uses within the Dominguez Channel Watershed
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3.2 IDENTIFICATION OF WATER QUALITY PRIORITIES
As part of the EWMP, the Permit requires the Beach Cities WMG to identify water quality priorities within their EWMP AREA. To accomplish this per Permit Section VI.C.5.a, the Beach Cities WMG conducted the following for the Dominguez Channel Watershed portion of the Beach Cities EWMP Area:
1. Characterize the water quality of stormwater and non-stormwater discharges from the MS4 as well as receiving water bodies;
2. Prioritize WBPCs; and
3. Assess sources for high priority water body.
A summary of results is provided below.
3.2.1 WATER QUALITY CHARACTERIZATION
Beneficial Uses
As discussed in Section 2.2.1, the Basin Plan (LARWQCB, 1995, updated 2011) identifies receiving waters within the Los Angeles region and sets regulatory objectives for these receiving waters. The Basin Plan regulates waste discharges to protect the quality of surface waters for use and enjoyment by the general public. Regulations set forth in the Basin Plan are based on assigned beneficial uses for each receiving water body. Beneficial use designations for receiving waters within the Beach Cities WMG Area are defined in Section 2.2.1 and summarized in Table 3-2 below.
Table 3-2. Beach Cities EWMP Area – Dominguez Channel Watershed Water Bodies and Beneficial Uses
Water Body
MUNINDNAVREC1REC2HFSCOMMWARMMARWILDRAREMIGRSPWNSHELLWET3 Dominguez Channel P1 P E E P P E
Torrance Lateral2 P1 P E E P P E
E = Existing beneficial use
P = Potential beneficial use
1 Designated under SB 88-63 and RB 89-03. Some designations may be considered for exemption at a later date.
2 Listed in Basin Plan Table 1 as a “major surface water,” tributary to Dominguez Channel Estuary. 3 Water bodies designated as WET may have wetlands habitat associated with only a portion of the water body. Any regulatory action would require a detailed analysis of the area.
The high flow suspension beneficial use, which was approved by the USEPA as a Basin Plan Amendment in 2004, applies to Dominguez Channel and its tributaries. During days on which this beneficial use suspension is in effect, bacteriological objectives applicable to Dominguez Channel and its tributaries are suspended. The high flow suspension applies on days with rainfall greater than or equal to ½ inch and the 24 hours following the end of such an event.
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Dominguez Channel Watershed Data Analysis
An evaluation of existing water quality conditions, including characterization of stormwater and non-stormwater discharges from the MS4 as well as water quality of the receiving water bodies within the Beach Cities WMG Area, was carried out as part of this EWMP to support identification and prioritization/sequencing of management actions, to the extent possible based on available data. Analyzed raw monitoring data were limited to data collected as part of the Mass Emission Station monitoring program established by the Los Angeles County Department of Public Works (LACDPW). No other data within Dominguez Channel were known to exist. Data were analyzed from two relevant monitoring stations: the Dominguez Channel Mass Emission Station (Station S28), located in Dominguez Channel at Artesia Blvd on the Torrance city boundary; and Tributary Station “Project No. 1232” (Station TS19), located in Torrance Carson Channel (Torrance Lateral) within the City of Carson. The ten most recent years of data (2003 to 2013) from Mass Emission Station S28 were used; all available data (2008 to 2011) from Station TS19 were used.
3.2.2 WATER BODY-POLLUTANT CLASSIFICATION
Receiving waters for stormwater runoff from the Dominguez Channel Watershed portion of the Beach Cities EWMP area were screened for water quality priorities by reviewing TMDLs, the State’s 303(d) list, and recent available water quality data. Each identified water quality priority for a given receiving water body was categorized as a WBPC. WBPCs were classified into one of three categories, in accordance with Section VI.C.5(a).ii of the Permit, and further detailed in Section 2.2.2 herein.
Figure 2-3 in Section 2.2.2 provides a conceptual overview of the process used to identify and categorize the WBPCs within the Beach Cities EWMP Area. In order to categorize and prioritize the WBPCs within the Dominguez Channel Watershed portion of the Beach Cities EWMP Area, relevant TMDLs, 303(d) listings, recent available monitoring data, and water quality objectives from the Basin Plan were considered.
Category 1 – Highest Priority
WBPCs under Category 1 (highest priority) are defined in the Permit as “water body-pollutant combinations for which WQBELs and/or RWLs are established in Part VI.E and Attachments L through R of [the Permit].” These WBPCs include:
• Dominguez Channel for copper, lead, and zinc in wet weather: These WBPCs are considered Category 1 due to the Dominguez Channel and Greater Los Angeles and Long Beach Harbor Waters Toxics and Metals TMDL (Dominguez Channel Toxics TMDL) (LARWQCB, 2011). • Dominguez Channel for toxicity: This is considered Category 1 due to the Dominguez Channel and Greater Los Angeles and Long Beach Harbor Waters Toxics and Metals TMDL. Toxicity was not modeled for Dominguez Channel and Torrance Lateral as part of the RAA due to the fact that there is currently a lack of evidence supporting a linkage between MS4 discharges and exceedances of toxicity. Toxicity will continue to be monitored under the Beach Cities’ CIMP. • Dominguez Channel Estuary for copper, lead, zinc, cadmium, DDT, PAHs, and PCBs: These WBPCs are considered Category 1 due to the Dominguez Channel Toxics TMDL (LARWQCB,
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2011). According to the Dominguez Channel WMA EWMP (DC WMG, 2015), relationships between TSS and historical organics were evaluated to determine if TSS could be used as a surrogate for historical organics. As there were significant non-detects in the available water quality data, a relationship between historic organics and TSS could not be established in the available Dominguez Channel monitoring data. Other studies have shown that relationship between TSS and historical organics can exist; however, the water quality depends on the storm event, soil disturbance, and other factors. It was assumed that if water column pollutant targets were met in Dominguez Channel, the targets would also be met downstream in the Dominguez Channel Estuary, which is the receiving water to Dominguez Channel. Sediment-borne pollutants would also be reduced by the same BMPs that are being used to address the water column pollutants. For these reasons, it was not necessary to perform a separate Reasonable Assurance Analysis for the Dominguez Channel Estuary. If monitoring data show that Dominguez Channel discharges are not meeting sediment objectives, a Reasonable Assurance Analysis will be conducted for sediment and the EWMP will be revised accordingly.
Category 2 – High Priority
Category 2 (high priority) WBPCs are defined as “pollutants for which data indicate water quality impairment in the receiving water according to the State’s Water Quality Control Policy for Developing California’s Clean Water Act Section 303(d) List (State Listing Policy) (SWRCB, 2004) and for which MS4 discharges may be causing or contributing to the impairment.” Aside from those WBPCs already identified as Category 1, the remaining WBPC list can be condensed by excluding pollutants which are not stormwater related (i.e., MS4 discharges are unlikely to cause or contribute to the impairment) as well as pollutants which are already being addressed (directly or indirectly) by one of the TMDLs. Therefore, the Category 2 WBPCs are limited to the following:
• Dominguez Channel (including Torrance Lateral) for indicator bacteria. This qualifies as a Category 2 WBPC based on the 303(d) listing for indicator bacteria. • Dominguez Channel (including Torrance Lateral) for ammonia. In conformance with Permit requirements, this qualifies as a Category 2 WBPC based on the 303(d) listing for ammonia.
However, monitoring data since 2003 show that all water quality samples at S28 and TS19 meet the freshwater Basin Plan Objective for ammonia. As a result, ammonia will not be modeled as part of the Beach Cities’ RAA. Monitoring for ammonia will occur under the CIMP. If future monitoring data suggest that the Beach Cities’ MS4s may cause or contribute to ammonia exceedances in the receiving water, the EWMP will be revised accordingly. • Dominguez Channel (including Torrance Lateral) for diazinon. Dominguez Channel is also 303(d)-listed for diazinon, although data are not available on the SWRCB’s website since this listing was made prior to 2006. However, as the Dominguez Channel Toxics TMDL staff report states, the USEPA banned diazinon on December 31, 2005. The Dominguez Channel Toxics TMDL staff report (Section 2.6.1) states, "Whereas elevated diazinon levels had been observed concurrently with toxicity in 2002-2005 wet weather samples and therefore diazinon was presumed to be contributing to adverse toxicity results; post-2005 results show no diazinon concentrations above the freshwater guideline. Therefore, it is appropriate to develop freshwater metals and toxicity TMDLs for wet weather; however, the more recent toxicity
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results are not attributable to diazinon and therefore no diazinon TMDLs have been developed for Dominguez Channel." Dominguez Channel and Torrance Lateral data from 2006-2013, which includes 85 total samples between the two monitoring sites, show no exceedances of the chronic diazinon criteria established by the California Department of Fish and Game (0.10 ug/L). Due to the fact that monitoring data since 2006 show that all samples at S28 and TS19 meet the applicable water quality criteria for diazinon, diazinon could reasonably be removed from the State’s 303(d) list for Dominguez Channel and therefore is not included as a Category 2 pollutant for Dominguez Channel (including Torrance Lateral). • Dominguez Channel Estuary for indicator bacteria. This qualifies as a Category 2 WBPC based on the 303(d) listing for indicator bacteria.
• Dominguez Channel Estuary for ammonia. In conformance with Permit requirements, this qualifies as a Category 2 WBPC based on the 303(d) listing for ammonia. However, monitoring data since 2003 show that all water quality samples at S28 and TS19 meet the freshwater Basin Plan Objective for ammonia (Appendix R). As a result, ammonia was not modeled as part of the Beach Cities’ RAA. Monitoring for ammonia will occur under the CIMP. If future monitoring data suggest that the Beach Cities’ MS4s may cause or contribute to ammonia exceedances in the receiving water, the EWMP will be revised accordingly.
Category 3 – Medium Priority
Category 3 (Medium Priority) designations are applied to WBPCs which are not 303(d)-listed but which exceed applicable RWLs contained in the Permit and for which MS4 discharges may be causing or contributing to the exceedance.
The annual monitoring reports published by LACDPW list exceedances of each sampled constituent relative to various water quality criteria, including Basin Plan Objectives (BPOs) and California Toxics Rule (CTR) criteria.20 Raw data from S28 and TS19 have been reevaluated. Aside from the constituents described previously, measured exceedances at S28 and TS19 are summarized in Table 3-3. A single exceedance of the Department of Fish and Game’s chronic criterion for chlorpyrifos (0.05 mg/L) occurred in October 2005 at S28. This exceedance occurred prior to EPA’s December 31, 2005 chlorpyrifos ban. Since this time, 85 total samples from S28 and TS19 have been analyzed for chlorpyrifos and no exceedances have been recorded.
20 Because of some additional water quality criteria used to evaluate exceedances in the County’s annual monitoring reports (e.g., applying Ocean Plan Objectives to freshwater bodies; applying MUN-specific BPOs to potential-MUN-designated water bodies), exceedances were over-reported. As a result, pollutants evaluated as part of this appendix were limited to those pollutants which had at least one reported exceedance since 2003. For pollutants with a reported exceedance since 2003, all historic water quality data from that time forward was evaluated against appropriate water quality criteria. For pollutants with no reported exceedances, it was assumed that LACDPW’s exceedance analyses were accurate.
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Table 3-3. LACDPW Monitoring Results Summary
Pollutant
Dominguez Channel Mass
Emission Station (S28)
Torrance Lateral Tributary
Station (TS19) Water Quality
Criteria
(Source)
No. of
Samples
No. of
Exceedances
%
Exceed
No. of
Samples
No. of
Exceedances
%
Exceed
Cyanide 61 24 39% 25 8 32%
5.2 ug/L
(CTR continuous
concentration)
pH 66 13 20% 26 11 42% 6.5 – 8.5
(BPO)
Selenium 66 3 5% 26 2 8%
5.0 ug/L
(CTR continuous
concentration)
Mercury 66 5 8% 26 3 12%
0.051 ug/L
(CTR human
health criterion,
organisms only)
Dissolved
Oxygen 60 1 2% 25 0 0% 5.0 mg/L (BPO)
Cadmium 66 3 5% 26 1 4%
2.2 ug/L
(CTR continuous
concentration)
In addition, based on water quality data analyses conducted by Dominguez Channel EWMP Group in the Dominguez Channel Estuary, arsenic, chromium, silver, nickel, mercury, and thallium are also considered Category 3 pollutants in the Dominguez Channel Estuary. Details are found in the Dominguez Channel EWMP (DC WMG, 2015).
Although data are not currently available to evaluate a linkage between Beach Cities WMG MS4 discharges and these receiving water exceedances, the following WBPCs are considered Category 3 based on the receiving water exceedances described above:
• Dominguez Channel (including Torrance Lateral) for cyanide, due to exceedances of the CTR continuous concentration criterion for cyanide summarized in Table 3-3. Cyanide was not modeled for Dominguez Channel and Torrance Lateral due to the fact that there is currently a lack of evidence supporting a linkage between MS4 discharges and exceedances of cyanide.
Cyanide will continue to be monitored under the Beach Cities’ CIMP. • Dominguez Channel (including Torrance Lateral) for pH, due to exceedances of the Basin Plan Objective for pH summarized in Table 3-3. However, due to the fact that there is currently no evidence supporting a linkage between MS4 discharges and exceedances of the pH criteria, pH was not modeled as part of the Beach Cities’ RAA. Monitoring for pH will occur under the CIMP.
If future monitoring data suggest that the Beach Cities’ MS4s may cause or contribute to pH exceedances in the receiving water, the EWMP will be revised accordingly. • Dominguez Channel (including Torrance Lateral) for selenium, due to exceedances of the CTR continuous concentration criterion for selenium summarized in Table 3-3. However, due to the
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fact that there is currently no evidence supporting a linkage between MS4 discharges and exceedances of selenium21, selenium was not addressed in the Beach Cities’ RAA. Monitoring for selenium will occur under the CIMP. If future monitoring data suggest that the Beach Cities’ MS4s may cause or contribute to selenium exceedances in the receiving water, the EWMP will be revised accordingly.
• Dominguez Channel (including Torrance Lateral) for mercury, due to exceedances of the CTR human health criterion for mercury summarized in Table 3-3. Mercury was not modeled for Dominguez Channel and Torrance Lateral as part of the RAA due to the fact that there is currently a lack of evidence supporting a linkage between MS4 discharges and exceedances of mercury. Mercury will continue to be monitored under the Beach Cities’ CIMP. If future monitoring data suggest that the Beach Cities’ MS4s may cause or contribute to mercury exceedances in the receiving water, the EWMP will be revised accordingly. • Dominguez Channel (including Torrance Lateral) for cadmium, due to exceedances of the CTR continuous concentration criterion for cadmium summarized in Table 3-3. Cadmium was not modeled for Dominguez Channel and Torrance Lateral as part of the RAA due to the fact that there is currently a lack of evidence supporting a linkage between MS4 discharges and exceedances of cadmium. Cadmium will continue to be monitored under the Beach Cities’ CIMP.
If future monitoring data suggest that the Beach Cities’ MS4s may cause or contribute to cadmium exceedances in the receiving water, the EWMP will be revised accordingly. • Dominguez Channel Estuary for arsenic, due to exceedances of the proposed Effect Range Low (ERL) sediment quality guideline for arsenic. Arsenic was not modeled for Dominguez Channel Estuary as part of the RAA due to the fact that there is currently a lack of evidence supporting a linkage between MS4 discharges and exceedances of arsenic. Arsenic will continue to be monitored under the Beach Cities’ CIMP. If future monitoring data suggest that the Beach Cities’ MS4s may cause or contribute to arsenic exceedances in the receiving water, the EWMP will be revised accordingly.
• Dominguez Channel Estuary for chromium, due to exceedances of the proposed ERL sediment quality guideline for chromium. Chromium was not modeled for Dominguez Channel Estuary as part of the RAA due to the fact that there is currently a lack of evidence supporting a linkage between MS4 discharges and exceedances of chromium. Chromium will continue to be monitored under the Beach Cities’ CIMP. If future monitoring data suggest that the Beach Cities’ MS4s may cause or contribute to chromium exceedances in the receiving water, the EWMP will be revised accordingly.
• Dominguez Channel Estuary for silver, due to exceedances of the CTR continuous saltwater concentration criterion for silver. Silver was not modeled for Dominguez Channel Estuary as part of the RAA due to the fact that there is currently a lack of evidence supporting a linkage between MS4 discharges and exceedances of silver. Silver will continue to be monitored under
21 Water quality results from urban runoff throughout Southern California show average selenium concentrations to be well below the referenced CTR criterion of 5 ug/L. A 2003 study by SCCWRP examined selenium concentrations in runoff from five different developed land uses types. Findings showed that even 90th percentile concentrations for each land use were all below the 5 ug/L threshold, with the largest 90th percentile concentration being 2.9 ug/L from agricultural land (Ackerman and Schiff, 2003).
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the Beach Cities’ CIMP. If future monitoring data suggest that the Beach Cities’ MS4s may cause or contribute to silver exceedances in the receiving water, the EWMP will be revised accordingly.
• Dominguez Channel Estuary for nickel, due to exceedances of the CTR continuous and maximum saltwater concentration criteria for nickel. Nickel was not modeled for Dominguez Channel Estuary as part of the RAA due to the fact that there is currently a lack of evidence supporting a linkage between MS4 discharges and exceedances of nickel. Nickel will continue to be monitored under the Beach Cities’ CIMP. If future monitoring data suggest that the Beach Cities’ MS4s may cause or contribute to nickel exceedances in the receiving water, the EWMP will be revised accordingly.
• Dominguez Channel Estuary for mercury, due to exceedances of the proposed ERL sediment quality guideline and the CTR human health criterion for mercury. Mercury was not modeled for Dominguez Channel Estuary as part of the RAA due to the fact that there is currently a lack of evidence supporting a linkage between MS4 discharges and exceedances of mercury.
Mercury will continue to be monitored under the Beach Cities’ CIMP. If future monitoring data suggest that the Beach Cities’ MS4s may cause or contribute to mercury exceedances in the receiving water, the EWMP will be revised accordingly.
• Dominguez Channel Estuary for thallium, due to exceedances of the CTR human health criterion for thallium. Thallium was not modeled for Dominguez Channel Estuary as part of the RAA due to the fact that there is currently a lack of evidence supporting a linkage between MS4 discharges and exceedances of thallium. Thallium will continue to be monitored under the Beach Cities’ CIMP. If future monitoring data suggest that the Beach Cities’ MS4s may cause or contribute to thallium exceedances in the receiving water, the EWMP will be revised accordingly.
Table 3-4 summarizes the prioritized WBPCs within the Dominguez Channel Watershed portion of the Beach Cities EWMP Area.
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Table 3-4. Water Body-Pollutant Combination Prioritization and Pollutant Interim and Final Compliance Targets for Dominguez Channel Watershed
Category
Water
Body Pollutant
Reason for
Categorization
WQBEL/RWL/
Objective Basis
Interim WQBEL/
RWL
Final WQBEL/RWL/
Objective
1: Highest
Priority
Dominguez
Channel
(including
Torrance
Lateral) 1
Toxicity
Dominguez
Channel Toxics
TMDL
Monthly Average 2 TUc 2 1 TUc
Total
Copper
Dominguez
Channel Toxics
TMDL
Wet Weather Single
Event 207.51 ug/L2 9.7 ug/L
Total Lead
Dominguez
Channel Toxics
TMDL
Wet Weather Single
Event 122.88 ug/L2 42.7 ug/L
Total Zinc
Dominguez
Channel Toxics
TMDL
Wet Weather Single
Event 898.87 ug/L2 69.7 ug/L
Dominguez
Channel
Estuary
Total
Copper
Dominguez
Channel Toxics
TMDL
Annual Average 220 mg/kg sediment2 22.4 kg/yr
Total Lead
Dominguez
Channel Toxics
TMDL
Annual Average 510.0 mg/kg
sediment2 54.2 kg/yr
Total Zinc
Dominguez
Channel Toxics
TMDL
Annual Average 789.0 mg/kg
sediment2 271.8 kg/yr
Cadmium
Dominguez
Channel Toxics
TMDL
Daily Maximum n/a 1.2 mg/kg sediment
DDT
Dominguez
Channel Toxics
TMDL
Annual Average 1.727 mg/kg
sediment2 0.25 g/yr
Total PAHs
Dominguez
Channel Toxics
TMDL
Annual Average 31.60 mg/kg
sediment2 0.134 kg/yr
PCBs
Dominguez
Channel Toxics
TMDL
Annual Average 1.490 mg/kg
sediment2 0.207 g/yr
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Category
Water
Body Pollutant
Reason for
Categorization
WQBEL/RWL/
Objective Basis
Interim WQBEL/
RWL
Final WQBEL/RWL/
Objective
2: High
Priority
Dominguez
Channel
(including
Torrance
Lateral)
Indicator
Bacteria 303(d) List Exceedance Rate
over 30-day Period n/a See Footnote 3
Ammonia 303(d) List 1-hour Average n/a
Dominguez
Channel
Estuary
Indicator
Bacteria 303(d) List Single Event and
Geometric Mean n/a See Footnote 3
Ammonia 303(d) List 1-hour Average n/a 0.233mg N/L or limit calculated using Equation 1, whichever is greater
3: Medium
Priority
Dominguez
Channel
(including
Torrance
Lateral)
Cyanide
Historic
exceedances of the
California Toxics
Rule (CTR)
continuous
concentration
water quality
objective (5.2
ug/L)
Continuous
Monitoring n/a 5.2 ug/L
pH
Historic
exceedance of the
Basin Plan
Objective (6.5 –
8.5)
Continuous
Monitoring n/a 6.5 - 8.5
𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸 𝐿𝐿𝐿𝐿𝐿𝐿𝐿𝐿 � 𝑚𝑚 𝑁𝑁
𝐿𝐿 � =
0.411
1+107.204 −𝑝𝑝𝑝𝑝+ 58.41+10𝑝𝑝𝑝𝑝−7.204 (Equation 1)
Beach Cities EWMP | Section 3 | Dominguez Channel Watershed 3-13 | Page 201 8
Category
Water
Body Pollutant
Reason for
Categorization
WQBEL/RWL/
Objective Basis
Interim WQBEL/
RWL
Final WQBEL/RWL/
Objective
Selenium
Historic
exceedances of the
CTR continuous
concentration
water quality
objective (5.0
ug/L)
Continuous
Monitoring n/a 5.0 ug/L
Mercury
Historic
exceedances of the
CTR human health
criterion for
organisms only
(0.051 ug/L)
Continuous
Monitoring n/a 0.051 ug/L
Cadmium
Historic
exceedances of the
CTR continuous
concentration
water quality
objective (2.2
ug/L)
Continuous
Monitoring n/a 2.2 ug/L
Dominguez
Channel
Estuary
Arsenic
Historic
exceedances of the
Effects Range-Low
(ERL) proposed
sediment quality
guidelines from the
National Status
and Trends
database (8.2
mg/kg sediment)
Continuous
Monitoring n/a 8.2 mg/kg sediment
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Category
Water
Body Pollutant
Reason for
Categorization
WQBEL/RWL/
Objective Basis
Interim WQBEL/
RWL
Final WQBEL/RWL/
Objective
Chromium
Historic
exceedances of the
ERL proposed
sediment quality
guidelines from the
National Status
and Trends
database (81
mg/kg sediment)
Continuous
Monitoring n/a 81 mg/kg sediment
Silver
Historic
exceedances of the
CTR continuous
saltwater objective
(1.9 ug/L)
Continuous
Monitoring n/a 1.9 ug/L
Nickel
Historic
exceedances of the
CTR maximum
saltwater objective
(74 ug/L) and
the CTR
continuous
saltwater objective
(8.2 ug/L )
Continuous
Monitoring n/a
8.2 ug/L (continuous)
74 ug/L (maximum)
Mercury
Historic
exceedances of the
ERL proposed
sediment quality
guidelines from the
National Status
and Trends
database (0.15
mg/kg sediment)
and the CTR
human health
Continuous
Monitoring n/a 0.15 mg/kg sediment
0.051 ug/L
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Category
Water
Body Pollutant
Reason for
Categorization
WQBEL/RWL/
Objective Basis
Interim WQBEL/
RWL
Final WQBEL/RWL/
Objective
criterion for
organisms only
(0.051 ug/L)
Thallium
Historic
exceedances of the
CTR human health
criterion for
organisms only
(6.3 ug/L)
Continuous
Monitoring n/a 6.3 ug/L
1 Wet weather only, based on the Dominguez Channel Toxics TMDL 2 The interim deadline for Dominguez Channel Toxic TMDL is 3/23/2012. Hence the interim target is no longer applicable 3 Per the Basin Plan Objective REC1 Water Bodies Limit for Indicator Bacteria.
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The Beach Cities WMG agencies understand that data collected as part of their approved CIMP may result in future Category 3 designations in instances when RWLs are exceeded and MS4 discharges are identified as contributing to such exceedances. Under these conditions, the Beach Cities WMG agencies will adhere to Section VI.C.2.a.iii of the Permit.
Sections VI.C.2 and VI.C.3 of the Permit describe how compliance with RWLs and WQBELs is attained for the prioritized WBPCs identified. Appendix H sets forth the EWMP framework for evaluating and addressing receiving water exceedances and a brief summary is included below.
Different actions are required to demonstrate compliance for different types of WBPCs. Specifically; the following classifications are addressed by the Permit:
• WBPCs Addressed by a TMDL;
• 303(d)-listed WBPCs: Pollutants in the same class as those identified in a TMDL and for which the water body is 303(d)-listed (Section VI.C.2.a.i), and pollutants not in the same class as those identified in a TMDL, but for which the water body is 303(d)-listed (Section VI.C.2.a.ii); and • Non 303(d)-listed WBPCs: Pollutants for which there are exceedances of RWLs, but for which the water body is not 303(d)-listed (Section VI.C.2.a.iii).
For WBPCs already addressed by a TMDL, adherence to all requirements and compliance dates as set forth in the approved EWMP will constitute compliance with applicable interim TMDL-based water quality based effluent limits and interim receiving water limits. 303(d)-listed WBPCs are equivalent to the identified Category 2 combinations. For any Category 2 and 3 WBPCs that are identified in the future through the adaptive management process, adherence to all implementation actions, milestones, and compliance schedules identified in the updated EWMP will constitute compliance with applicable receiving water limits. This approach is outlined in Appendix H.
Category 2 and 3 parameters will also be monitored under the Beach Cities’ CIMP and if future monitoring data suggest that the Beach Cities’ MS4s may cause or contribute to exceedances of these pollutants in the receiving water, the EWMP will be revised to address these pollutants.
3.2.3 SOURCE ASSESSMENT
The following data sources have been reviewed as part of the source assessment for the WBPCs listed previously:
• Findings from the Permittees’ IC/ID Programs;
• 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 TMDL compliance monitoring and receiving water monitoring; and
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• Any other pertinent data, information, or studies related to pollutant sources and conditions that contribute to the highest water quality priorities.
Since sources of pollutants for the various water bodies within the Beach Cities WMG Area are essentially identical based on similarity of land uses (e.g., sources of trash within SMB Watershed and Dominguez Channel Watershed are believed to be the same), the following source assessment is broken down by pollutants applicable to the Dominguez Channel Watershed.
Copper, Lead, and Zinc
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.
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).
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
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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.
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 right-of-ways), 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 direct discharges of these chemicals to Dominguez Channel, SMB, and other local surface water bodies, except from legacy sources.
Additional sources of toxicity within the Dominguez Channel Watershed are unknown at this time.
Therefore, toxicity monitoring will be conducted under the Beach Cities CIMP to help assess if MS4 discharges are causing or contributing toxicity exceedances in Dominguez Channel. In addition, a toxicity identification evaluation (TIE) will be performed as necessary to identify the compound(s) responsible for any observed toxicity.
Indicator Bacteria
Although the Dominguez Channel is 303(d) listed for indicator bacteria, a bacteria TMDL has not yet been developed for the watershed. The source assessment for indicator bacteria within the Santa Monica Bay watershed portion of the Beach Cities EWMP area is provided in Section 2.2.3, and many of these urban anthropogenic and non-anthropogenic sources apply to the Dominguez Channel portion of the Beach Cities EWMP Area as well.
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Additional local monitoring data will be needed to quantify the contribution of MS4 discharges – particularly relative to the many other identified non-anthropogenic sources that have been documented. Additional data are also needed to identify the sources of bacteria within MS4 discharges as well as their potential to contribute to recreational illness risks; such source tracking data have the potential to affect the TMDL WLAs through a future reopener. For example, if human fecal sources are found to be undetected in MS4 discharges to Dominguez Channel using a rigorous sampling design, the latest analytical markers, and a credible laboratory, then TMDL revisions may be proposed. And the combination of MS4 outfall monitoring (through the CIMP) and source identification (through special studies) will be essential to support future BMP planning and EWMP updates.
Ammonia
Monitoring data since 2003 show that all water quality samples at S28 and TS19 meet the freshwater Basin Plan Objective for ammonia. Because ammonia does not exceed water quality standards, a source assessment has not been completed at this time.
Generally, ammonia enters urban creeks via anthropogenic sources or discharges such as municipal effluent discharges, agricultural runoff, and natural sources such as nitrogen fixation, the excretion of nitrogenous wastes from animals, and runoff from agricultural lands (USEPA, 2013a).
Diazinon
Dominguez Channel and Torrance Lateral data from 2006-2013, which includes 85 total samples between the two monitoring sites, show no exceedances of the chronic diazinon criteria established by the California Department of Fish and Game (0.10 ug/L). No diazinon TMDLs have been developed at this time. Due to the fact that monitoring data since 2006 show that all samples at S28 and TS19 meet the applicable water quality criteria for diazinon, a source assessment has not been completed at this time.
Generally, diazinon in urban creeks may be attributed to urban runoff that contains pesticides as a result of such activities as application by businesses and individuals who apply them for structural pest control, landscape maintenance, agricultural, and other pest management purposes (Werner, et al., 2002).
3.2.4 PRIORITIZATION
Based on the water quality characterization above, the WBPCs have been classified into one of three categories, in accordance with Section IV.C.5(a)ii of the Permit: highest priority, high priority, and medium priority (Table 3-4). 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 and 2. WBPCs will be further prioritized based on the applicable compliance schedules, as discussed in Section 4.
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3.3 SELECTION OF APPROPRIATE BEST MANAGEMENT PRACTICES
3.3.1 OBJECTIVES
The Permit requires the Beach Cities WMG to identify strategies, control measures, and BMPs to implement within their EWMP area. Specifically, the Permit specifies that BMPs are expected to be implemented so that MS4 discharges meet effluent limits as established in the Permit and to reduce impacts to receiving waters from stormwater and non-stormwater runoff. This expectation assumes the implementation of both types of BMPs – non-structural and structural – by the Beach Cities WMG.
The objectives of selecting and incorporating BMPs into the Beach Cities EWMP include:
1. Preventing and/or eliminating non-stormwater discharges to the MS4 that are a source of pollutants from the MS4 to receiving waters;
2. Achieving all applicable interim and final WQBELs and/or RWLs pursuant to corresponding compliance schedules; and
3. Ensuring that discharges form the MS4 do not cause or contribute to exceedances of RWLs.
3.3.2 DEFINITION OF BEST MANAGEMENT PRACTICES
See Section 2.3.2.
3.3.3 INCORPORATED PROVISIONS
Minimum Control Measures
See Section 2.3.3.
Non-Stormwater Discharge Measures
The Permit requires Permittees to identify non-stormwater discharges that cause or contribute to exceedances of RWLs, and to then identify and implement BMPs to effectively eliminate the source of pollutants. These BMPs may include measures to prohibit non-stormwater discharge to the MS4, additional structural BMPs to reduce pollutants in the non-stormwater discharge, diversion to a sanitary sewer for treatment, or strategies to require the non-stormwater discharge to be separately regulated under a general NPDES permit. In contrast to Santa Monica Bay, Dominguez Channel Watershed does not have low flow diversions; however, within the Cities of Redondo Beach and Manhattan Beach, the implementation of two regional BMPs at both outlets from the EWMP area (see Section 3.6.4) will control dry weather flows by capturing the small flows in the pretreatment volume and either retaining them or treating them in the media filter. In addition, the cities each have water conservation ordinances which include elimination of irrigation overspray.
The non-stormwater screening process consists of the steps shown in Figure 2-4. Further details on the Beach Cities WMGs’ approach to meet this requirement are provided in the CIMP for the Beach Cities Watershed Management Group (Beach Cities Watershed Management Group, 2014).
The watershed control measures proposed within Dominguez Channel that are expected to
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eliminate non-stormwater discharges meet the requirements as set forth in Parts III.A and VI.D.4.d and VI.D.10 of the LA County MS4 Permit.
The following schedule is proposed to eliminate unauthorized non-stormwater discharges that are either causing or contributing to receiving water exceedances in Dominguez Channel Watershed:
• December 2023: 50% volume reduction of significant non-stormwater discharges. • December 2025: 100% elimination of all significant non-stormwater contributions.
Since there is no bacteria TMDL for Dominguez Channel, the final compliance date for dry weather bacteria was selected to be consistent with the draft TMDL for indicator bacteria in the San Gabriel River, Estuary and Tributaries, adopted by the LARWQCB in 2015, which requires that compliance is achieved with applicable MS4 WLAs 10 years after the effective date of the TMDL (Water Quality Control Plan, Attachment A to Resolution No. R15-0xx, adopted by the RWQCB in 2015).
TMDL-Specific Control Measures
See Section 2.3.3.
Additional BMPs
See Section 2.3.3.
Demonstration of BMP Performance – Introduction to the Reasonable Assurance Analysis
See Section 2.3.3.
Legal Authority
The Permit-required legal authority that the Beach Cities WMG has to implement the BMPs identified in the EWMP is discussed in Section 8.
3.4 REASONABLE ASSURANCE ANALYSIS APPROACH
The general approach used for Dominguez Channel is described below with references to relevant portions of Section 2 where the approaches or data used in the Santa Monica Bay Watershed are similar (e.g., for calculating bacteria TLRs).
3.4.1 DESCRIPTION OF RAA TOOLS AND APPROACH
The approaches for performing the RAA in both dry and wet weather are described below.
Dry Weather
For the purposes of the dry weather RAA, the EWMP area draining to Dominguez Channel was combined into a single analysis region, for which bacteria was the only applicable dry weather WBPC specific to both Dominguez Channel and Dominguez Channel Estuary and total lead, copper, and zinc were dry weather WBPCs specific to Dominguez Channel Estuary.
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The Beach Cities WMG dry weather compliance approach for Dominguez Channel and subsequently Dominguez Channel Estuary is to eliminate non-exempt dry weather MS4 discharges using a suite of non-structural source controls (e.g., water conservation incentives, enhanced IDDE efforts, and enhanced education/outreach and inspection/enforcement to prevent sources of non-stormwater flow), source investigations following dry weather outfall screening, and structural BMPs that are primarily designed to support wet weather reasonable assurance demonstration. If monitoring shows that this combination of nonstructural and structural BMPs does not eliminate non-exempt dry weather flows, additional measures such as low flow diversion to sanitary sewers will be constructed as necessary so that dry weather flows are eliminated. By eliminating dry weather flows, this is equivalent to 100% load reduction for all pollutants, thereby demonstrating reasonable assurance of meeting all applicable Permit limitations during dry weather. Elimination of discharges is a pathway for compliance with RWLs and WQBELs in the MS4 permit (per section VI.E.2.e.i.(3)); without discharges there can be no “cause or contribute” to receiving water issues.
Wet Weather
The modeled wet-weather RAA applied in the Dominguez Channel watershed consists generally of the following steps:
• Identify WBPCs for which the RAA will be performed;
• Identify the MS4 service area (exclude lands of agencies not party to this EWMP such as Federal land, State land, etc.);
• For each analysis region, develop TLRs for the critical condition; • Identify structural and non-structural BMPs that were either implemented after applicable TMDL effective dates or are planned for implementation in the future; • Evaluate the performance of these BMPs in terms of annual pollutant load reductions; • Compare these estimates with the TLRs; and
• Revise the BMP implementation scenario until TLRs are met.
For the purposes of the wet weather RAA, the EWMP area draining to Dominguez Channel was combined into a single analysis region to establish TLRs and into two analysis regions, one including the portion of the Cities of Redondo Beach and Manhattan Beach (Dominguez Channel – Redondo Beach/Manhattan Beach [DC-RB/MB]) and one including the portion of the City of Torrance (DC – Torrance), to evaluate the performance of BMPs. The Dominguez Channel Watershed analysis regions are shown in Figure 3-3.
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Figure 3-3. Analysis Regions within the Dominguez Channel Watershed portion of the Beach Cities EWMP Area
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In general, the approach, including model selection, data inputs, critical condition selection (90th percentile year for bacteria and 90th percentile load day for metals), calibration performance criteria, and output types have been selected for consistency with the LARWQCB RAA Guidance Document (LARWQCB, 2014) and to leverage previous efforts where relevant models have already been developed. Previous efforts include the development of a Loading Simulation Program C++ (LSPC) model for the LACFCD in connection with Watershed Management Modeling System (WMMS). LSPC is a publically available watershed model that was developed for the LACFCD in connection with WMMS. This model uses Hydrologic Simulation Program Fortran (HSPF) algorithms to simulate hydrology, sediment transport, water quality on land, and fate and transport within streams. GIS is used for the spatial component of the analysis in addition to visualization.
The LSPC model used for the RAA was recently calibrated by CWE to stream gauge S28 which receives runoff from almost all of the Dominguez Channel Watershed.
To leverage these previous calibration efforts, the portion of the LSPC model within the Dominguez Channel Watershed EWMP Area was used to calibrate SBPAT’s hydrology. SBPAT was used to establish all TLRs in the Dominguez Channel Watershed. SBPAT was also used to perform the RAA for the portion of the Cities of Redondo Beach and Manhattan Beach within the Dominguez Channel Watershed. The RAA for the portion of the City of Torrance within the Dominguez Channel Watershed was performed using SWMM to determine baseline loading and static spreadsheetbased calculations based on a literature review to estimate load reductions from the proposed BMPs. The SWMM model used for baseline loading was calibrated using the recently calibrated LSPC model. Table 3-5 below summarizes the TLR and RAA models used across the Dominguez Channel Watershed for this EWMP. These models are discussed in more detail below.
Table 3-5. RAA Models Used in the Dominguez Channel Watershed City
Model Selection
Set Target Load
Reduction Perform RAA Calibration Data Source
Manhattan Beach SBPAT SBPAT Recently calibrated LSPC
model
Redondo Beach SBPAT SBPAT Recently calibrated LSPC
model
Torrance SBPAT
SWMM for baseline/static
spreadsheet-based
calculations for load
reductions
Recently calibrated LSPC
model
As in the Santa Monica Bay watershed, the Beach Cities RAA was conducted within the Dominguez Channel Watershed to demonstrate reasonable assurance of compliance with Permit specified TMDL RWLs and WQBELs, as well as other RWLs and water quality objectives for non-TMDL WBPCs. In instances where critical conditions were not explicitly defined in the Permit (e.g., a critical condition of “wet weather” without an associated rainfall or flow-based criterion), steps were taken to establish a link between the expressed Permit limit and the modeled pollutant concentrations and loads (i.e., rainfall, runoff, and pollutant concentrations in the runoff). Table 3-6 summarizes these steps for the modeled WBPC in the Dominguez Channel Watershed with a Permit-established limit. According to the Dominguez Channel WMA EWMP (DC WMG, 2015),
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relationships between TSS and historical organics were evaluated to determine if TSS could be used as a surrogate for historical organics. As there were significant non-detects in the available water quality data, a relationship between historic organics and TSS could not be established in the available Dominguez Channel monitoring data. Other studies have shown that relationship between TSS and historical organics can exist; however, the water quality depends on the storm event, soil disturbance, and other factors. It was assumed that if water column pollutant targets were met in Dominguez Channel, the targets would also be met downstream in the Dominguez Channel Estuary, which is the receiving water to Dominguez Channel. Sediment-borne pollutants would also be reduced by the same BMPs that are being used to address the water column pollutants. For these reasons, it was not necessary to perform a separate Reasonable Assurance Analysis for the Dominguez Channel Estuary. If monitoring data show that Dominguez Channel discharges are not meeting sediment objectives, a Reasonable Assurance Analysis will be conducted for sediment and the EWMP will be revised accordingly. Because no evidence currently exists to support a linkage between ongoing MS4 discharges and exceedances of toxicity, mercury, cadmium, cyanide, selenium, or pH in Dominguez Channel, these pollutants were not modeled as part of this analysis.
Table 3-6. Wet Weather Permit Limits (Final Compliance Limits for Modeled Pollutants) Pollutant
RWL/WQBEL from the Permit or
Assumed Based on Other Similar
Los Angeles Region TMDLs Approach for Applying the Critical Period Fecal
Coliform
19% allowed exceedance of the
REC-1 water quality objective, (400
MPN/100mL) on non-high flow
suspension days2.
90th percentile year (based on wet days1) was used
as the critical condition. Allowable number of wet
weather exceedance days for the critical year was
set to % of non-high flow suspension wet days,
rounding down.
Total
Copper WQBEL= 9.7 ug/L *Daily Volume3
90th percentile daily load during wet weather was
used as the critical condition. This calendar day
was identified for each metal by ranking daily metal
loads for wet days1 between 2003 and 2012.
Total
Lead WQBEL= 42.7 ug/L *Daily Volume3
Total
Zinc WQBEL= 69.7 ug/L *Daily Volume3
1 For bacteria, wet days were defined as days with 0.1” or greater of rainfall plus the next three days. For metals, the TMDL defines wet weather as days in which the maximum daily flow at the S-28 gauge on Dominguez Channel is 63 cfs or greater; for the purpose of this RAA, this was assumed to equate to days in which the SBPAT model (which responds to rainfall events greater than 0.1”, had a non-zero flow). 2 High Flow Suspension days are defined based on the criteria used in bacteria TMDLs in the region in which days in which 0.5” or greater of rainfall occurs, and the day following such an event, are both high flow suspension days. 3 The MS4 permit provides both the concentration-based effluent limitations above as well as load based limitations on page N-6 which come from the Dominguez Channel Toxics TMDL. The load-based limitations are based on multiplying the metal concentration-based limitations by the runoff volume on the 90th percentile day. However, the TMDL does not provide quantitative load-based effluent limitations, but instead states that the WLAs are the water quality effluent target multiplied by the daily flow volume. The MS4 permit states that the load-based limitations can be recalculated based on the flow volume at the time of sampling. Therefore, the load-based effluent limitations will change based on the daily flow volume, so the WQBEL is written to account for flow variability.
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Cities of Redondo Beach and Manhattan Beach (DC-RB/MB Analysis Region). SBPAT was used for the portion of the Dominguez Channel Watershed within the Cities of Redondo Beach and Manhattan Beach to evaluate BMP scenarios and demonstrate reasonable assurance of achieving applicable Permit limits. SBPAT was used in the same capacity for the Santa Monica Bay watershed and is described in detail in Section 2.4.1 above.
City of Torrance (DC-Torrance Analysis Region). In general, the RAA approach used within the City of Torrance portion of the Dominguez Channel Watershed was conducted using static spreadsheet calculations coupled with a literature review on the performance of catch basin inlet filters to determine reasonable removal percentages for metals and bacteria.
3.4.2 MODELING DATA
The critical condition definition and a summary of data associated with the models used in the RAA are described below.
Critical Condition Definition
Bacteria. Consistent with all existing Los Angeles region bacteria TMDLs for freshwater bodies, as well as the LARWQCB RAA Guidance (LARWQCB, 2014), the RAA for bacteria was performed on the 90th percentile critical wet year in the Dominguez Channel Watershed. This was determined in the same manner as the Santa Monica Bay portion of the EWMP area as described in Section 2.4.2 using the same rain gauge and the same period of record. The 90th percentile TMDL year (Nov 1-Oct 31), based on the number of wet days based on gage D1070 was determined to be 1995 (see Appendix Q).
Metals. The critical condition for metals is based on the 90th percentile metal load day on wet days (see Appendix Q). Wet days in the Dominguez Channel Toxics TMDL are defined as days where the maximum daily flow at the S-28 stream gauge in lower Dominguez Channel is 62.7 cfs or greater.
Consistent with RAA Guidelines, the most recent 10 year period with available rainfall data was selected; this period was 2003 to 2012 (Nov 1, 2002-Oct 31, 2012). The stream gauge data at this S-28 prior to October 2011 are segmented and do not cover the entire period. This could result in actual wet days that do not get classified as wet days if stream gage data are missing from that day, and could bias the TLR calculations and RAA analysis. Therefore, wet days for this analysis were based on days where the calibrated SBPAT model (which models only wet weather, i.e., no dry weather runoff or baseflows are modeled) predicted non-zero flow. This was compared to the bacteria wet day definition in which days with 0.1” or greater rainfall plus the next three days were counted as wet days. Storms that were greater than 0.1” produced runoff in SBPAT throughout the modeled period, thereby confirming that predicted flow in SBPAT was a reasonable representation of wet days. The calibrated SBPAT model (discussed below) was used to determine the daily metal load on wet days. These days were ranked by their daily metals load for each metal to determine the 90th percentile load day for TLR calculation. The 90th percentile load days were found to be Nov 30, 2007, February 5, 2010, and February 26, 2006 for copper, lead, and zinc, respectively. Other data related to the SBPAT model are discussed in detail in Section 2.4.2.
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3.4.3 CALIBRATION
Hydrology
No stream gauge exists that measures flow from only the Dominguez Channel portion of the EWMP area. However, a stream gauge does exist on lower Dominguez Channel above the Torrance Lateral.
This gauge captures flow from 24,275 acres. Approximately 3,687 acres of the EWMP area drain to this gauge. The rest of the EWMP area drains to the Torrance Lateral and is therefore downstream of this gauge. The EWMP area upstream of this gauge constitutes only 15% of the total area draining to the gauge. Therefore, in lieu of local measured stream flow data from within the EWMP area, a Los Angeles County LSPC model of the Dominguez Channel Watershed which had previously been calibrated to the S28 stream gauge on Dominguez Channel was used as a stream flow calibration comparison dataset for SBPAT. As future monitoring data become available, this calibration may be reassessed as part of the EWMP adaptive management process.
The Los Angeles County LSPC model was previously calibrated by CWE to gauge S28 for the Dominguez Channel watershed using the calibration parameters in Table 3.0 of the RAA Guidelines.
A ten-year calibration period was used (2003-2012). The percent difference for both daily and monthly runoff volumes between the LSPC model and the stream gauge was less than 10%, which is in the ‘very good’ category in the RAA guidelines (CWE, 2015). The mean annual runoff volume in the LSPC model (7,210 acre-ft) was within 12% of the stream gauge volume (8,210 acre-ft) which is in the ‘good’ range in the RAA Guidelines.
For modeling the portion of the Beach Cities EWMP area which drains to Dominguez Channel, the calibrated LSPC model was clipped to the Dominguez Channel analysis region (including Torrance, see Figure 1), while keeping all other model parameters unchanged. Because SBPAT only includes storm generated runoff and LSPC includes dry weather flows (irrigation was turned off for the purposes of this analysis), any dry weather flows were first removed from the LSPC annual volumes using the Web-based Hydrograph Analysis Tool (WHAT) for porous aquifers with ephemeral streams; this tool was developed by Purdue University to separate base flows and runoff. Because dry weather flows are minimal in Dominguez Channel Watershed in the LSPC model, this resulted in a decrease in volume of only 6%.
The SBPAT calibration of the Dominguez Channel analysis region focused on accurate prediction of annual discharge volumes predicted by the LSPC model for TMDL years 1989-2011. The dominant rain gauge used by LSPC (Manhattan Beach Station ID 1070) was also used by SBPAT. This gage had less than 2% difference in total rainfall volume than the aggregate of the surrounding rain gauges making it a good representative gauge for the EWMP area. The calibration parameters were the soil saturated hydraulic conductivities and the land use imperviousness, which were changed by a uniform multiplier for all soil and land use types in all subcatchments to match the LSPC predictions.
Table 3-7 shows the mean annual volume predicted by the calibrated SBPAT model versus the mean annual volume predicted by the calibrated LSPC model for the Dominguez Channel portion of the Beach Cities EWMP area. Figure 3-4 compares the annual volumes predicted by SBPAT to the annual volumes predicted by LSPC for all years between 1989 and 2011. Figure 3-5 presents these same results in a flow duration curve format. The difference in mean annual volume between LSPC
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and the calibrated SBPAT model was 2%, and the difference for the 90th percentile year was 1%, both of which are in the “very good” category for calibration in the RAA Guidelines.
Table 3-7. Mean Annual Volume Predicted by SBPAT and LSPC and Measured at the S28 Stream Gauge
Model/Source Average Annual Volume (acre-ft)
SBPAT 2,943
LSPC 2,890
Stream Gauge -
Difference (%) 2%
Figure 3-4. Annual Runoff Volumes Predicted by LSPC and SBPAT
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Figure 3-5. Annual Runoff Volumes Predicted by LSPC and SBPAT Water Quality
The RAA Guidelines require water quality calibration based on available monitoring data from the most recent 10 years. However, in the portion of the Beach Cities EWMP draining to Dominguez Channel, recent water quality monitoring data are not available for the applicable pollutants for a nearby receiving water monitoring station (the Dominguez Channel mass emission station S28 (Figure 3-2) is located downstream of a portion of the Beach Cities EWMP area, but upstream of the rest and includes large areas outside the EWMP area), so a conventional water quality calibration was not feasible. In the future as new local monitoring data become available, SBPAT’s water quality input parameters may be calibrated as part of the EWMP adaptive management process. In the meantime, to meet current model verification needs for the RAA, SBPAT’s lognormal land use EMC statistics were compared with the original land use monitoring datasets upon which were based. This land use based comparison is consistent with the calibration method applied for the original county-wide LSPC model (Los Angeles County Department of Public Works, 2010).
The land use EMCs used in SBPAT were calculated from data collected by Los Angeles County between 1996 to 2000 (County of Los Angeles, 2000) for metals, and land use-specific data collected by SCCWRP (SCCWRP, 2007) between 2000 to 2005 for fecal coliform. An example of the fecal coliform distribution for high density residential land use from the SCCWRP results and the 0 1,000
2,000
3,000
4,000
5,000
6,000
7,000
8,000
0% 20% 40% 60% 80% 100%
Annual Runoff Volume Prediction (ac-ft)
Percent of Results Below Y-Axis Value (%)
LSPC Output SBPAT Output
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distributions used in SBPAT for multi-family land use are shown in Figure 3-6 for fecal coliform bacteria. An additional example of the zinc distribution for high density residential land use from Los Angeles County results and the distributions used in SBPAT is shown in Figure 3-7. As shown by the percentiles, the pollutant EMC distribution is well representative of measured data. The example is provided for high density residential land use since this is the dominant developed land use in the Dominguez portion of the Beach Cities WMG area. Modeled EMC values are consistent with the recommended values for land use-specific loading in Table 3.3 of the RAA Guidelines.
Figure 3-6. Comparison of Fecal Coliform High Density Residential EMC Values between SCCWRP Measurements (n=7) and Multi-Family Residential EMC distribution in SBPAT22
22 A full log distribution is used by the model, but non-parametric summary statistics are shown for comparison.
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Figure 3-7. Comparison of Total Zinc Multi Family Residential EMC Values between Los Angeles County Measurements (n=4) and Multi-Family Residential EMC distribution in SBPAT23
3.4.4 VALIDATION
A validation step was performed to demonstrate that modeled annual fecal coliform loads are indeed predictive of the compliance metric, or annual exceedance days for fecal indicator bacteria.
For bacteria modeling, verifying the linkage between modeled fecal coliform loads (i.e., discharged from the watershed outlets) and total observed wet weather exceedance days (in the receiving water, based on REC1 daily maximum water quality objectives) was critical to establish reasonable assurance that CMLs would be in compliance with the Permit limits. To establish this linkage, an analysis was conducted using shoreline monitoring data at Topanga Canyon24 (SMB-1-18) between 2005 and 2013. As presented in Section 2.4.4, Figure 2-11 in Section 2.4.4 illustrates that decreasing fecal coliform loads should result in measurable reductions in exceedance days, and that there is a reasonable correlation between total annual modeled fecal coliform loads and total annual observed wet weather exceedance days. Each point shown represents one TMDL year.
23 A full log distribution is used by the model, but non-parametric summary statistics are shown for comparison.
24 Fecal coliform data and objectives were used to represent all fecal indicator bacteria because fecal coliform has the most robust land use and BMP effluent EMC datasets.
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3.5 BASELINE LOADS AND TARGET LOAD REDUCTIONS
Baseline loads for the critical period for bacteria and metals from the entire EWMP area draining to Dominguez Channel were computed using SBPAT. For bacteria, the critical period was the 90th percentile wet TMDL year, which was computed to be 1995 as discussed in Section 3.4.2. For metals, the critical condition is the 90th percentile metal load day between 2003 and 2012. These dates were found to be November 30, 2007, February 5, 2010, and February 26, 2006 for copper, lead, and zinc, respectively, as discussed in Section 3.4.2. The computed baseline conditions for runoff volume, pollutant concentration, and pollutant loading based on 90th percentile critical condition are shown in Table 3-8 below.
Table 3-8. Baseline Runoff, Concentration, and Load for Pollutants in the Dominguez Channel Watershed for the Critical Condition
Pollutant
90th Percentile Critical
Condition
Baseline
Runoff
Average Baseline
Concentration 1
Baseline
Load
Copper 11/30/2007 301 ac-ft/day 25.8 µg/L 21 lb/day
Lead 2/5/2010 275 ac-ft/day 11.6 µg /L 8.7 lb/day
Zinc 2/26/2006 291 ac-ft/day 290.2 µg /L 230 lb/day
Bacteria 11/1/1994-10/31/1995 6,048 ac-ft/yr 20,080
MPN/100 mL
1,498*1012
MPN/yr
1 Average pollutant concentrations are estimated as the total annual load divided by the total annual runoff volume.
The process for establishing TLRs for the modeled WBPCs (copper, lead, zinc, and bacteria in Dominguez Channel) is described in the following section. TLRs were set for the entire Dominguez Channel analysis region, including the cities of Manhattan Beach, Redondo Beach, and Torrance.
Because no evidence currently exists to support a linkage between MS4 discharges and exceedances of toxicity, mercury, cadmium, cyanide, selenium, or pH in Dominguez Channel, these pollutants were not modeled as part of this analysis. This potential linkage will be re-evaluated based on results of future monitoring efforts.
3.5.1 METALS
For the Dominguez Channel and Greater LA Harbor Toxics and Metals TMDL, the final WQBELs in the Permit are expressed as allowed daily loading of total copper, total lead, and total zinc during wet weather. The WQBEL loads were calculated as the CTR freshwater chronic criteria-based numeric target concentrations (9.7, 42.7, 62.7 ug/L for total copper, total lead, and total zinc, respectively) multiplied by the daily flow volume at the time of sampling.
The following approach was implemented to calculate a wet weather TLR for each metal in the Dominguez Channel portion of the Beach Cities EWMP area:
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1. The analysis region was modeled in SBPAT for TMDL years 2003 to 2012.
2. Including only wet25 days, the day with the 90th percentile metal load (the critical daily load) was determined (see Appendix Q).
3. The target load was calculated by multiplying the allowed concentration by the runoff volume on that day which is the WQBEL expressed in the permit.
4. The difference between the baseline load (step 2) and the target load (step 3) resulted in a TLR for the 90th percentile load day, which was the load reduction required to meet the allowable TMDL concentration.
Appendix K provides an example calculation for this TLR process.
Zinc was found to require the greatest TLR and was also found to be the controlling pollutant for BMP implementation, meaning that meeting the zinc requirement required the most stringent BMP implementation, which will likely produce load reductions for the other pollutants greater than the TLR. The TLR for lead was found to be zero because the baseline concentration on the 90th percentile critical day was found to be less than the allowed concentration. TLRs for each of the metals are shown in Table 3-9.
3.5.2 FECAL COLIFORM BACTERIA
Since no TMDL exists for this WBPC, an approach was developed to compute a wet weather bacteria TLR consistent with freshwater bacteria TMDLs in the region, which use allowable exceedance days (per year) and the 90th percentile critical year as the basis for their WLAs. The TLR calculation for bacteria for Dominguez Channel EWMP area was similar to the method used in the SMB portion.
The method relates the annual number of modeled calendar days with rainfall-generated runoff (or “discharge days”) to the expected annual bacteria exceedance days. The validation of this methodology on the Arroyo Sequit reference watershed is described in Section 2.5.1.
The TLR-development methodology was applied to the EWMP area to predict the number of baseline exceedance days for the 90th percentile year, or TMDL year 1995. Once the number of baseline discharge days were estimated, the number of allowed discharge days was established.
Consistent with other Los Angeles region freshwater bacteria TMDLs, it was assumed that 19% of non-high flow suspension days were allowed to exceed the REC1 single sample limit, or 400 MPN/100mL for fecal coliforms26.The D1070 rain gauge, which was used to determine the 90th percentile year and used to model both the Dominguez Channel and Santa Monica Bay portions of the EWMP area, was used to determine the number of wet days and high flow suspension days in TMDL year 1995. Wet day definition and high flow suspension day definition were based on other
25 Wet days defined as days in which gauge S28 has flows equal than or greater than 62.7 cfs. Due to insufficient continuous flow data at this gauge, wet days were estimated as days in which flows in SBPAT were non-zero excluding days with less than 0.1 inch of rainfall. This is discussed in more detail in Section
3.4.2. 26 Fecal coliform, and its previous freshwater Basin Plan objective value (400 mpn/100mL), is used as the modeled surrogate for E. coli due to its more robust available modeling datasets.
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bacteria TMDLs in the region, where wet days are days in which 0.1” or greater of rainfall occur, plus the following 3 days, and high flow suspension days are days in which 0.5” or greater of rainfall occur plus the following day. In TMDL year, 1995, a total of 73 wet days (19 of which were high flow suspension days) occurred using this methodology. Because the REC1 single sample limits are suspended on high flow suspension days, the total number of applicable wet days is 54. Using the 19% allowable exceedance rate, the number of allowable exceedance days was set to 10 (19% x 54 wet days). Thus, 10 wet days (that are not high flow suspension days) were allowed to exceed 400 MPN/100mL. Any remaining exceedance days must be removed using BMPs.
To determine the TLR necessary to meet the allowed discharge days, a virtual retention BMP was modeled in SBPAT at the outlet of the EWMP area. This approach was presented to LARWQCB staff on June 6, 2014 and verbal feedback received during the meeting was supportive.
For the outlet virtual retention BMP included a diversion with a virtual hydraulic capacity that results in a model-derived bypass frequency (or number of discharge days), during TMDL year 1995 that meets the allowable exceedance day criteria. The diversion is modeled as a full capture system. High flow suspension days were not included in the number of exceedance days, and the concentration on each discharge day was confirmed to be greater than 400 MPN/100mL to ensure it was actually an exceedance day. The diversion is modeled as a full capture system. The load reduction resulting from this BMP scenario (i.e., baseline analysis region load minus analysis region load with the diversion system and retention BMP in place) became the TLR. “Reasonable assurance” of compliance with the allowed discharge days was then considered to have been met when actual and proposed BMPs combined to achieve the TLR for each analysis region. The calculated TLR for bacteria is shown in Table 3-9.
In summary, the following approach was implemented to calculate a wet weather bacteria TLR in the Dominguez Channel analysis region:
1. The analysis region is modeled in SBPAT for the 90th percentile year (TMDL year 1995) (see Appendix Q).
2. The existing, baseline condition (i.e., without any outlet retention BMP) is modeled for the analysis region, resulting in a mean baseline fecal coliform (FC) load for the 90th percentile year (baseline load).
3. The allowable number of non-high flow suspension discharge days is calculated to be 10 (19% of 54 non-high flow suspension wet weather days in TMDL year 1995).
4. An in-stream diversion to a large, virtual retention BMP at the outlet of the analysis region is iteratively sized so that the number of non-high flow suspension discharges meets the criteria established in Step 3.
5. The diversion and retention BMP is then modeled in SBPAT to produce a mean FC load for the 90th percentile year (allowed load).
6. The difference between the baseline load (step 2) and the allowed load (step 5) results in a TLR for the 90th percentile year, which is the load reduction required to meet the 10 allowable exceedance days for wet weather.
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7. In order to meet the allowable exceedance days of 10, the TLR (as a percentage of the baseline 90th percentile year load) is 33%.
Table 3-9. Target Load Reductions and Baseline Conditions for Pollutants in the Dominguez Channel Watershed for the Critical Condition
Pollutant
Baseline Data for Critical Condition
Allowable Discharge for Critical
Condition
Target Load
Reduction[2]
Runoff
Volume
Pollutant
Conc.[1]
Pollutant
Load
Runoff
Volume
Pollutant
Conc. [1]
Pollutant
Load
Absolute
Load
% of
Baseline
Load
Copper 301
ac-ft/day 25.8 µg/L 21 lb/day 301 ac-ft/day 9.7 µg /L 8 lb/day 13 lb/day 62% Lead 275
ac-ft/day 11.6 µg /L 8.7 lb/day 275 ac-ft/day 42.7 µg /L 32 lb/day 0 lb/day 0% Zinc 291
ac-ft/day 290.2 µg /L 230 lb/day 291 ac-ft/day 69.7 µg /L 55 lb/day 175 lb/day 76% Bacteria 6,048 acft/yr
20,080
MPN/100
mL
1,498*1012
MPN/yr
6,048
ac-ft/yr
13,454
MPN/100
mL
1,004*1012
MPN/yr
493*1012
MPN/yr 33%
1 Bacteria concentration is estimated as the total annual load divided by the total annual runoff volume. The pollutant concentrations presented for the Dominguez Channel Toxics TMDL are a direct output from the LSPC model used for the RAA.
2 RAA demonstration is made based on the achievement of the TLR values in terms of absolute load removed by the proposed suite of BMPs in each analysis region. The allowed conditions in terms of runoff volume and concentration are shown for informational purposes only.
3.6 BEST MANAGEMENT PRACTICES
3.6.1 METHODS TO SELECT AND PRIORITIZE BMPS
In order to demonstrate reasonable assurance, BMPs were identified in a prioritized manner.
Prioritization was based on cost (low cost BMPs were prioritized); BMP effectiveness for the pollutants of concern (BMPs that had greater treatment efficiency for the pollutant of concern in a particular analysis region were prioritized over other BMPs); and implementation feasibility as determined by the Beach Cities agencies. In general, nonstructural BMPs were prioritized over structural BMPs due to their lower relative cost, and then structural BMPs were identified that would likely result in the greatest load reduction per dollar.
The RAA was performed according to the following steps:
1. Calculate load reductions associated with existing structural BMPs;
2. Assume a load reduction for non-modeled non-structural BMPs(five percent of baseline pollutant load);
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3. Calculate load reductions for public retrofit incentives (e.g., downspout disconnects) and redevelopment;
4. Calculate load reductions attributable to anticipated new permit compliance activities of non-MS4 entities (e.g., Industrial General Permit holders and Caltrans);
5. Calculate load reductions for proposed regional BMPs that were identified in existing plans; and
6. Meet the TLR by backfilling the remaining load reduction with new regional or distributed green streets BMPs, with green streets modeled by assuming treatment of runoff from a percentage of specific developed land uses.
The following schedule assumptions were made:
• Only BMPs implemented after the TMDL effective date (2012) were included; • Redevelopment BMPs were assumed to use different sizing criteria before and after 2015 (EWMP submittal date), consistent with the Permit’s post-construction requirements; and • Modeled load reduction outputs are reported for the proposed interim bacteria (2018, 2023, and 2027) and final proposed bacteria/toxics TMDL (2032) compliance dates.
3.6.2 RECOMMENDED MCMS AND NONSTRUCTURAL BMPS
See Section 2.6.2. All information provided in Table 2-8, excluding the City of Hermosa Beach (which is not in the Dominguez Channel Watershed), also pertains to the Dominguez Channel Watershed.
3.6.3 QUANTIFIED NON-STRUCTURAL BMPS
Non-structural BMPs have been categorized as follows. Specific model inputs are summarized below. No modeling of non-structural BMPs was conducted in the City of Torrance, as all load reductions were quantified based on literature references.
Non-Modeled Programmatic BMPs
These source controls include a combination of BMPs such as new or enhanced pet waste controls (ordinance, signage, education/outreach, mutt mitts, etc.), Clean Bay Restaurant Program, human waste source tracking and remediation (e.g., leaking sewer investigations, etc.), enhanced street sweeping (e.g., 100% vacuum sweepers, increased frequency, posting of ‘No Parking’ signs for street sweeping, etc.), increased catch basin and storm drain cleaning, and other new or enhanced nonstructural BMPs that target the pollutants addressed in this EWMP. The City of Torrance, for instance, has committed to such BMPs as smart gardening program enhancements, TMDL-specific stormwater training, enhancement of commercial and industrial facility inspections, enhancement escalation procedures, improved street sweeping technology, and reduction of irrigation return flow. A combined credit of 5% load reduction was applied for all pollutants to represent the cumulative benefit from non-modeled programmatic BMPs.
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In addition, a separate load reduction is assumed for copper due to the elimination 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 draft detailed 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 identifies three possible implementation scenarios, the least aggressive of which estimates that a 55% load reduction in copper will be achieved by 2032 due to the brake pad phase out. Therefore, a 55% load reduction was assumed for copper in the Greater LA Harbor analysis region; however, to avoid double counting load reductions, this reduction was applied to the copper load after accounting for all future nonstructural and structural BMP load reductions.
Modeled Redevelopment
Beginning in 2001, redevelopment projects were required by the Permit (via the SUSMP) to incorporate stormwater treatment BMPs into their projects if their project size exceeded specified thresholds. The 2001 MS4 Permit SUSMP redevelopment requirements were applied between 2012 (the point at which the Metals TMDL was implemented) and 2015 for the Dominguez Channel EWMP area. Redevelopment in this period was modeled as flow-through media filters at a 0.2 in/hr design event.
The 2012 MS4 Permit established new criteria for redevelopment projects, requiring certain sized projects to capture, retain, or infiltrate the 85th percentile design storm or the 0.75-inch design storm, whichever is greater, via the implementation of LID BMPs. To account for these redevelopment requirements in the Cities of Redondo Beach and Manhattan Beach, BMPs were modeled in SBPAT assuming land use-specific annual redevelopment rates for projects that triggered former SUSMP requirements or will trigger the Permit’s LID BMP requirements (Table 3-10). No load reduction from this non-structural BMP was quantified for the City of Torrance.
Table 3-10. Estimated Annual Redevelopment Rates
Land Use
Annual Redevelopment Rate (% of total land use area)
Cities of Redondo Beach and Torrance1 City of Manhattan Beach Residential 0.18 0.10
Commercial 0.15 0.38
Industrial 0.34 0.38
Education 0.16 0.16
Transportation 2.7 2.7
1Regionally developed redevelopment rates were applied to the City of Torrance and Redondo Beach (City of Los Angeles Bureau of Sanitation, 2012).
A City-specific redevelopment rate of 3.8 percent for commercial redevelopment in Manhattan Beach was provided based on historical SUSMP data over the past ten years. This value was also assumed for historical industrial redevelopment and both commercial and industrial redevelopment moving forward. For residential land use, because there are insufficient data to
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project LID rates, a nominal 0.10 percent was assumed and is subject to change based on the model outcomes and discussions with City staff as the LID ordinance is finalized.
BMPs were assumed to be implemented and to continue be implemented in the future, at these rates across five distinct time periods in the Dominguez Channel watershed:
• 2012 (Dominguez Channel Toxics TMDL Effective Date) – 2015: The SUSMP requirements, based on the 2001 MS4 Permit, were assumed to be implemented over this period as flowthrough media filters at a 0.2 in/hr design intensity (Los Angeles County Department of Public Works, 2002).
• 2015 - 2032 (Final Dominguez Channel Toxics TMDL Compliance Deadline and Proposed Final Bacteria Compliance Deadline): The 2012 MS4 Permit post-construction requirements were assumed to be implemented over this period as 50% biofiltration and 50% bioretention.
Biofiltration (bioretention with underdrains) were modeled using bioswale BMP types with effluent EMCs set to bioretention and sized to retain 150 percent of the 1-year, 1-hour design storm (approximately 0.3 in/hr) because they do not retain all the design storm volume on site (they are flow-through systems), while bioretention units were sized to retain 100 percent of the 85th percentile, 24-hour design storm depth, calculated as the mean for each analysis region. 2015 is used as a transition date since the LID post-construction requirements from the 2012 MS4 Permit are required to be in full effect via local LID ordinances by this time.
In order to estimate load reductions associated with these redevelopment BMPs, the land use percentages shown in Table 3-10 were multiplied by the respective land use areas in each analysis region, resulting in an assumed area treated by LID BMPs each year. This area was multiplied by the applicable number of years, since new BMPs are assumed to be implemented each year. The total land use area assumed to be redeveloped for each analysis region was then modeled as being treated and the total load reduction was quantified. The default design parameter assumptions for the biofiltration redevelopment projects were that the longitudinal slopes were 0.03 ft/ft, Manning’s n was 0.25, hydraulic residence time was 10 min, and water quality flow depth was 4 in.
Modeled Public Retrofit Incentives
These BMPs include programs directed at incentivizing the public to decrease the amount of stormwater runoff from their property, specifically via downspout disconnects. Public incentives for retrofitting existing development were modeled in SBPAT between 2015, when the EWMP will begin to be implemented, and the respective TMDL final compliance date. No quantification of these load reductions was done for the City of Torrance, although they may be taken into account in future iterations. Public retrofit incentives were assumed to be a downspout disconnection program, modeled as bioswales sized to a design storm intensity of 0.2 in/hr (see Table 2-10). The default design parameter assumptions for the biofiltration redevelopment projects were that longitudinal slopes were 0.03 ft/ft, Manning’s n was 0.25, hydraulic residence time was 10 min, and water quality flow depth was 4 in.
Assumptions included that 10 percent of single family residential areas would be converted to disconnected downspout systems over 2015 to 2021, and that, based on GIS analysis, 38 percent of
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the single family residential area consists of rooftops that can be effectively disconnected.
Therefore, 3.8 percent of single family residential neighborhoods were modeled as treated by bioswales in order to account for public retrofit incentives.
Modeled Non-MS4 Permitted Parcels or Areas
SBPAT was used to quantify the load reduction assuming that regulated parcels/areas would be in compliance with the NPDES Statewide Storm Water Permit Waste Discharge Requirements (WDRs) from State of California Department of Transportation (Order No. 2012-0011-DWQ, NPDES No.
CAS000003) and the California NPDES General Permit for Storm Water Discharges Associated with Industrial Activities (Industrial General Permit [IGP], Order 2014-0057-DWQ) (Figure 3-8). The load reduction from these areas was quantified in analysis region DC-RB/MB. This load reduction was obtained from these areas by simulating treatment plants sized to treat the IGP’s design storm requirement, the 85th percentile, 24-hour storm event, with an effluent concentration set equal to the water quality standard (see Section 2.6.3). For fecal coliform, 400 MPN/100mL was used. In the Dominguez portion of the Beach Cities EWMP, these constituted only a small fraction of the total area.
3.6.4 STRUCTURAL BMPS
Structural BMPs have been categorized as follows. Proposed distributed BMPs in the Dominguez Channel Watershed area of the Beach Cities EWMP are shown in Figure 3-9, and existing and proposed regional BMPs are shown in Figure 3-10.
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Figure 3-8. IGP and Caltrans Area within the Dominguez Channel portion of the Beach Cities EWMP Area
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Figure 3-9. Proposed Distributed BMPs within the Dominguez Channel Watershed
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Figure 3-10. Proposed Regional BMPs within the Dominguez Channel Watershed
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Existing Regional BMPs
There are no existing regional BMPs in either Dominguez Channel analysis region; as such, none were modeled in SBPAT.
Proposed Regional BMPs
Two regional BMPs are being proposed in the Dominguez Channel Watershed, both within the City of Redondo Beach in Analysis Region DC-RB/MB.
Analysis Region DC – RB/MB
Two proposed regional BMPs in the DC-RB/MB analysis region were modeled in SBPAT based on conceptual design information and discussions with the Beach Cities WMG (Figure 3-11). While the BMPs are conceptual at this point, they will include media filtration such as proprietary media filters or bioretention. Infiltration is not feasible due to the low saturated flow rates in the areas where regional BMPs could be constructed (0.3-0.4 in/hr).
Powerline Easement Filtration. This regional BMP would
include a filtration system (i.e., media filter, biofilter, or bioretention with underdrains) or systems along the
powerline easement. This BMP could be constructed to
capture runoff from the EWMP areas draining towards the intersection of Manhattan Beach Blvd and Inglewood Ave. In order to determine a conservative estimate of the footprint available for this BMP, an analysis was conducted along the powerline easement and along Manhattan Beach Blvd that
included the following criteria:
• 100 ft away from large utility poles; and
• 25 ft away from roads, railroads, and buildings.
These criteria aim to address some of the concerns with BMP construction within a powerline easement, as was
previously described. The resulting approximate footprint shown in Figure 3-11 should be considered approximate and large enough to allow for construction in the roadway right-of-way or easement or both. It is noted that this is meant to be a conservative estimate given the above criteria and would be sited to capture runoff from the drainage area shown in Figure 3-11. The total footprint area calculated for this BMP was 313,500 square feet. It was assumed that approximately 15% of this area would be used for pretreatment (10%) and side slopes (5%) so only 85% of the area was used as the footprint available for filtration. The BMP was modeled as a flow through BMP, with the only storage available being the pretreatment. A media filter was chosen to represent this BMP. The treatment rate was set to 10 inches per hour multiplied by the available footprint. This constitutes a design flow of approximately 48% of the 0.2 in/hr 85th percentile design intensity in the Permit. The BMP was assumed to be 5 feet deep, and the diversion flow rate was estimated based on the flow rate from 0.2 in/hr on the drainage area using the rational method. Modeling criteria are shown in Table 3-11.
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A potential alternative location to the Powerline Easement Filtration facility is the green space adjacent to Manhattan Beach Blvd and Marine Avenue. Due to limited spatial availability, highcapacity filter media would be required for the alternative location in order to achieve the same reduction objective as the Powerline Easement Filtration facility.
Both potential locations for this BMP would provide the additional benefits of neighborhood greening, potentially mitigating issues such as the urban heat island effect and also raising public education/awareness.
Artesia Blvd and Hawthorne Blvd Filtration. This regional BMP would include a filtration system or systems near the intersection of Artesia Blvd and Hawthorne Blvd. It was assumed that this BMP could be constructed to capture runoff from the EWMP areas draining towards this intersection. A conceptual footprint was developed based on the space available in medians, park strips, and areas that could be converted for subsurface filtration systems. The approximate footprint is shown in Figure 3-11.
The total footprint area calculated for this BMP was 43,700 square feet. It was assumed based on other similar BMPs in the Los Angeles region that approximately 15% of this area would be used for pretreatment (10%) and side slopes (5%), so only 85% of the area was used as the footprint available for filtration. The BMP was modeled as a flow-through BMP, with the only storage available being the pretreatment. A treatment plant type BMP was chosen for the modeling, and the EMCs from distributed media filters were assigned to the treatment plant to simulate a regional media filter. The treatment rate was set to 10 inches per hour multiplied by the available footprint.
This constitutes a design flow of approximately 63% of the 0.2 in/hr intensity in the Permit. The BMP was assumed to be 5 feet deep, and the diversion flow rate was estimated based on the flow rate from 0.2 in/hr on the drainage area using the rational method. Modeling criteria are shown in Table 3-11.
This BMP would provide the additional benefit of neighborhood greening, potentially mitigating issues such as the urban heat island effect and also raising public education/awareness.
Analysis Region Dominguez Channel – Torrance (DC-Torrance) No regional BMPs are proposed in the DC-Torrance analysis region.
Summary of Proposed Regional BMPs
Two regional BMPs are proposed in the Dominguez Channel portion of the Beach Cities EWMP Area.
None of these projects could be feasibly sized to meet the 85th percentile design criteria. However, the BMPs were sized to collectively meet the target load reductions necessary to achieve compliance with the WQBELs and RWLs, in combination with other existing and proposed structural and non-structural BMPs. Proposed regional BMPs, including their location, analysis region, project name, model inputs, and expected performance, are summarized in Table 3-11.
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Figure 3-11. Proposed Regional BMPs, DC-RB/MB Analysis Region
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Table 3-11. Parameters and Performance for Proposed Regional BMPs Modeled as Media Filters Location
of BMP
Analysis
Region Project Name
Model Assumptions
Expected Performance
(load reduction as a %
of analysis region
baseline load)
Design
Storm
(in/hr)
Treatment
Flow Rate
(cfs)
Average
Basin
Depth
(ft)
Equalization
Volume
(cu-ft)
Diversion
Flow Rate
(cfs)
Infiltration
Rate
(in/hr)1
Redondo
Beach DC-RB/MB
Powerline
Easement
Filtration
0.09 62 5 141,086 132 0.00001
Fecal coliform: 36%
Zinc: 34%
Copper: 26%
Redondo
Beach DC-RB/MB
Artesia Blvd and
Hawthorne
Blvd. Filtration
0.13 8.6 5 19,682 13.6 0.00001
Fecal coliform: 9%
Zinc: 5%
Copper: 4%
1 Model requires some infiltration, but infiltration minimized to essentially 0.
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Existing Distributed BMPs
No existing distributed BMPs were accounted for or modeled in the Dominguez Channel portion of the Beach Cities EWMP area.
Proposed Distributed BMPs
Proposed distributed BMPs are depicted in Figure 3-9. Distributed green streets BMPs are proposed and were modeled as part of the RAA within the DC-RB/MB analysis region, at an implementation level of 14% (i.e., runoff from 14% of single family residential, multi-family residential, commercial, and industrial land uses would be treated by green streets BMPs designed as described in Section 2.6.4).
Approximately 200 catch basin inlet filters (media filtration devices with a variety of media types and configurations such as cartridge filters, vertical bed filters, etc.) are proposed within the DCTorrance analysis region. Infiltration of runoff is not feasible in the DC-Torrance analysis region due to the prevalence of Montezuma Clay Adobe soils. Roads represent a potentially significant source of pollutant loads, and therefore treating road runoff is considered a key strategy for multi-pollutant TMDL implementation. Implementing catch basin inlet filters throughout the DC-Torrance Watershed is highly applicable because of the high density of catch basins. The predicted load reduction attributable to catch basin inlet filters was estimated on a percent load removal basis, extracted from a review of relevant literature.
Fact sheets and literature available on commercially available catch basin inlet filters suggest that catch basin inlet filters are effective at capturing and removing pollutants from stormwater runoff including sediments, heavy metals, and bacteria. A study titled, Optimization of Stormwater Filtration at the Urban/Watershed Interface by the University of California, Irvine, Department of Environmental Health (2005), estimated a 99% removal efficiency of lead concentrations by a grate inlet skimmer box/round curb inlet basket. Another study conducted by the City of El Monte at Longo Toyota in 2002 concluded that the grate inlet skimmer box/round curb inlet baskets were effective in removing 95% of zinc and copper concentrations and 87% of lead concentrations.
A more recent independent test conducted in 2013-2014 by the City of Lake Forest showed that the tested catch basin inlet filters achieve 75% removal of heavy metals. The product tested was the Ultra Filter Sock Heavy Metal Drain Filter.
For bacteria, the 2005 UC Irvine study found a fecal coliform removal efficiency of 33% by the grate inlet skimmer box/round curb inlet basket.
In addition, the City of Torrance is in the process of developing the Green Street Program and the ordinances to implement green street design features as part of street redevelopment. While implementing redevelopment of arterial streets, the City of Torrance would assess opportunities for Green Street design features to facilitate treatment through filtration or infiltration. Green street elements may include infiltration trench that provides water quality treatment, reduction in peak flow discharges, and potential groundwater recharge. Other green street elements that may be considered include bioretention/biofiltration practices to achieve water quality treatment through
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filtration by vegetation and soils to remove pollutants with perforated underdrain to convey the treated runoff. The City of Torrance is committed to developing the Green Street Policy by July 2015, as required by the MS4 Permit.
3.7 REASONABLE ASSURANCE ANALYSIS RESULTS
3.7.1 DISCUSSION OF LIMITING POLLUTANTS
Zinc was determined to be the controlling pollutant, therefore the cumulative BMP load reductions for copper, lead, and bacteria are each greater than their respective TLRs. Ammonia, cyanide, pH, selenium, mercury, and cadmium were not modeled as part of the Beach Cities’ RAA; however, the implementation of the proposed BMPs is expected to achieve similarly substantive load reductions for these pollutants as for zinc. Meeting the zinc requirement required the most stringent BMP implementation, which is expected to also address all Category 1, 2 and 3 pollutants in Dominguez Channel.
3.7.2 WET WEATHER
For all pollutants in the DC-RB/MB analysis region, cumulative load reductions are predicted to meet the interim and final TLRs. The non-structural BMPs achieve a relatively minor load reduction for zinc compared to the regional BMPs and the distributed green streets. After accounting for the load reductions attributed to non-modeled programmatic, public incentives and redevelopment, non-MS4 compliance, and regional BMPs, the implementation of distributed green street BMPs to treat stormwater from 14% of residential, commercial, and industrial land uses within Redondo Beach and Manhattan Beach was required to meet the zinc TLR (the limiting pollutant). Table 3-12 below summarizes the estimated load reductions achieved by the proposed BMPs for both the interim and final compliance deadlines.
Within the DC-Torrance analysis region, cumulative load reductions are dependent on the level of implementation of the planned catch basin inlet filters. At this time, inlet filters are planned for 200 of 643 catch basins in the analysis region, targeting high priority areas. Since the estimated load reduction is applicable per filter, and not to the entire analysis region, monitoring and subsequent adaptive management will be employed through CIMP monitoring to evaluate the achieved load reductions prior to each of the compliance deadlines, installing additional filters as needed or proposing additional structural/non-structural BMPs until compliance is achieved for every applicable WQBEL or RWL. At this time, the City of Torrance is not committing to any regional or distributed BMPs, aside from catch basin inlet filters and a review of green streets opportunities.
It should be noted that if at any time specific distributed green streets or regional/centralized BMPs are found to be infeasible for implementation, alternative BMPs or operational changes will be planned within the same analysis region and within the same timeline, to meet an equivalent load reduction. The performance of the proposed catch basin inlet filters within the City of Torrance will also be evaluated as potential alternatives to the proposed structural BMPs within the Cities of Redondo Beach and Manhattan Beach.
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Zinc
The zinc load reductions were quantified on the 90th percentile wet load day which was determined during TLR calculations (Table 3-12). Load reductions vary by day due to storm timing and size and due to some variability in the randomly generated pollutant concentrations in the model. To ensure that the load reductions estimated on the 90th percentile load day are not significantly greater than typical daily load reductions, and to get an idea of the variability, the average of the daily load reductions during the 10 year modeling period were also calculated. The predicted zinc load reduction achieved on the 90th percentile load day in the DC-RB/MB analysis region is estimated to be 79%, which is greater than the TLR of 76%. Most of the zinc reduction comes from the proposed regional infiltration BMPs. For comparison, the average daily load reduction was 98%.
Because the 90th percentile day has more flow than an average day, the capture rate of the BMPs would be expected to be lower on this day than for smaller storms, thereby justifying the decreased load removal on the 90th percentile day.
The estimated zinc load reduction in analysis region DC-Torrance is 85%, including both nonstructural and distributed (catch basin inlet filters) BMPs, which is greater than the TLR of 76%. As noted above, the estimated load reduction cannot be applied to the entire analysis region.
Therefore, adaptive management will be strongly employed to evaluate the achieved load reductions prior to each of the compliance deadlines, installing additional filters as needed.
Copper
The copper load reductions were quantified on the 90th percentile wet load day which was determined during TLR calculations (Table 3-12). Similar to zinc, the average of the daily load reductions during the 10 year modeling period are also shown to account for variability. The load reduction achieved on the 90th percentile load day in the DC-RB/MB analysis region is predicted to be 85%, which is greater than the TLR of 62%.
The estimated copper load reduction in the DC-Torrance analysis region is predicted to be 89%, which also exceeds the copper TLR of 62%. As noted above, the estimated load reduction cannot be applied to the entire analysis region. Therefore, adaptive management will be strongly employed to evaluate the achieved load reductions prior to each of the compliance deadlines, installing additional filters as needed.
Fecal Coliform
The average bacteria load reduction for TMDL year 1995 was quantified and compared to the TLR calculated for the 90th percentile critical year (1995) (Table 3-12). The predicted load reduction of 74% within the DC-RB/MB analysis region is greater than the TLR of 33%. Most of the reduction comes from the regional BMP filtration systems.
In the City of Torrance, the estimated bacteria load reduction is 38%, which is greater than the TLR of 33%. As noted above, the estimated load reduction cannot be applied to the entire analysis region. Therefore, adaptive management will be strongly employed to evaluate the achieved load reductions prior to each of the compliance deadlines, installing additional filters as needed.
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Lead
Although the load reductions for lead were not quantified because no load reductions were required to meet the TMDL WQBEL, the implementation of the proposed BMPs will result in similarly substantive load reductions for lead as for other metals. FAA and USEPA efforts to phase out lead from Avgas will further reduce lead in stormwater runoff in the future.
Time Series Output
Electronic input and output SWMM files and Excel summary spreadsheets will be provided to the LARWQCB upon submittal of this Draft EWMP.
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Table 3-12. Dominguez Channel Watershed – RAA Results – Interim and Final Compliance Pollutant Date
Implementation Benefits (average load reduction as % of baseline for the critical condition1) TLR
Compliance
(TLR Met)?
Non-Structural
BMPs
(Non-Modeled)
Public Retrofit
Incentives +
Redevelopment
NonMS4Regional
BMPs
Distributed
BMPs
Distributed BMP
Implementation
Level
Estimated
Load
Reduction
Analysis Region DC-RB/MB
Zinc 2032
(Final) 5% 9% 6% 39% 20% 14% SFR, MFR,
COM, IND
79% 76% Yes
Copper 2032
(Final) 24%2 0% 5% 30% 26% 85% 62% Yes
Fecal
coliform
2022
(Interim) 2.1% 1.5% 0.7% 0% 4.1% 3% SFR, MFR, COM, IND 8.4% 8.3% Yes 2027
(Interim) 3.5% 2.4% 1.3% 0% 10% 7% SFR, MFR, COM, IND 17% 17% Yes 2032
(Final) 5% 3.2% 1.8% 45% 20% 14% SFR, MFR, COM, IND 74% 33% Yes Analysis Region DC-Torrance
Zinc 2032
(Final) 5% 0% 0% 0% 75% per filter Catch basin inlet filters See note 3 76% See note 3 Copper 2032
(Final) 14%2 0% 0% 0% 75% per filter Catch basin inlet filters See note 3 62% See note 3 Fecal
coliform
2022
(Interim) 2.1% 0% 0% 0% 33% per filter Catch basin inlet filters See note 3 8.3% See note 3 2027
(Interim) 3.5% 0% 0% 0% 33% per filter Catch basin inlet filters See note 3 17% See note 3 2032
(Final) 5% 0% 0% 0% 33% per filter Catch basin inlet filters See note 3 33% See note 3 1 The critical condition is TMDL year 1995 for fecal coliform, 11/30/2007 for copper, 2/5/2010 for lead, and 2/26/2006 for zinc. 2 Load reduction attributable to copper brake pad phase-out, after accounting for other BMPs, up to 55%. 3 Load reduction sum cannot be estimated at this time. The individual load reduction for each inlet filter’s drainage area is shown under the “Distributed BMPs” column. Initially, 200 of 643 catch basins are planned to be retrofitted in high priority catchments. The total load reduction from inlet filters will be evaluated in the future through CIMP monitoring, as part of the EWMP adaptive management process. At that time, the catch basin BMPs will be modified, with additional filters installed as necessary and additional structural/non-structural BMPs proposed as needed to meet the TLRs required to achieve water quality objectives by the compliance deadlines.
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3.7.3 DRY WEATHER
For dry weather, the applicable pollutants in the Dominguez Channel Estuary are total copper, total lead, and total zinc as Category 1 WBPCs (i.e. WQBELs and/or RWLs are established in Part VI.E and Attachments L through R of [the Permit]) and the applicable pollutant in both the Dominguez Channel and Dominguez Channel Estuary is bacteria as a Category 2 WBPC (i.e., 303(d)-listed but not currently subject to a TMDL).
The City of Torrance’s dry weather load reduction strategy will focus on non-structural source control and pollution prevention measures that are designed to reduce the amount of pollutants and understand the effect of pollutants entering runoff though education, enforcement and behavioral modification programs.
Within the Cities of Redondo Beach and Manhattan Beach, the implementation of the two regional BMPs at both outlets from the DC-RB/MB analysis region to address wet weather pollutants will control dry weather flows by capturing the small flows in the pre-treatment volume and either retaining them or treating them in the media filter.
In addition, each of the EWMP Group cities has water conservation regulations which will reduce dry weather runoff at its source. Collectively, by controlling dry weather MS4 flows prior to entering Dominguez Channel using the proposed suite of BMPs, bacteria will be addressed. If necessary, the EWMP Group agencies retain the option of installing low flow diversions sized to effectively eliminate discharges to the receiving water year-round dry weather days. Therefore, reasonable assurance of meeting the applicable RWLs was demonstrated in this EWMP through a qualitative assessment of the proposed BMPs and their overall approach of eliminating or substantially reducing MS4 discharges during dry weather.
3.8 MULTIPLE BENEFITS
The proposed projects in the Dominguez Channel Watershed not only demonstrate reasonable assurance for the water quality objectives, but also provide multiple benefits beyond pollutant load reduction. Multiple benefits provided by the projects proposed in the Santa Monica Bay watershed are also applicable to those proposed in the Dominguez Channel Watershed, including neighborhood greening, water conservation/supply, and public education and awareness (see Section 2.8 for more detail). However, infiltration in Dominguez Channel Watershed is infeasible due to low saturated flowrates of the soil at the potential structural BMP locations; therefore, groundwater recharge is not considered an added benefit to the proposed structural BMPs in the Dominguez Channel Watershed.
3.9 PARALLEL COMPLIANCE EFFORTS
During the remaining compliance period, the Beach Cities WMG may also elect to perform special studies to evaluate the Dominguez Channel Toxics TMDL WLAs and/or REC-1 indicator bacteria RWLs. For example, a reevaluation of the site-specific Water Effects Ratio (WER) used to calculate the targets for copper and zinc may result in modifications to the target load and TLR. Another example might include the application of a non-structural pollutant load reduction credit in the case
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that state legislation restricting zinc in manufactured rubber tires is passed. Through the adaptive management process, the RAA may be reevaluated after any changes to bacteria statewide objectives, TMDL WLAs, and/or Permit limits.
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4 IMPLEMENTATION SCHEDULE
4.1 COMPLIANCE SCHEDULE
The following sections present the proposed compliance schedules and project sequencing necessary to meet the interim and final compliance deadlines for the Beach Cities EWMP WPBCs.
4.1.1 SANTA MONICA BAY WATERSHED
Bacteria, debris, and PCBs and DDTs have been identified as Category 1 WBPCs in the Santa Monica Bay Watershed. No Category 2 or 3 WBPCs are specified in this watershed. The interim and final compliance deadlines in the Santa Monica Bay watershed are summarized in Table 4-1.
Table 4-1. Compliance Deadlines associated with Santa Monica Bay Watershed WBPCs Category Pollutant(s) Date Action
1: Highest
Priority
Dry Weather
Bacteria
July 2006 Final: Summer-dry single sample Allowable Exceedance Days (AED) met; compliance is currently in effect and
attained through diversions and non-structural BMPs.
November 2009 Final: Winter-Dry period Single Sample AED met; compliance is currently in effect and attained through
diversions and non-structural BMPs.
Wet Weather
Bacteria
7/15/2018 Interim: 50% single sample ED reduction
7/15/2021 Final: Geometric Mean [GM] targets met
Final: Single sample AED targets met
Trash/Debris
3/20/2016 Interim: 20% load reduction
3/20/2017 Interim: 40% load reduction
8/20/2018 Interim (Cities of Hermosa Beach and Redondo Beach):
Determination of compliance strategy for installing full capture trash systems
3/20/2019 Interim (Cities of Hermosa Beach and Redondo Beach):
Installation of full capture trash systems serving 50% of the MS4 drainage area to Santa Monica Bay outside of
Regional EWMP BMPs
8/20/2019 Interim (City of Manhattan Beach): Determination of compliance strategy for installing full capture trash
systems.
3/20/2020
Interim (City of Manhattan Beach): Installation of full capture trash systems serving 50% of the MS4 drainage
area to Santa Monica Bay outside of Regional EWMP
BMPs
Final (Cities of Hermosa Beach and Redondo Beach):
100% reduction in trash from baseline through the
installation of full capture trash systems serving MS4
drainage area to Santa Monica Bay.
3/20/2023 Final (City of Manhattan Beach): 100% reduction in trash from baseline through the installation of full
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Category Pollutant(s) Date Action
capture trash systems serving MS4 drainage area to
Santa Monica Bay.
DDTs N/A
Since the TMDL effectively implements an antidegradation approach (i.e., historic low MS4 concentrations or loads must be kept the same or
lower), and the Beach Cities EWMP Agencies are
currently presumed to be achieving the WLAs (thus
negating the need for RAA), no compliance schedule is
proposed.
PCBs N/A
2: High
Priority N/A N/A N/A
3: Medium
Priority N/A N/A N/A
The final wet weather compliance deadline for the SMBBB TMDL is proposed to be met through a combination of non-structural, distributed green streets BMPs, and existing, planned, and proposed regional BMPs. The interim compliance deadline for the SMBBB TMDL requires a 50 percent reduction in exceedance days by July 2018; this will be met by achieving 50 percent of the final bacteria TLR (13.2%) on a watershed-wide basis, through a combination of non-structural BMPs including redevelopment, public retrofit incentives, non-MS4 parcels/areas NPDES Permit compliance, and programmatic BMPs, as well as and existing regional BMPs. Neither the load reductions from distributed green streets BMPs, nor planned/proposed regional BMPs, are necessary to meet the interim TLR. Table 2-17 previously summarized the breakdown of estimated load reductions at the interim and final compliance deadlines. At the time of the interim compliance deadline, 2018, a 14.4% load reduction is estimated based on a combination of existing regional BMPs and existing and proposed non-structural BMPs, which is greater than the interim TLR of
13.2%.
Compliance with the Debris TMDL will be met through a phased retrofit of all catch basins throughout the Beach Cities EWMP Area to meet each interim and final compliance deadline.
4.1.2 DOMINGUEZ CHANNEL WATERSHED
Toxicity, copper, lead, and zinc have been identified as Category 1 WBPCs in the Dominguez Channel Watershed. Additionally, indicator bacteria and ammonia have been identified as a Category 2 WPBC, and cyanide, pH, selenium, mercury, and cadmium have been identified as Category 3 WBPCs. The compliance schedules associated with each WBPC are summarized in Table 4-2. The compliance schedule for Category 1 WBPCs is consistent with the associated TMDL. The compliance schedule for the Category 2 WBPC has been selected to achieve the proposed wet and dry weather bacteria milestones, with implementation actions not exceeding one year, in accordance with the Permit (Section ii(5)9B). As described in Table 4-2, the compliance schedule for the Category 3 WBPCs will be dependent on the results of the CIMP.
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Table 4-2. Implementation Actions and Dates associated with Dominguez Channel Watershed WBPCs Category Pollutant(s)
Wet/Dry
Weather Date Implementation Action
1:
Highest
Priority
Toxicity1
Total Copper1,2
Total Lead1,2
Total Zinc1,2
Cadmium2
Wet/Dry Current4 Interim: Comply with the interim water quality-based effluent limitations as listed in the TMDL3
March 2032 Final: Comply with the final water quality-based effluent limitations as listed in the TMDL3
2: High
Priority
Indicator
Bacteria
Dry December 2023 Interim: 50% load reduction
December 20255 Final: 100% compliance may be demonstrated by the Permittee in one of three ways:
1. Meeting the allowed exceedance days (5 days during the dry weather period); or
2. Meet the allowed exceedance percentage (1.6% during a dry weather period) within the total drainage area served by the MS4.
3. Diversions are in place such that they are consistently operational, well maintained, and sized to effectively eliminate discharges to the receiving water year-round dry weather days.
Wet December 2016 Provide documentation supporting MCM enhancements implemented over the past year6
December 2017 Provide documentation supporting MCM enhancements implemented over the past year6
December 2018 Identify planned green streets locations to treat runoff from 3% of SFR, MFR, COM, and IND land uses in cities of Redondo Beach and Manhattan Beach.
December 2019 City Council approval of Plans & Specifications for green streets to treat runoff from 3% of SFR, MFR, COM, and IND land uses in cities of Redondo Beach and Manhattan Beach. Begin installation of catch basin inlet filters in the DC-Torrance analysis region.
December 2020 Develop concept reports for regional BMPs in the cities of Redondo Beach and Manhattan Beach. Begin construction on green streets to treat runoff from 3% of SFR, MFR, COM, and IND land uses in cities of Redondo Beach and Manhattan Beach.
December 2021 Submit grant application for any one of the proposed regional projects in the cities of Redondo Beach and Manhattan Beach.
December 2022 Interim Milestone: 25% of target load reduction December 2023 Identify planned green streets locations to treat runoff from an additional 4% (7% total) of SFR, MFR, COM, and IND land uses in cities of Redondo Beach and Manhattan Beach.
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Category Pollutant(s)
Wet/Dry
Weather Date Implementation Action
December 2024 Begin construction on planned green streets to treat runoff from an additional 4% (7% total) of SFR, MFR, COM, and IND land uses in cities of Redondo Beach and Manhattan Beach. Continue installation of catch basin inlet filters in the DCTorrance analysis region.
December 2025 Release Request for Proposals for regional BMP designs in Redondo Beach and/or Manhattan Beach
December 2026 Complete construction on planned green streets to treat runoff from an additional 4% (7% total) of SFR, MFR, COM, and IND land uses in cities of Redondo Beach and Manhattan Beach.
December 2027 Interim Milestone: 50% of target load reduction December 2028 Produce regional BMP design reports; identify locations for green streets implementation to treat runoff from an additional 7% (14% total) of SFR, MFR, COM, and IND land uses in the cities of Redondo Beach and Manhattan Beach.
December 2029 Begin regional BMP permitting process for project in Redondo Beach or Manhattan Beach.
December 2030 Begin construction on planned green streets to treat runoff from an additional 7% (14% total) of SFR, MFR, COM, and IND land uses in the cities of Redondo Beach and Manhattan Beach.
December 20317 Begin regional BMP construction of project in Redondo Beach or Manhattan Beach.
March 20328 Final Milestone: 100% compliance may be demonstrated by the Permittee in one of three ways:
1. Meeting the allowed exceedance days (10 days during a wet weather period, plus high flow suspension days)
2. Meeting the target load reduction (33%); or
3. Meeting the allowed exceedance percentage (19% during a wet weather period) within the total drainage area served by the MS4. 3:
Medium
Priority9
Cyanide
pH
Selenium
Mercury
Cadmium
Arsenic
Chromium
Silver
Nickel
Thallium
N/A March 20328 Final: Comply with the applicable water quality standards as listed in Table 3-4.
As required by the Permit, monitoring for these pollutants will occur under the CIMP. If monitoring data suggest that the Beach Cities Agencies’ MS4s may cause or contribute to exceedances of these pollutants in the receiving water10, these contributions will be addressed through modifications to the EWMP as a part of the adaptive management process, as described in Permit section VI.C.2.a.iii.
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1 Toxicity, copper, lead, and zinc are listed as Category 1 wet weather pollutants in Dominguez Channel. 2 Copper, lead, zinc, and cadmium are listed as Category 1 pollutants in Dominguez Channel Estuary with annual average WQBELs that apply to both wet and dry weather. 3 Dominguez Channel Estuary WQBELs for total copper, lead, zinc, and cadmium are addressed by the implementation actions taken for Dominguez Channel wet weather WQBELs. 4 According to monitoring data at Dominguez Channel Mass Emission Station S28, the copper, lead, and zinc exceedance rates of the interim WQBELs are 9%, 3% 10% respectively, based on qualified sampling events between 2002 and 2013. At the Torrance Lateral Mass Emission Station TS19, the copper, lead, and zinc exceedance rates of the interim WQBELs are 5%, 0%, and 8% respectively. These monitoring locations receive flow contributions from the Beach Cities WMG, as well as other WMGs. CIMP monitoring and subsequent adaptive management will evaluate if the Beach Cities WMG are exceeding the interim Category 1 WQBELs and evaluate compliance with the Dominguez Channel Toxics TMDL. 5 The proposed compliance schedule for dry weather bacteria is the minimum time expected to be necessary for the agencies to plan, design, permit, construct, monitor, and adaptively manage the proposed dry weather BMPs, and is also consistent with the 10-year MS4 compliance schedule for dry weather from the TMDL for indicator bacteria in the San Gabriel River, Estuary and Tributaries, adopted by the LARWQCB in 2015 (Water Quality Control Plan, Attachment A to Resolution No. R15-005, adopted by the RWQCB in 2015). 6 Proposed milestones for MCM enhancement implementation are detailed in Table 2-8. 7 If regional BMPs are deemed necessary for dry weather compliance, their construction dates will be moved up to meet the dry weather deadlines. 8 The proposed compliance schedule for wet weather bacteria and all Category 3 pollutants was selected to be consistent with the Dominguez Channel and Greater Los Angeles and Long Beach Harbor Waters Toxic Pollutants TMDL (Dominguez Channel Toxics TMDL) (RWQCB, 2011). This compliance schedule is the minimum time expected to be necessary for the agencies to plan, design, permit, construct, monitor, and adaptively manage the proposed wet weather BMPs. 9 Cyanide, pH, selenium, mercury, and cadmium are Category 3 pollutants in Dominguez Channel. Arsenic, chromium, silver, nickel, mercury, and thallium are Category 3 pollutants in Dominguez Channel Estuary. 10 This will be assumed to be the case if monitoring data show that outfall concentrations and receiving water concentrations are in excess of the applicable water quality criteria for the same monitoring event.
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Table 3-12 previously summarized the load reductions achieved for the quantified WBPCs for the interim and final compliance deadlines.
Zinc has been identified as the controlling pollutant for BMP implementation, as it would likely produce load reductions for the other pollutants greater than their individual TLRs. Therefore, it is assumed that the nonstructural and structural BMPs proposed to meet the zinc final TLR by 2032 would also achieve compliance with the other metals TLRs. Therefore, distributed green streets BMPs at a final implementation level of 14%27 and all regional BMPs are planned to be implemented no later than 2032 (with the exception of the Powerline Easement Project, as discussed below). At the time of the proposed final compliance deadline (2032), the proposed projects result in a 79% (DC-RB/MB analysis region) to 80% (DC-Torrance analysis region) load reduction, both of which are greater than the TLR of 76%. Copper TLRs are also proposed to be met in both analysis regions, in combination with the adaptive management approach discussed previously.
For bacteria, within the DC-RB/MB analysis region, the proposed final wet weather compliance deadline of March 2032 is proposed to be met through the suite of non-structural and structural BMPs, including distributed green streets BMPs at a 14% implementation level28. At the time of the proposed final compliance deadline (2032), this implementation plan results in a load reduction of 74% in analysis region DC-RB/MB, which is greater than the TLR of 33%. A 38% bacteria load reduction is estimated in the DC-Torrance analysis region. As shown in Table 3-12, the interim deadlines for bacteria are also proposed to be met through a combination of non-structural and distributed green streets BMPs, phased in over the compliance period.
It should be noted that although the inlet filters proposed in the DC-Torrance analysis region are not planned for 100% of catch basins (200 of 643 are currently planned in high priority drainage areas), the achieved load reduction will be evaluated through adaptive management, with additional filters to be installed as necessary to meet the TLRs by the specified compliance deadlines.
4.2 PROJECT SEQUENCING
In order to meet the compliance deadlines for the WBPCs discussed above based on load reduction projections in the RAA, the proposed structural BMPs within the Santa Monica Bay and Dominguez Channel Watersheds would be implemented per the timeline provided in Figure 4-1.
27 An “implementation level” of 14% is defined here to mean that runoff from 14% of land use areas (commercial, single family residential, multi-family residential, and industrial land uses) would be treated by green street BMPs (bioretention and biofiltration systems) designed as described in Section 2.6.3. 28 An “implementation level” of 7% is defined here to mean that runoff from 7% of land use areas (commercial, single family residential, multi-family residential, and industrial land uses) would be treated by green street BMPs (bioretention and biofiltration systems) designed as described in Section 2.6.3.
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Figure 4-1. Proposed Project Sequencing
COLOR KEY Funding Phase Design Phase Construction/ Installation Phase BMP Location/Name
Timeline
201520162017201820192020202120222023202420252026202720282029203020312032 Santa Monica Bay Watershed
Catch basin retrofits for trash
Manhattan Beach Infiltration
Trench1
Manhattan Beach Green streets
application in SMB-5-02
Hermosa Beach Greenbelt
Infiltration1
Hermosa Beach Infiltration
Trench
Redondo Beach Park #3
Green streets application in
SMB-6-01 for All Cities
Dominguez Channel Watershed
Catch basin inlet filters in DCTorrance Green Streets (Redondo Beach and Manhattan Beach) Treatment of 3%
of Land Uses
Treatment of
Additional 4% of
Land Uses
Treatment of
Additional 7% of
Land Uses
Redondo Beach Powerline
Easement Filtration1,2
Artesia Boulevard and
Hawthorne Boulevard Filtration2
in Redondo Beach
1Alternative project locations have also been identified 2Current regional BMP project sequencing in Dominguez Channel helps achieve dry weather bacteria TMDL compliance. If compliance is met through other means, regional BMP scheduling in Dominguez Channel may be pushed back so that regional projects are instead complete by March 2032.
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5 ASSESSMENT AND ADAPTIVE MANAGEMENT FRAMEWORK
Adaptive management is a critical component of the EWMP implementation process, and EWMP updates are required at two-year cycles by the Permit. The CIMP will gather additional data on receiving water conditions and stormwater/non-stormwater quality. These data will support adaptive management at multiple levels, including: (1) tracking improvements in water quality over the course of EWMP implementation and (2) generating data not previously available to support model updates. Furthermore, over time, the experience gained through intensive BMP implementation will provide lessons learned to support modifications to the control measures identified in the EWMP.
The adaptive management process also includes a schedule for developing and reporting on the EWMP updates, the approach to conducting the updates, and the process for implementing any modifications to the RAA and EWMP to reflect the updates.
The adaptive management approach for the Beach Cities EWMP area is designed to address the EWMP planning process and the relationship between monitoring, scheduling, and BMP planning.
The adaptive management process outlines how the EWMP will be modified in response to monitoring results, updated modeling results, and lessons learned from BMP implementation. It is designed to accomplish three goals:
1. Clarify the short-term and long-term commitments of the Beach Cities WMG within the EWMP.
2. Provide a structured decision-making process for modifications to the EWMP based on the results of monitoring data.
3. Propose a structure for evaluating compliance with water-quality based permit requirements within an adaptive structure.
As outlined in Section 4, the schedule and milestones for the EWMP have been designed around meeting the interim and final TMDL requirements for bacteria and metals. While the EWMP identifies actions that will lead to compliance with the final TMDL limitations, the specific actions taken will be informed by monitoring data collected under the CIMP, special studies that may be conducted during implementation, and any applicable regulatory changes that could influence the remaining interim and final milestones and schedule. For example, the Statewide Bacteria Amendments have the potential to modify water quality objectives in the Ocean Plan and Basin Plan, as well as the TMDL WLAs and their WQBEL and/or RWL expressions in the Permit. These changes could affect the required load reductions for bacteria as well as the watershed control measures identified herein.
Monitoring data will be utilized to measure progress towards achieving RWLs and WQBELs. An evaluation of monitoring data will be carried out on a biennial basis in accordance with Figure 5-1 to determine if modifications to the EWMP are necessary. Modifications that are warranted because final milestones are achieved more quickly than anticipated can be made at any time (i.e. no more actions are needed if fewer control measures result in meeting RWLs and/or WQBELs).
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Modifications that are warranted because insufficient progress is being made will be noted every two years in the annual report and a schedule for implementation will be provided. A full update to the EWMP and the RAA is not anticipated as the schedule for bacteria compliance is only six years long. Updating the EWMP and RAA is a significant and costly undertaking that is not necessary unless conditions change significantly and additional modeling is needed to inform implementation decisions. However, at any point, the Beach Cities Agencies could choose to update the EWMP and the associated RAA, particularly if deemed appropriate based on monitoring data.
If at any point during the implementation period any of the permit conditions are modified in response to a regulatory action, TMDL modification, or local studies, the receiving water and outfall monitoring data will be compared to the new RWLs and WQBELs. The same procedure will be followed for evaluating the data and adapting the EWMP, but the new RWLs and WQBELs will be used for the analysis.
The process outlined in Figure 5-1 applies during the implementation period for the EWMP. At the end of the implementation period for the TMDLs, if the final RWL and/or WQBELs are not being met, either the TMDL must be modified to adjust the schedule or the permittees will need to apply for a Time Schedule Order or other mechanism to get an extension of the compliance deadlines.
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Figure 5-1. Adaptive Management Approach
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6 FINANCIAL ANALYSIS
In June of 2014, the Beach Cities WMG submitted the Beach Cities EWMP Work Plan to the LARWQCB (Beach Cities WMG, 2014). The EWMP Work Plan described the approach to cost estimation and scheduling for the EWMP, which is addressed in this section. This section provides an order-of-magnitude estimate of the financial resources that may be required to attain compliance with the 2012 MS4 Permit’s RWLs and WQBELs, as well as a recommended project scheduling in order to meet TMDL compliance deadlines and interim deadlines. Planning-level cost opinions associated with implementation of the proposed structural BMPs within the Beach Cities WMG area are provided based on RAA results.
Prior to and separate from the EWMP, BMP cost effectiveness (i.e., pollutant load removed per dollar cost) were developed and evaluated by Geosyntec using SBPAT for a variety of BMP implementation scenarios. For example, it was found that regional infiltration BMPs, followed by regional flow-through treatment BMPs, followed by distributed green streets provide the greatest cost effectiveness, in part due to the economies of scale that benefit regional BMPs. Within those categories, greater BMP cost effectiveness is achieved for a given pollutant in order of the tributary land uses' EMC and runoff coefficient product (for example, for bacteria, commercial land use has a very high EMC and runoff coefficient; therefore, a given BMP type is most cost effective when placed downstream of a commercial area). This relative cost effectiveness understanding was applied by Geosyntec in identifying and prioritizing BMP implementation scenarios for agency consideration in this WMG. The most cost effective yet implementable BMPs were then sequentially incorporated into the EWMP (i.e., with the most cost effective BMPs added first) until reasonable assurance of compliance was demonstrated.
Cost opinions are presented as an aid for decision makers, and contain considerable uncertainties.
Given the iterative and adaptive nature of the EWMP and the many variables associated with the projects, the budget forecasts are order-of magnitude opinions, and are subject to change based on site-specific BMP feasibility assessment findings, preliminary and final BMP designs and landscaping, BMP effectiveness assessments, results of outfall and receiving water monitoring, and special studies such as those that might result in site specific objectives which could modify water quality objectives or TMDL Waste Load Allocations for a specific WBPC.
A financial strategy and details regarding potential funding sources and programs to support the financial resources required for the structural BMPs being proposed in the EWMP are also provided herein. These funding sources and programs may be utilized depending on applicability and feasibility.
6.1 BMP COST METHODOLOGY AND ASSUMPTIONS
6.1.1 HARD COST ASSUMPTIONS
Costs estimated for structural BMPs include “hard” costs for tangible assets and are determined using a line item unit cost approach, which separately accounts for each material cost element required for the installation of a given BMP. Quantities for each line item were calculated based on
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BMP storage/treatment volumes and typical design configurations. A safety factor was applied to the BMP footprints for calculation of design parameters, for both the low and high cost estimates.
Unit costs were taken from RS Means 29 , past projects based in Southern California, recent construction cost/bid information, and vendors. Line item unit costs of the proposed structural BMPs are included in Appendix O. Since the majority of proposed BMPs were located on publicly owned land to reduce land acquisition costs to the extent possible, land acquisition costs were not considered as part of this analysis.
6.1.2 SOFT COST ASSUMPTIONS
Structural BMP cost opinions also include “soft” costs, which include considerations such as design and permitting. Soft costs are project costs that cannot be calculated on a unit cost basis. For conceptual cost estimating, these costs are generally calculated as a percentage of total capital costs.
The soft costs considered for each BMP were:
• Utility Realignment— Costs associated with the relocation of utilities that are located within the proposed BMP footprint or inhibit construction activities. • Mobilization and Demobilization – The costs associated with activation/deactivation of equipment and manpower resources for transfer to/from a construction site until completion of the contract.
• Planning, Permitting, Bond, and Insurance Costs – Cost, including planning and permit fees and personnel hours, of obtaining required permits for BMP installation. Examples of permits needed may include erosion and sediment control, stormwater, construction, and public space permits. Potential bond and insurance costs are also included. • Engineering and Planning – Costs associated with BMP and site design, as well as access for maintenance, environmental mitigation, buried objects, safety/security, traffic control, limited space, and site restoration.
• Construction Management – The costs associated with management and oversight of the construction of the BMP, from project initiation until completion of the contract.
Estimated soft costs as percent of total project capital costs are presented in Table 6-1. These percentages were based on literature, best professional judgment, and data from past projects (Brown and Schueler, 1997; International Cost Engineering Council, 2014).
29 RS Means is a unit cost database that is updated annually (http://www.rsmeansonline.com/). When costs from literature are not available project’s design criteria and unit costs from the database were used to estimate the project’s cost.
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Table 6-1. Range of Soft Costs for Proposed Structural BMP Projects as a Percent of Capital Cost Item
Cost Range
Low High
Utility Realignment 0% 3%
Mobilization/Demobilization1 3% 10%
Planning, permitting, bond, and insurance costs 5% 10%
Engineering and Planning 20% 40%
Construction Management 8% 15%
1 $2,000 minimum fee
6.1.3 OPERATIONS AND MAINTENANCE
Annual Operations and Maintenance (O&M) costs were assumed to be two percent of the capital cost for subsurface infiltration basins, two percent of the capital cost for sub-surface biofilters, five percent of the capital cost for subsurface infiltration trenches, and six percent of the capital cost for green streets (USEPA, 2005; Weiss et al., 2007). O&M opinions for underground infiltration basins include cleaning and removal of debris after major storm events, mowing and maintenance of surface vegetated areas, and sediment cleanout. O&M necessary for maintaining sub-surface biofilters includes landscape maintenance, media and gravel replacement once clogged when surface scarification is no longer effective, pest control, sediment and pre-treatment cleanout. O&M for underground infiltration trenches includes cleaning and removal of debris, repairs to inlet/control structures, and pre-treatment cleanup. O&M for green streets includes repairs to eroded areas, incremental landscape maintenance, media and gravel replacement once clogged and surface scarification is no longer effective, removal of trash and debris, and removal of aged mulch with installation of a new layer. O&M costs have been summarized as 20-year lifecycle costs, with no discounting applied, also including post-construction monitoring.
Additional maintenance will be necessary after the 20-year lifecycle. Extended maintenance for subsurface infiltration includes excavation and washing of all drain rock on a 25-year cycle and is estimated to be approximately 60 percent of capital costs. All drainage elements should be replaced on a 50-year cycle, at approximately 125 percent of capital costs. Cisterns should be replaced after a useful life of approximately 50 years, at 125 percent of the capital cost. Green streets should be excavated, disposing of existing soil media, and backfilled with new soil media every 25 to 50 years at approximately 90 percent of capital costs.
Typical maintenance for trash exclusion devices includes removal of trash and sediment, and catch basins should be cleaned at a minimum of once or twice per year. Trash exclusion devices can be plugged if they are overloaded with sediment or debris, greatly reducing their efficiency. Inspection and cleanout is recommended after major storm events, or storms with a rainfall intensity of greater than one inch in 12 hours.
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6.1.4 ADDITIONAL DESIGN ASSUMPTIONS
Additional design details were assumed for the purpose of the cost estimation presented herein, including, but not limited to:
• The percentage of excavated material requiring hauling; • The type and length of BMP inflow and outflow conveyance structures; • The type and quantity of vegetation required for the post-BMP condition; • The percentage of the parcel area requiring hydroseeding for the post-BMP condition; • The type of pre-treatment used for each BMP.
6.2 PROPOSED STRUCTURAL BMPS
As previously described, regional and distributed structural BMP options are proposed to achieve compliance with the RWLs and WQBELs. Table 6-2 summarizes the basic, concept-level design assumptions for each of the proposed structural BMPs which formed the basis for the conceptual cost opinions.
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Table 6-2. Proposed BMP Design Assumptions for Conceptual Cost Opinions Analysis
Region BMP Name1 BMP Description
Design Storage
Volume (cu-ft)
Tributary
Area (acres)
SMB-5-02
Manhattan Beach
Infiltration Trench –
Alternative 1
Located along the coast of Manhattan Beach, the sub-surface trench has a potential surface area of 2.2 ac, an average depth of
2.1 ft with a diversion rate of 160 cfs and an infiltration rate under the trench of 13 in/hr.
198,000 1,4752
SMB-5-02
Manhattan Beach
Infiltration Trench –
Alternative 2
Located along the coast of Manhattan Beach, the sub-surface trench has a potential surface area of 1.6 ac, an average depth of
2.1 ft with a diversion rate of 128 cfs and an infiltration rate under the trench of 13 in/hr.
158,400 1,4752
SMB-5-02
Polliwog Park
Infiltration Gallery –
Alternative 2
Located adjacent to Manhattan Beach Boulevard in Manhattan Beach, the sub-surface infiltration gallery has a potential surface area of 1 ac, an average depth of 4 ft, a diversion flowrate of 11 cfs, and an infiltration rate of 0.74 in/hr.
148,100 470
SMB-5-02 Distributed Green
Streets – Alternative 1
The distributed green streets, proposed to address runoff from 5% of single family residential, multi-family residential, and commercial land uses, are assumed to have 6 in of ponding, 1.5 ft of amended soil, 3 in of mulch, and an infiltration rate of 0.15 in/hr.
205,500 66
SMB-5-02 Distributed Green
Streets – Alternative 2
The distributed green streets, proposed to address runoff from 5% of single family residential, multi-family residential, and commercial land uses, are assumed to have 6 in of ponding, 1.5 ft of amended soil, 3 in of mulch, and an infiltration rate of 0.15 in/hr.
142,100 45
SMB-6-01 Hermosa Beach
Infiltration Trench
Located along the coast of Hermosa Beach, the sub-surface trench has a potential surface area of 0.2 ac, an average depth of 1.7 ft, a diversion flowrate of 25 cfs, and an infiltration rate of 12.5 in/hr. 13,300 2,0002
SMB-6-01 Hermosa Beach
Greenbelt Infiltration3
Located between Valley Dr. and Ardmore Ave., the sub-surface trench has a potential surface area of 1.5 ac, an average depth of 5 ft, a diversion flowrate of 48 cfs, and an assumed infiltration rate of 12 in/hr.
319,000 1,8002
SMB-6-01 Park #3
Located northwest of Blossom Lane and 190th street, the subsurface infiltration basin has a potential surface area of 0.4 ac, an average depth of 5ft , a diversion flowrate of 13 cfs, and an infiltration rate of 1 in/hr.
87,100 1,4302
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Analysis
Region BMP Name1 BMP Description
Design Storage
Volume (cu-ft)
Tributary
Area (acres)
SMB-6-01 Distributed Green
Streets
The distributed green streets, proposed to address runoff from 25% of single family residential, multi-family residential, and commercial land uses, are assumed to have 6 in of ponding, 1.5 ft of amended soil, 3 in of mulch, and an infiltration rate of 0.15 in/hr.
605,200 190
SMB 5-02,
SMB 6-01,
DC –
MB/RB
Trash exclusion devices
The City of Redondo Beach plans to retrofit 1,085 catch basins (634 of which are County-owned), the City of Hermosa Beach will retrofit 151 (79 of which are County-owned), and the City of Manhattan Beach plans to retrofit 640 (200 of which are Countyowned) catch basins. All cities will retrofit catch basins with automatic retractable screens (ARS) and connector pipe screen full capture trash systems (CPS).
N/A -
DC –
MB/RB
Powerline Easement
and Manhattan Beach
Blvd Infiltration
Located along powerline easements and/or adjacent to Marine Avenue and Manhattan Beach Boulevard, the sub-surface
biofilter has a potential surface area of 7.2 ac, an average depth of 5 ft, a diversion flowrate of 132 cfs, and a negligible infiltration rate.
N/A
(Flow-through
BMP)
1,500
DC –
MB/RB
Artesia Blvd. and
Hawthorne Blvd.
Filtration
Located near the intersection of Artesia Blvd. and Hawthorne Blvd., the sub-surface biofilter has a potential surface area of 1 ac, an average depth of 5 ft, a diversion flowrate of 13.6 cfs, and a negligible infiltration rate.
N/A
(Flow-through
BMP)
130
DCMB/RBDistributed Green
Streets
The distributed green streets are assumed to have 6 in of ponding, 1.5 ft of amended soil, 3 in of mulch, and an infiltration rate of 0.15 in/hr.
636,300 200
DCTorrance Catch basin inlet filters The City of Torrance plans to retrofit 200 of 643 catch basins with inlet filters. N/A 5,760
1 All projects listed in this table (except for the catch basin inlet filters in DC-Torrance) were modeled in the RAA and sized to collectively comply with the WQBELs and RWLs in combination with other existing and proposed structural and non-structural BMPs. Within the DC-Torrance analysis region, catch basin inlet filters are assumed to achieve WQBEL/RWL compliance based on a review of literature/studies on their performance. The total load reduction from inlet filters will be evaluated in the future through CIMP monitoring, as part of the EWMP adaptive management process. At that time, the catch basin BMPs will be modified, with additional filters installed as necessary and additional structural/non-structural BMPs proposed as needed to meet the TLRs required to achieve water quality objectives by the compliance deadlines. 2 This includes upstream BMPs and associated tributary drainage areas 3 Alternative project locations have also been identified
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6.2.1 COST OPINION - SMB WATERSHED - ANALYSIS REGION SMB-5-02 For the SMB subwatershed tributary to compliance monitoring location SMB-5-02, two implementation alternatives were identified in the RAA. Alternative 1 includes the Manhattan Beach Infiltration Trench and distributed green streets at a 5% application rate30. Alternative 2 includes a reduced volume of the Manhattan Beach Infiltration Trench (i.e., reducing the volume by approximately 20%), the Polliwog Park Infiltration Gallery project, and distributed green street BMPs at a 5% application rate.
Table 6-3 outlines the costs associated with Alternative 1 and Table 6-4 outlines the costs associated with Alternative 2. Based on projected cost alone, Alternative 1 (larger beach infiltration trench, without Polliwog Park project) is the preferred option, however a preliminary engineering study is needed to verify the feasibility of Alternative 1 so Alternative 2 is included to demonstrate an alternate approach to reasonable assurance. Trash exclusion devices will also be implemented in the SMB 5-02 analysis region. These costs were determined for each city (Redondo Beach, Manhattan Beach, and Hermosa Beach) and are presented in Section 6.2.5.
Further cost opinion details are provided in Appendix O.
30 An “application rate” of 5% is defined here to mean that 5% of RAA-specified land use areas (commercial, single family residential, and multi-family residential land uses) would be treated by green street BMPs (bioretention and biofiltration systems) designed as described in Section 2.6.3.
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Table 6-3. Estimated Construction and O&M Costs for Structural BMPs in Analysis Region SMB-5-02, Alternative 1 Project Name Manhattan Beach Infiltration Trench Distributed Green Streets Location of BMP Manhattan Beach Manhattan Beach
Cost Range Low High Low High
Capital Subtotal $2,700,000 $3,800,000 $1,800,000 $3,600,000 Utility Realignment $0 $110,000 $0 $110,000
Mobilization/Demobilization $81,000 $380,000 $53,000 $360,000 Planning, permitting, bond, and insurance costs $140,000 $380,000 $89,000 $360,000 Engineering and Planning $540,000 $1,500,000 $350,000 $1,500,000 Construction Management $220,000 $570,000 $140,000 $550,000 Total Estimated Project Construction Cost $3,700,000 $6,800,000 $2,400,000 $6,500,000 Annual O&M $140,000 $190,000 $110,000 $220,000
Total 20-year Lifecycle Cost $6,100,000 (low) to $13,000,000 (high)
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Table 6-4. Estimated Construction and O&M Costs for Structural BMPs in Analysis Region SMB-5-02, Alternative 2 Project Name Manhattan Beach Infiltration Trench Polliwog Park Infiltration Gallery Distributed Green Streets Location of BMP Manhattan Beach Manhattan Beach Manhattan Beach Cost Range Low High Low High Low High
Capital Subtotal $2,200,000 $3,300,000 $2,100,000 $2,500,000 $1,200,000 $2,500,000 Utility Realignment $0 $98,000 $0 $74,000 $0 $75,000
Mobilization/Demobilization $67,000 $330,000 $64,000 $250,000 $37,000 $250,000 Planning, permitting, bond,
and insurance costs $110,000 $330,000 $110,000 $250,000 $61,000 $250,000 Engineering and Planning $450,000 $1,300,000 $430,000 $990,000 $240,000 $1,000,000 Construction Management $180,000 $490,000 $170,000 $370,000 $98,000 $380,000 Total Estimated Project
Construction Cost $3,000,000 $5,800,000 $2,900,000 $4,400,000 $1,700,000 $4,500,000 Annual O&M $110,000 $160,000 $43,000 $50,000 $73,000 $150,000 Total 20-year Lifecycle Cost $7,600,000 (low) to $15,000,000 (high)
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6.2.2 COST OPINION - SMB WATERSHED – ANALYSIS REGION SMB-6-01 The RAA within analysis region SMB-6-01 predicts that the TLR will be met with reasonable assurance through implementation of the proposed Hermosa Beach Infiltration Trench, Hermosa Beach Greenbelt Infiltration, Park #3, and a combination of green street BMPs at an application rate of 25%31. Table 6-5 outlines the costs associated with this structural BMP combination which, when implemented with the existing structural regional BMPs and non-structural control measures32 detailed in the RAA modeling efforts, will achieve TLR compliance at CML SMB-6-01.
Trash exclusion devices will also be implemented in the SMB 6-01 analysis region. These costs were determined for each city (Redondo Beach, Manhattan Beach, and Hermosa Beach) and are presented in Section 6.2.5. Further cost estimate details are provided in Appendix O.
31 An “application rate” of 25% is defined here to mean that runoff from 25% of RAA-specified land use areas (commercial, single family residential, and multi-family residential land uses) would be treated by green street BMPs (bioretention and biofiltration systems) designed as described in Section 2.6.3. 32 Non-structural control measures include redevelopment, public retrofit incentives, non-MS4 parcels/areas, and programmatic BMPs.
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Table 6-5. Estimated Construction and O&M Costs for Structural BMPs in Analysis Region SMB-6-01 Project Name Hermosa Beach
Infiltration Trench
Hermosa Beach Greenbelt
Infiltration Park #3 Distributed GreenStreets
Location of BMP Hermosa Beach Hermosa Beach or
Redondo Beach Redondo Beach
Hermosa Beach, Manhattan
Beach, Redondo Beach,
Torrance
Cost Range Low High Low High Low High Low High
Capital Subtotal $370,000 $640,000 $4,100,000 $4,500,000 $1,400,000 $1,700,000 $5,200,000 $11,000,000 Utility Realignment $0 $19,000 $0 $130,000 $0 $50,000 $0 $320,000 Mobilization/Demobilizatio
n $11,000 $64,000 $120,000 $450,000 $42,000 $170,000 $160,000 $1,100,000 Planning, permitting, bond,
and insurance costs $18,000 $64,000 $200,000 $450,000 $70,000 $170,000 $260,000 $1,100,000 Engineering and Planning $74,000 $260,000 $810,000 $1,800,000 $280,000 $660,000 $1,000,000 $4,200,000 Construction Management $29,000 $96,000 $320,000 $670,000 $110,000 $250,000 $410,000 $1,600,000 Total Estimated Project
Construction Cost $500,000 $1,100,000 $5,500,000 $8,000,000 $1,900,000 $3,000,000 $7,000,000 $19,000,000 Annual O&M $18,000 $32,000 $81,000 $90,000 $28,000 $33,000 $310,000 $640,000 Total 20-year Lifecycle
Cost $15,000,000 (low) to $31,000,000 (high)
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6.2.3 COST OPINION - DOMINGUEZ CHANNEL WATERSHED – ANALYSIS REGION DC-RB/MB According to the Beach Cities RAA model analysis of the Redondo Beach and Manhattan Beach areas within the Dominguez Channel Watershed, it is predicted that the TLR will be met with reasonable assurance through implementation of the proposed Powerline Easement Infiltration Project, Artesia Boulevard Infiltration Project, and a combination of green street BMPs at an application rate of 14%33 . Table 6-6 outlines the costs associated with these proposed projects which, when implemented with non-structural control measures 34 detailed in the RAA modeling efforts, are predicted to achieve TLR compliance within the Manhattan Beach and Redondo Beach areas within the Dominguez Channel Watershed.
Trash exclusion devices will also be implemented in the DC-RB/MB analysis region. These costs were approximated for each city (Redondo Beach, Manhattan Beach, and Hermosa Beach) and are presented in Section 6.2.5. Further cost estimate details are provided in Appendix O.
33 An “application rate” of 14% is defined here to mean that runoff from 14% of RAA-specified land use areas (commercial, single family residential, and multi-family residential land uses) would be treated by green street BMPs (bioretention and biofiltration systems) designed as described in Section 2.6.3. 34 Non-structural control measures include redevelopment, public retrofit incentives, non-MS4 parcels/areas, and programmatic BMPs.
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Table 6-6. Estimated Construction and O&M Costs for Structural BMPs in Analysis Region DC-RB/MB1 Project Name Powerline Easement
Infiltration
Artesia Blvd
Infiltration
Distributed Green
Streets
Location of BMP Redondo Beach Redondo Beach Redondo Beach/Manhattan Beach
Cost Range Low High Low High Low High
Capital Subtotal $8,200,000 $9,200,000 $1,500,000 $1,800,000 $5,500,000 $11,000,000 Utility Realignment $0 $270,000 $0 $53,000 $0 $340,000
Mobilization/Demobilization $250,000 $920,000 $45,000 $180,000 $160,000 $1,100,000 Planning, permitting, bond, and insurance costs $410,000 $920,000 $75,000 $180,000 $270,000 $1,100,000 Engineering and Planning $1,600,000 $3,700,000 $300,000 $710,000 $1,100,000 $4,500,000 Construction Management $660,000 $1,400,000 $120,000 $260,000 $440,000 $1,700,000 Total Estimated Project Construction Cost $11,000,000 $16,000,000 $2,000,000 $3,100,000 $7,400,000 $20,000,000 Annual O&M $160,000 $180,000 $30,000 $35,000 $330,000 $670,000 Total 20-year Lifecycle Cost $20,000,000 (low) to $39,000,000 (high) 1 Costs for the Powerline Easement Infiltration project and Artesia Boulevard Infiltration project were estimated based on cost information for lined biofilters with engineered media; the design elements of which cover a range of infiltration options.
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6.2.4 COST OPINION - DOMINGUEZ CHANNEL WATERSHED – ANALYSIS REGION DCTORRANCE An analysis of the proposed catch basin inlet filters predicts an estimated load reduction attributable to each inlet filter installed. Table 6-7 outlines the approximate high and low capital and O&M costs associated with 200 retrofits. Further cost estimate details are provided in Appendix O.
Table 6-7. Estimated Construction and O&M Costs for Structural BMPs in Analysis Region DC-Torrance
Project Name Catch Basin Inlet Filters
Location of BMP Torrance
Cost Range Low High
Capital Subtotal $240,000 $360,000
Total Estimated Project Construction Cost $240,000 $360,000 Annual O&M $130,000 $170,000
Total 20-year Lifecycle Cost $2,840,000 (low) to $3,760,000 (high)
6.2.5 COST OPINION – TRASH EXCLUSION DEVICES – ALL ANALYSIS REGIONS The Cities of Manhattan Beach, Redondo Beach, and Hermosa Beach plan to retrofit catch basins with trash exclusion devices (either automatic retractable screens [ARSs] and/or connector pipe screen [CPS] full capture trash systems in the Santa Monica Bay watershed). The City of Redondo Beach plans to retrofit 1,085 catch basins (634 of which are County-owned), the City of Hermosa Beach will retrofit 151 catch basins (79 of which are County-owned), and the City of Manhattan Beach plans to retrofit 640 catch basins (200 of which are County-owned) catch basins. These catch basin retrofits will be located in SMB-5-02, SMB-6-01, as well as in the other analysis regions in SMB; these catch basin retrofits will work in combination with other regionally sited BMPs. The City of Torrance has substantially completed retrofit of its Santa Monica Bay watershed area through several recent grant funded projects so costs for City of Torrance trash exclusion devices are not included. Not included in these costs are the retrofits of catch basins in high priority areas of Dominguez Channel to meet the MCMs in the MS4 Permit for areas without trash TMDLs.
Table 6-8 outlines the costs associated with these retrofits, as approximated by each city. Annual O&M costs for trash exclusion devices reflect additional costs for cleaning the inserts/screens only.
An estimate of current costs spent to clean non-retrofitted catch basins was subtracted from the annual O&M estimate, resulting in annual O&M required for the addition of the inserts/screens only. Further cost estimate details are provided in Appendix O.
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Table 6-8. Estimated Construction and O&M Costs for Catch Basin Retrofits Location of BMP Hermosa Beach Redondo Beach Manhattan Beach Cost Range Low High Low High Low High
Capital Subtotal1 $110,000 $370,000 $790,000 $2,600,000 $470,000 $1,600,000 Mobilization2 $5,500 $18,000 $40,000 $130,000 $23,000 $78,000 Permitting3 $40,000 $40,000 $320,000 $320,000 $100,000 $100,000 Total Estimated Project Construction Cost $160,000 $430,000 $1,100,000 $3,100,000 $590,000 $1,700,000 Annual O&M $50,000 $64,000 $360,000 $460,000 $210,000 $270,000 Total 20-year Lifecycle Cost $1,900,000 (low) to $5,200,000 (high) 1 Includes cost of both ARS and CPS
2 5% of capital subtotal cost
3 $500 for each County-owned catch basin only
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6.2.6 SUMMARY OF COST OPINIONS
Table 6-9 summarizes the total 20-year life-cycle cost opinions for each proposed structural BMP, which are composed of the cost to construct or implement each structural BMP plus the associated annual O&M costs over 20 years. In order to account for possible variations in BMP design, BMP configurations, and site-specific constraints, as well as for uncertainties in available BMP unit costs from literature or estimated BMP unit costs, a range of costs is presented. Table 6-9 includes combined costs for proposed structural BMPs by analysis region and by watershed. Not included in these costs are the annual monitoring costs for implementing the CIMP or the costs associated with implementing baseline and enhanced MCMs.
From the analysis of potential costs in this section as summarized in Table 6-9, it is clear that projected costs of implementing the EWMP are substantial and orders of magnitude higher than have previously been expended by the agencies under the previous MS4 Permit. Thus availability of funds will be critical for the implementation of the EWMP. Currently, the Beach Cities do not have sufficient funds or dedicated funding streams to construct and maintain the projects proposed in this EWMP.
The Beach Cities agencies are working with the Los Angeles County Division of the League of California Cities and the California Contract Cities Association to partner with other affected agencies to collectively influence State policies, pursue changes in legislation and lobby high level officials for additional stormwater funding. Working together with the other cities will increase effectiveness, communication, collaboration, and reduce redundant efforts. The LACFCD will also work with the Beach Cities WMG in their efforts to address source controls; assess, develop, and pursue funding for structural BMPs, and promote the use of water reuse and infiltration. As regional project scopes are further refined, the LACFCD will determine on a case-by-case basis their contribution to the projects.
In addition to working with other affected cities on a regional level, the Beach Cities WMG individually and collaboratively are committed to pursue funding sources at a local level including but not limited to:
• Grants - Collaboration and coordination between the Beach Cities will be important to increase accessible grant funding opportunities for stormwater projects, however alternative funding sources will also be needed to provide stable O&M revenues since grants typically do not provide for O&M.
• Interagency Partnerships – Interagency partnerships, like the Beach Cities WMG, can allow agencies to leverage local funding resources to make cost intensive projects possible. • Local Bond Issuance - Two types of local bonds can be utilized. General Obligation (GO) bonds are issued by local governments and repaid through a property tax surcharge. Revenue bonds are tax-exempt securitized bonds repaid through utility rate increases charged directly to customers.
• Local Stormwater Assessments - Stormwater charges are potentially the most critical local funding source to finance stormwater programs. These charges include stormwater fees and taxes.
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• Direct Subsidies - Direct financial subsidies to local projects 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.
These potential sources of funding are discussed in greater detail in Section 7.
6.2.7 CLOSING DISCUSSION
In concluding its review of the LA MS4 Permit in response to petitions on the order, the SWRCB acknowledges that:
“Addressing the water quality impacts of municipal storm water is a complex and difficult undertaking, requiring innovative approaches and significant investment of resources. We recognize and appreciate the commendable effort of the Los Angeles Water Board to come up with a workable and collaborative solution to the difficult technical, policy, and legal issues, as well as the demonstrated commitment of many of the area’s MS4 dischargers and of the environmental community to work with the Los Angeles Water Board in the development and implementation of the proposed solution. We also recognize the extensive work that interested persons from across the state, including CASQA, have invested in assisting us in understanding how the watershed-based alternative compliance approach developed by the Los Angeles Water Board may inform statewide approaches to addressing achievement of water quality requirements. While storm water poses an immediate water quality problem, we believe that a rigorous and transparent watershed-based approach that emphasizes low impact development, green infrastructure, multi-benefit projects, and capture, infiltration, and reuse of storm water is a promising long-term approach to addressing the complex issues involved. We must balance requirements for and enforcement of immediate, but often incomplete, solutions with allowing enough time and leeway for dischargers to invest in infrastructure that will provide for a more reliable trajectory away from storm water-caused pollution and degradation. We believe that the Los Angeles MS4 Order, with the revisions we have made, strikes that balance at this stage in our storm water programs, but expect that we will continue to revisit the question of the appropriate balance as the water boards’ experience in implementing watershed-based solutions to storm water grows.” [Revised draft Order, April 24, 2015, p.86-87 conclusion]35
35 Revised Draft April 24, 2015. State of California State Water Resources Control Board Order WQ 2015-XX In the Matter of Review of Order No. R4-2012-0175, NPDES Permit No. CAS004001 Waste Discharge Requirements for the 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.
Issued by the California Regional Water Quality Control Board, Los Angeles Region. SWRCB/OCC Files A2236(a)-(kk).
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The SWRCB also states that:
“The WMP/EWMP provisions constitute an effort to set ambitious, yet achievable, targets for Permittees; receiving water limitations, on the other hand, while the ultimate goal of MS4 permitting, may not in all cases be achievable within the five-year permit cycle.
Generally, permits are best structured so that enforcement actions are employed when a discharger shows some shortcoming in achieving a realistic, even if ambitious, permit condition and not under circumstances where even the most diligent and good faith effort will fail to achieve the required condition.” [Revised draft Order, April 24, 2015, p.35]36 Additionally, SWRCB in discussing compliance with receiving water limitations provisions stated:
“Yet, we are sympathetic to the assertions made by MS4 dischargers that the receiving water limitations provisions mandated by our Order WQ 99-05 may result in many years of permit noncompliance, because it may take years of technical efforts to achieve compliance with the receiving water limitations, especially for wet weather discharges. Accordingly, we believe that the MS4 permits should incorporate a well-defined, transparent, and finite alternative path to permit compliance that allows MS4 dischargers that are willing to pursue significant undertakings beyond the iterative process to be deemed in compliance with the receiving water limitations.” [Revised draft Order, April 24, 2015, p. 17]37 The Beach Cities WMG agencies appreciate the SWRCB acknowledgement of the challenges that lie ahead, the understanding of the need for adaptive management in this complex and difficult undertaking, and the significant commitment of resources that must be secured to carry out this ambitious plan to address the water quality impacts of municipal stormwater.
36 Revised Draft April 24, 2015. State of California State Water Resource’s Control Board Order WQ 2015-XX In the Matter of Review of Order No. R4-2012-0175.
37 Revised Draft April 24, 2015. State of California State Water Resource’s Control Board Order WQ 2015-XX In the Matter of Review of Order No. R4-2012-0175.
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Table 6-9. Capital, O&M, and 20-year Life-Cycle Cost Opinion for Proposed Structural BMPs by Analysis Region Watershed/
Analysis Region Location of BMP Project Name
Construction Cost
Range Annual O&M Range
Total 20-Year LifeCycle1 Range
Low High Low High Low High
Santa Monica Bay
Watershed
SMB-5-02,
Alternative 1
Manhattan Beach Manhattan Beach Infiltration Trench2 $3.7M $6.8M $140K $190K $6.5M $11M Manhattan Beach Distributed Green Streets $2.4M $6.5M $110K $220K $4.6M $11M SMB-5-02 Alternative 1 Combined Costs $6.1M $13M $250K $410K $11M $22M SMB-6-01
Hermosa Beach Hermosa Beach Infiltration Trench $500K $1.1M $18K $32K $860K $1.7M Hermosa Beach Hermosa Beach Greenbelt Infiltration2 $5.5M $8.0M $81K $90K $7.1M $9.8M Redondo Beach Park #3 $1.9M $3.0M $28K $33K $2.5M $3.7M Hermosa Beach Distributed Green Streets $7.0M $19M $310K $640K $13M $32M SMB-6-01 Combined Costs $15M $31M $440K $800K $23M $47M All Analysis
Regions
Hermosa Beach Trash exclusion devices $160K $430K $50K $64K $1.1M $1.7M Redondo Beach Trash exclusion devices $1.1M $3.1M $360K $460K $8.3M $12M Manhattan Beach Trash exclusion devices $590K $1.7M $210K $270K $4.8M $7.1M Combined Costs in Santa Monica Bay Watershed $23M $50M $1.3M $2.0M $49M $90M Dominguez
Channel
Watershed
DC-RB/MB
Redondo Beach Powerline Easement Infiltration2 $11M $16M $160K $180K $14M $20M Redondo Beach Artesia Blvd Infiltration $2.0M $3.1M $30K $35K $2.6M $3.8M Redondo Beach +
Manhattan Beach Distributed Green Streets $7.4M $20M $330K $670K $14M $33M DC-RB/MB Combined Costs $20M $39M $520K $890K $31M $57M DC-Torrance Torrance Catch basin inlet filters $240K $360k $130K $170k $2.8M $3.7M DC-Torrance Combined Costs $240K $360k $130K $170k $2.8M $3.7M Combined Costs in Dominguez Channel Watershed $20M $39M $650K $1.1M $33M $61M Combined Costs of All Proposed Structural BMPs $43M $89M $2.0M $3.1M $82M $150M M = Million dollars, K = Thousand dollars
1 Life-cycle costs include construction costs and 20 years of annual O&M (in 2015 dollars) and are not discounted. 2 Alternative project locations have also been identified, but are not included in combined cost opinion
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7 POTENTIAL FUNDING SOURCES AND FINANCIAL STRATEGY
The availability of funds will be critical for the implementation of the EWMP. This section provides an overview of potentially available funding sources for programs proposed in the EWMP. The funding sources included in this section for consideration are grants, interagency partnerships, bonds, State Revolving Funds, local funding opportunities, and public private partnerships.
The Beach Cities will establish a Memorandum of Understanding (MOU) for implementation of the EWMP. Development of the MOU will be initiated in March 2016 with the goal of completing the MOU by December 2016. At minimum, the scope of the MOU will address how the group will investigate and pursue funding for regional structural BMP projects described in the EWMP, and will include such details as delineation of responsibility, funding milestones, methods to secure funding, and others. The scope of the MOU may also include but is not limited to other joint EWMP implementation activities such as public information and participation programs.
In addition, each City in the Beach Cities WMG is also committed to pursuit of funding for individual 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 continuing work under the Stormwater Funding Options study (Farfsing and Watson, 2014 which will assist the City in 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 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 Council has recently committed to funding green alleyways between Beach Drive and Hermosa Avenue in an effort to improve water quality and flood impacts near the beach.
• The City of Manhattan Beach, like the City of Hermosa Beach, has committed financial support for continuation of the Stormwater Funding Options study. The City is also committed to implementing its Green Street Policy for capital improvement projects in the public right-ofway, 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 the high priority area. City staff has an excellent track record and enjoys 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 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 recent addition of catch basin trash screening devices into the Esplanade Street Resurfacing Project. In addition, the City has a
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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 Stormdrain Diversion and Infiltration Project.
• The City of Torrance has appropriated funding for their catch basin inlet filters in the Dominguez Channel Watershed and has appropriated funding to complete their TMRP implementation by the end of 2016 (four years ahead of the TMDL compliance deadline). In addition, the City’s green streets policy requires green street BMPs to be integrated with 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 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 be investigated, as described below.
7.1 GRANT OPPORTUNITIES
Grants have historically been a backbone for financing stormwater projects. The majority of the water-related grants are designated for flood control, drinking water, and watershed protection; very few grants are made available for the sole purpose of stormwater permit compliance. For example, the State of California has planned to spend $7.5 billion under the Water Quality, Supply and Infrastructure Improvement Act (2014), but only $200 million have been designated for stormwater capture projects statewide to enhance regional water reliability. In order to increase the likelihood of getting grant funding, a stormwater project might need to be added to a larger project or program that serves different proposes and has different objectives rather than just for stormwater management. Thus, collaboration and coordination between stormwater agencies and other public agencies would be important to increase accessible grant funding opportunities for stormwater projects.
It is noted that 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 any funded projects. Table 7-1 presents the potential grant opportunities available that the Beach Cities can apply to fund the EWMP projects. The Beach Cities WMG intends to pursue the following grant opportunities:
The Beach Cities WMG has expressed commitment to pursue grant opportunities. The first joint effort will be for Prop 1 Coastal Conservancy in March 2016 for design of two priority regional projects – the Manhattan Beach Infiltration Trench Project and the Hermosa Beach Greenbelt Infiltration Project. Initiation of this pursuit has already begun, with the grant application expected to be submitted by the March 2016 deadline. The Beach Cities WMG intends to submit the Beach Cities EWMP for incorporation into the Integrated Regional Water Management Plan.
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Since SB-985-Stormwater Resource Planning became effective in 2014, local governments have been required to have a stormwater resource plan and be in compliance with provisions of SB-985 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. The EWMP could potentially be utilized as a functionally equivalent plan but further clarification will need to be provided in the guidance document which is anticipated to be established by the State Water Resource Control Board by July 1, 2016. Agencies and the LARWQCB staff should review and comment on the guidance document to ensure that these plans can be utilized.
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Table 7-1. 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, protect
endangered and threatened species,
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.
Funding will be awarded at one of
two levels: Funding Group I:
Up to $300,000 per agreement for a
project up to 2 years.
Funding Group II: Up to
$1,500,000 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. The primary goal is to
address two major concerns
synonymous with watershed groups
– 1) the need for funding to pay the
salary of a full-time coordinator and
2) the limited funding available for
project management.
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 needs of the state,
including the delivery of safe drinking
water, flood risk reduction, 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.
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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.
Santa Monica
Bay Restoration
Plan Proposition
84 ($18 million
allocated)
Santa Monica
Bay
Restoration
Commission
Providing a funding source for
implementation of projects that
protect Santa Monica Bay beaches
and coastal waters, prevent
contamination and degradation of
coastal waters and watersheds, and
protect and restore the Bay’s marine,
freshwater, and terrestrial habitats.
Projects that do not meet the
Clean Beaches Program
requirements. O&M projects are
not eligible.
A minimum of $150,000 and a
maximum of $6 million per project.
Approximately $7 million have
been made available for the recent
request for proposals that closes on
January 15, 2016.
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.
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Program Department Purpose Ineligible Uses Funding Limits 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.
IRWM Grant
Program, Prop 1
($510M, 2014)
and Prop 84
($232M,
remaining).
Department
of Water
Resources
Funding for planning
and implementation of IRWM, and
groundwater sustainability.
IRWM plans/projects that do not
contribute to addressing climate
change risks; do not meet the
requirements stated in the Prop
1 and Prop 84 Program
Guidelines.
A total of $98M of the Prop 1
funding has been allocated to the
Los Angeles Region. The Los
Angeles Region has about $40M of
remaining balance from Prop. 84
(after 2014 Drought Grant
Awards).
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7.2 PROJECT-SPECIFIC INTERAGENCY PARTNERSHIPS
Stormwater management projects often overlap with the jurisdiction of other public agencies, including water agencies, as well as parks and schools. Interagency partnerships would not only allow agencies involved to leverage one other’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 non-potable 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 7-2 provides a list of potentially viable partnerships and the benefits derived from management of stormwater runoff.
Table 7-2. Added Benefits of Interagency Partnership for Stormwater Management Potential Partners Benefits Derived from Stormwater Management Flood control district • Flood protection
• Climate change mitigation
Water agencies • Potable water conservation through stormwater use for nonpotable 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
7.3 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.
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
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are repaid through utility rate increases charged directly to customers. Recent enactment of AB850-Public Capital Facilities: Water Quality allows local publically 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).
Since the enactment of AB-850, a JPA, called Southern California Public Water Authority (SCPWA), has been established by the Los Angeles Department of Water and Power and the Burbank Water and Power (LADWP, 2015). The first two members of the SCPWA are the City of Los Angeles and the City of Burbank. The Beach Cities can consider becoming members of the SCPWA. However, details on how bond proceeds can be directed to pay for eligible stormwater projects identified in the EWMP will need to be further evaluated. It is expected that high level of collaboration and coordination between stormwater and water agencies would be 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.
7.4 STATE REVOLVING FUNDS
Clean Water State Revolving Fund (CWSRF) Program, which is managed by the State Water Resource Control Board and funded by the US Environmental Protection Agency, is an alternative funding source for development of new infrastructure projects that will benefit water quality. The CWSRF finances water quality projects similar to those proposed in the EWMP, including nonpoint source, watershed protection or restoration, 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 cost-saving achieved from utilizing the CWSRF can vary between 17% and 25% of the total project costs compared to conventional loans (USEPA, 2014; SWRCB, 2014). The maximum repayment term is 20 years. The CWSRF also has an Expanded Use program that provides funding for stormwater treatment and
Beach Cities EWMP | Section 7 | Potential Funding Sources and Financial Strategy 7-9 | Page 201 8
diversion, sediment and erosion control as well as stream restoration projects (CFCC, 2015). This special program offers interest rate at one-half of the general obligation bond rate with a repayment period of up to 30 years. There is no limit in terms of the amount an agency can borrow under this program. The main limitation of the CWSRF is that it cannot be used for project operation and maintenance (O&M) purposes (USEPA, 2013b).
The Infrastructure State Revolving Fund Program managed by the California Infrastructure and Economic Development Bank provides financing for public infrastructure projects for environmental mitigation purposes (CFCC, 2015). The loan can be used for construction or modification of public infrastructure, including educational, cultural, and social facilities, purchase and installation of pollution control equipment, and parks and recreation facilities. The loan size can range between $50,000 and $25 million with a maximum repayment period of 30 years. The interest rate is based on market rate but may be adjusted based on the social and economic status of the area where the project will be implemented.
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.
7.5 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 7-3 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.
Beach Cities EWMP | Section 7 | Potential Funding Sources and Financial Strategy 7-10 | Page 201 8
Table 7-3. 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 7-3 are subject to approval mechanisms that can vary from holding a simple written protest hearing to an election, depending on the type of funding sought after (Table 7-4). The types of charges that are deemed to be most suitable for stormwaterrelated services are property-related fees. For a property-based flood control-related stormwater management fees, 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. The recent 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 are also 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. An amendment to Proposition 218 that will allow stormwater fees to be treated like water, sewer, and refuse fees, is being discussed and considered (CSQA, 2015). A new AB-1362, which is designed to include the definition of “stormwater” into the California Constitution’s Article XIII C and Article XIII D, was introduced to the State Assembly on February 27, 2015. The introduction of this Bill marks the first step toward such an amendment of Proposition 218.
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 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).
Beach Cities EWMP | Section 7 | Potential Funding Sources and Financial Strategy 7-11 | Page 201 8
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 TMDLrelated 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 it discourages 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 7-4. 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-ofservice 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)
Non-propertyrelated feesFlexible Flexible Stricter requirements (more likely to be a tax)
Wholesale fees Flexible Flexible Stricter cost-of-service requirements
Source: Public Policy Institute of California (PICC), 2014.
Beach Cities EWMP | Section 7 | Potential Funding Sources and Financial Strategy 7-12 | Page 201 8
7.6 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 7-5. Based on these examples presented in Table 7-5, 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 7-5, 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.
Beach Cities EWMP | Section 7 | Potential Funding Sources and Financial Strategy 7-13 | Page 201 8
Table 7-5. Selected Cities that provide Financial Subsidies to encourage the Development of Stormwater Infrastructure in Private Properties
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 [SPU],
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
7.7 FINANCIAL STRATEGY
The above examples describe how the stormwater management program can potentially be funded using multiple approaches rather than a single fee arrangement. Such a strategy could potentially reduce the risk of insufficient support by voters or property owners. Based on the above discussions, a summary of potential financial approaches is provided in Table 7-6.
Beach Cities EWMP | Section 7 | Potential Funding Sources and Financial Strategy 7-14 | Page 201 8
Table 7-6. Funding Approach Summary
Approach Funding Type Limitations
Potential Significance
(with Respect to Overall
Funding)
Grants New Revenue • Competitive
• No guarantee of funding accessibility
• Infrastructure projects only
• Application preparation/submission
requires significant staff time
• Can only be used to pay for infrastructurerelated projects • O&M costs are typically excluded
Medium
Project-Specific
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
High
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)
• O&M costs are typically excluded (except
for stormwater fee)
High
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
Beach Cities EWMP | Section 7 | Potential Funding Sources and Financial Strategy 7-15 | Page 201 8
7.8 WATERSHED MANAGEMENT PROGRAM BUDGETS
Table 7-7 provides watershed management program budget information for the Cities of Hermosa Beach, Manhattan Beach, Redondo Beach, and Torrance, as presented in the cities’ Annual Reports per NPDES No. CAS 004001 Los Angeles County Municipal Storm Water Permit Order No. 01-182 and certain provisions of Order No. R4-2012-0175.
Table 7-7. Watershed Management Program Budgets for the Beach Cities WMG City of Manhattan Beach City of
Redondo Beach
City of
Hermosa Beach City of Torrance
Program Element Expenditures
in FY14-15
Budget
FY15-16
Expenditures
in FY14-15
Budget
FY15-16
Expenditures
in FY14-15
Budget
FY15-16
Expenditures
in FY14-15
Budget
FY15-16
1. Program Management
$26,567 $15,900 $29,700 $29,700
$126,525 (CDD
staff)
$36,416 -MS4
Annual Fee
$140,000
a. Administrative staff
time included included included included $13,000 $13,000 Included included b. Administrative
consultant support included included included included $22,414 $19,800 included Included c. NPDES Permit fee
and WDR fee N/A N/A N/A N/A $10,000 $9,594 N/A N/A
2. Public Information and
Participation
a. Public Outreach and
Education $8,184 $5,400 $7,700 $7,700 $8,057 $6,600 $6,500 $10,000 b. Employee Training $9,716 $9,600 $7,700 $7,700 $6,092 $9,300 $2,500 $3,500 c. Used Oil, BCR
(Hermosa Beach)/
c. Corporate Outreach
(Redondo Beach,
Torrance)
N/A N/A $6,600 $6,600 $15,692 $15,455 N/A $1,500
d. Business Assistance $1,735 $1,500 $7,700 $7,700 $3,085 $3,300 N/A $1,000
3. Industrial/Commercial
$99,000 $99,000
$126,691 (fireinspection &
enforcement)
$135,000
a. Consultant $1,112 $ 900 Included Included $3,263 $900 N/A N/A
Beach Cities EWMP | Section 7 | Potential Funding Sources and Financial Strategy 7-16 | Page 201 8
City of Manhattan Beach City of
Redondo Beach
City of
Hermosa Beach City of Torrance
Program Element Expenditures
in FY14-15
Budget
FY15-16
Expenditures
in FY14-15
Budget
FY15-16
Expenditures
in FY14-15
Budget
FY15-16
Expenditures
in FY14-15
Budget
FY15-16
b. Restaurant Inspect
(incl. FOG) $37,500 $35,000 Included Included
City’s cost
recovered
through fees
City’s cost
recovered
through
fees
N/A N/A
c. Commercial
Inspections $9,500 $12,000 Included Included N/A N/A
4. Development Planning $16,783 $2,400 $16,500 $16,500 N/A N/A a. Consultant/Special
Projects included included Included Included $9,797 $2,400 N/A N/A b. SUSMP and priority
project included included Included Included
City’s cost
recovered
through fees
City’s cost
recovered
through
fees
N/A N/A
5. Development Construction
a. Consultant N/A N/A N/A N/A N/A $4,500 N/A N/A
b. Construction Site
Inspections $12,000 $3,600 $26,400 $26,400
City’s cost
recovered
through fees
City’s cost
recovered
through
fees
$45,000 (BMP
Investigation,
Inspection)
$55,000
6. Public Agency Activities
a. Public Facility
Inventory and
BMPs
N/A N/A $26,400 $26,400 N/A- $9,000 $686,305.65 TBD
b. Municipal street
sweeping $346,000 $352,000 $1,045,000 $1,045,000 $164,354 $169,286 $1,240,000 $124,000 c. Downtown cleaning N/A N/A N/A N/A $141,577 $153,815 N/A N/A d. Catch basin and
insert cleaning $135,000 $138,000 $66,000 $66,000 $20,000 $28,688 $135,000 $135,000 e. Trash
collection/recycling $3,414,000 $3,483,000 $660,000 $660,000 N/A N/A $10,340,000
(PW), $402
(Transit)
$10,500,00
0 f. Capital Costs N/A $440,000 N/A N/A $957,626 $5,000 $76,000 $4,000,000 g. Consultant
assistance $10,831 $9,000 N/A N/A N/A N/A N/A N/A
h. Community
Services (Parks) N/A N/A N/A N/A $9,570 TBD
Beach Cities EWMP | Section 7 | Potential Funding Sources and Financial Strategy 7-17 | Page 201 8
City of Manhattan Beach City of
Redondo Beach
City of
Hermosa Beach City of Torrance
Program Element Expenditures
in FY14-15
Budget
FY15-16
Expenditures
in FY14-15
Budget
FY15-16
Expenditures
in FY14-15
Budget
FY15-16
Expenditures
in FY14-15
Budget
FY15-16
7. IC/ID Program $30,800 $30,800 N/A N/A
a. Sewer line hydro
flushing N/A N/A N/A N/A $126,885 $126,885 N/A N/A
b. Sewer CCTV,
emergency repairs N/A N/A N/A N/A $188,000 $272,325 N/A N/A c. IC/ID Program N/A N/A $1,518 $9,000 N/A N/A
d. Operations and
Maintenance $3,100 N/A Included Included N/A N/A
e. Consultant
Assistance $10, 831 $9,000 N/A N/A
8. Monitoring and TMDL
Compliance $30,800 $30,800 $150,000 $160,000
a. CIMP
Implementation N/A $80,000 N/A $26,222 included Included b. CSMP Monitoring
and Compliance $11,130 $11,350 $3,457 N/A included included
9. Watershed Planning and
Implementation N/A N/A
a. WMG Planning N/A N/A $10,276 $14,700 N/A N/A
b. EWMP and CIMP
development $65,000 $10,000 $27,704 $85,000 N/A N/A
c. TMDL Consulting
Services $12,500 $61,060 N/A N/A N/A N/A
10. Other
N/A N/A $209,000 $209,000 N/A N/A $20,000 (PW
and Parks)
$25,000
(PW and
Parks)
11. Total $4,131,489 $4,679,710 $2,275,900 $2,275,900 $1,732,797 $984,770 $13,000,910 15,290,000
Beach Cities EWMP | Section 8 | Legal Authority
8-1 | Page 201 8
8 LEGAL AUTHORITY
The Beach Cities WMG Permittees have the necessary legal authority to implement the BMPs identified in the EWMP, as provided in Appendix P.
Beach Cities EWMP | Section 9 | References
9-2 | Page 201 8
9 REFERENCES
Ackerman, D. and K. Schiff, 2003. “Modeling storm water mass emissions to the Southern California Bight.” SCCWRP Report #0390. Journal of Environmental Engineering. April.
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Beach Cities Watershed Management Group, 2014. Enhanced Watershed Management Program (EWMP) Work Plan for the Beach Cities Watershed Management Group. June.
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Carollo Engineers (Carollo), 2014. Broadway Neighborhood Greenway Project 100% Cost Estimate—General Conditions (DRAFT). Los Angeles, California. October.
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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.
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Geosyntec Consultants, 2008. A User’s Guide for the Structural BMP Prioritization and Analysis Tool (SBPAT v1.0): Technical Appendices. December.
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USEPA, 2014. Developing an Outreach Strategy. July 1.
(http://water.epa.gov/polwaste/npdes/swbmp/Developing-an-Outreach-Strategy.cfm) USEPA, 2015. Stormwater Management Model (SWMM).
Washington D.C., 2015. RiverSmart Rebates. District Department of the Environment. Washington D.C. (http://ddoe.dc.gov/riversmartrebates)
Weiss, P. T., J. S. Gulliver and A. J. Erickson, 2007. Cost and Pollutant Removal of Storm-Water Treatment Practices. Journal of Water Resources Planning and Management, Vol. 133.
Werner, I., Deanovic, L.A., Hinton, D.E., Henderson, J.D., de Oliveira, G.H., Wilson, B.W., Krueger, W., Wallender, W.W., Oliver, M.N., Zalom, F.G., 2002. “Toxicity of Stormwater Runoff after Dormant Spray Application of Diazinon and Esfenvalerate (Asana) in a French Prune Orchard, Glenn County, California, USA.
DESKTOP REVIEW
Site: Hermosa Beach Drywells
Prepared for
City of Hermosa Beach
1315 Valley Drive
Hermosa Beach, California 90254
Prepared by
Geosyntec Consultants, Inc.
5901 West Century Boulevard, Suite 1450,
Los Angeles, CA 90045
Project CWR0645/05
March 2023
CWR0645/05 Hermosa Beach Drywells, Herondo 1 Mar-23
1. INTRODUCTION
Geosyntec Consultants, Inc. (Geosyntec) was retained by the City of Hermosa Beach to perform a desktop review for potential drywell locations east of Pacific Coast Highway (PCH) between 1st Street and 10th Street in Hermosa Beach, California (the “Site”). The City of Hermosa Beach is planning to implement a series of drywells at the Site to capture stormwater and dry weather flows within 118 acres of the Herondo Drain watershed. This desktop review documents the review of publicly available records and regulatory files to assess potential environmental conditions associated with the Site.
2. SITE DESCRIPTION
The Site is located east of PCH between 1st Street and 10th Street in Hermosa Beach, California and is surrounded by a mix of commercial and residential properties. The location of the Site and the proposed drywell locations are shown on Figure 1.
3. PHYSICAL SETTING - HYDROLOGY
In general, groundwater flow direction may vary depending on area groundwater pumping, surface water bodies, land use and development, localized topography, and other macro and micro features. The Site is located within the Coastal Plain of Los Angeles County Groundwater Basin, West Coast Subbasin. Water bearing deposits within the Basin include unconsolidated and semiconsolidated marine and alluvium sediments. Injection wells in the West Coast Basin Barrier create a north-south trending groundwater mound and influences the groundwater levels and flow direction in the local area (CA DWR, 2004). Groundwater is projected to flow to the west towards the Pacific Ocean, located approximately 0.6-miles west of the Site. Based on groundwater measurements from a Los Angeles County Department of Public Works (LADPW)1 groundwater observation well located approximately 650 feet east-southeast of the Site (Well Number 714Q), depth to groundwater was reported at 156.5 feet below ground surface (bgs) in 2008.
4. RECORDS REVIEW
Geosyntec searched the California State Water Resources Control Board (SWRCB) GeoTracker online database2 and the Department of Toxic Substances Control (DTSC) EnviroStor3 online database for information relevant to the environmental condition of the Site and vicinity properties located within 1/3 mile from the Site. Properties greater than 1/3 mile from the Site were not evaluated because they are not anticipated to adversely affect the Site based on their location and proximity.
1 https://dpw.lacounty.gov/general/wells/#
2 https://geotracker.waterboards.ca.gov/
3 https://www.envirostor.dtsc.ca.gov/public/
CWR0645/05 Hermosa Beach Drywells, Herondo 2 Mar-23
Sites considered to be potential environmental concerns:
• Desert Petroleum is located within the northeast portion of the Site at 890 PCH and listed as a Leaking Underground Storage Tank (LUST) cleanup case (T0603701296). A LUST case was opened in 1996 for a release of gasoline affecting groundwater. The case is listed as completed and closed in 1999, however, records were not available for review online.
Due to the lack of additional information, this facility is considered a potential environmental concern.
Sites not considered to be potential environmental concerns:
• Vasek Polak Porsche-Audo located approximately 40 feet west (hydraulically downgradient) at 199 PCH was listed as a LUST cleanup case (T0603705055). A release of gasoline impacting soil was discovered during tank closure activities in 1996 and the case was issued closure in 1997. No records were available for review online, however, based on the lack of groundwater impact and downgradient location, this facility is not considered a potential environmental concern.
• Mobil #11-E3F located approximately 40 feet west (hydraulically downgradient) at 931 PCH was listed as a LUST cleanup case (T0603704808). The facility is an active Mobile gasoline service station. In 2001, soil contamination was discovered during dispenser upgrade activities. In 2007, soil samples collected during a subsurface investigation reported low to non-detect concentrations of petroleum hydrocarbons constituents.
Groundwater was not encountered to a total depth of 45 feet (Exxon Mobil, 2007). The case was issued closure by the LADPW in 2010. Based on the lack of groundwater impact, downgradient location and regulatory closure status, this facility is not considered a potential environmental concern.
• GTE Redondo Beach Central located approximately 70 feet south (hydraulically crossgradient) at 102 PCH was listed as a LUST cleanup case (T0603701295). Diesel contamination affecting groundwater was discovered in 1987. The RWQCB issued a NFA letter confirming completion of site investigation and remedial action in 1996. No additional records regarding investigation activities was available for review online.
Based on the time elapsed since the release and the closure status of the case, this facility is not considered a potential environmental concern.
CWR0645/05 Hermosa Beach Drywells, Herondo 3 Mar-23
• Jeep Eagle Dealership located approximately 180 feet southeast (hydraulically crossgradient) at 125 PCH was listed a LUST cleanup case (T0603705276). A release of aviation fuel to soil was reported in 1991 and the case was issued closure in 1991. No records were available for review online. Based on the lack of groundwater impact and distance from the Site, this facility is not considered a potential environmental concern.
5. FINDINGS AND CONCLUSIONS
Geosyntec has conducted a desktop review of the Site located east of PCH between 1st Street and 10th Street in Hermosa Beach, California. In 1996, a LUST case was investigated at the Site (Desert Petroleum, 890 PCH) involving a release of gasoline to groundwater. The facility received regulatory closure, however, records were not available for review online. Therefore, the Site likely has a high environmental risk potential in terms of hazardous substances and/or petroleum products in the soil, soil vapor, and groundwater from the adjoining historical Desert Petroleum property. However, this case is at least 250-ft from any proposed drywell. Furthermore, no exclusions for drywell suitability, as defined in the California Drywell Guidance Research and Recommendations Report (Geosyntec, 2020), are present at the proposed drywell sites. Exclusions include less than a 10-ft separation between the base of the drywell to the seasonally high groundwater table, sites within contaminated soils or contaminate groundwater plumes, sites with risk of septic effluent mobilization, sites within 150 feet of a drinking water well, sites within 250- ft of sources of surface water and groundwater contamination4 , and sites with slopes greater than
15% without a geotechnical review. Also consistent with the guidance, given that the contributing drainage areas do not include industrial facilities, the risk of the proposed drywells introducing additional contaminants into the groundwater basin is low to medium; pretreatment appropriate to the level of risk will be implemented as recommended.
6. LIMITATIONS
This desktop review is limited in scope and summarizes the findings from online research and documentation available at the time of the Review. No in-person file review or Site reconnaissance were performed.
Attachments:
Figure 1: Site Layout Map
4 Sources of surface water and groundwater contamination include auto shops, gas stations, dry cleaners, hazardous materials sites, contaminated soils, contaminated groundwater plumes, etc.
CWR0645/05 Hermosa Beach Drywells, Herondo 4 Mar-23
7. REFERENCES
California Department of Health Services, 1999. Drinking Water Source Assessment and Protection (DWSAP) Program, January.
California Department of Water Resources, 2004. Coastal Plain of Los Angeles County Groundwater Basin, West Coast Subbasin Description, 27 February.
Exxon Mobil, 2007. Soil Assessment Report, Mobil Station 18E3F. September 24.
Geosyntec, 2020. California Drywell Guidance Research and Recommendations, 31 March.
RWQCB, 1996. Underground Storage Tank Case Closure – GTE Redondo Beach Central Office.
October 29.
CWR0645/05 Hermosa Beach Drywells, Herondo 5 Mar-23
FIGURES
Hermosa Beach
Redondo Beach
Mobil #11-E3F
931 Pacific Coast Highway
Jeep Eagle Dealership
125 Pacific Coast Highway
GTE Redondo Beach Central
102 Pacific Coast Highway
Vasek Polak Porsche-Auto
199 Pacific Coast Highway
Desert Petroleum
890 Pacific Coast Highway South
HB_H_1
HB_H_2
HB_H_3
HB_H_4
HB_H_5
HB_H_6
HB_H_7
HB_H_8
HB_H_9
HB_H_10
HB_H_11
HB_H_17
HB_H_15 HB_H_16
HB_H_14
HB_H_13
HB_H_12
HB_H_19
HB_H_18
HB_H_20
HB_H_21
HB_H_22
HB_H_23
P:\GIS\Projects\CWR0645-BeachCities_EWMP_2020\Drywell Feasibility Study\Beach Cities\CWR0645 - BC Drywell Feasibility study - Enviro1.aprx Legend
Proposed Drywell Location
Approximate Evaluation Site Location
City Owned Storm Drain
County Owned Storm Drain
Evaluation Site Boundary
Drywell Subdrainage Area
Environmental Buffer (250 FT)
City Limits
Figure
1 CWR0645 March 2023
Hermosa Beach, CA
Data Sources:
1. CA State Water Resources Control Board GeoTracker, 2022.
2. CA Department of Toxic Substances Control EnviroStor, 2022. 0 450
1"=450'
§¨¦ §¨¦110
405
Hermosa Beach Distributed Infiltration Project
Environmental Screening Results
DRAFT
§¨¦105
City of Hermosa Beach | Page 1 of 5
Meeting Date: March 10, 2026
Staff Report No. 26-PR-004
Honorable Mayor and Members of the Hermosa Beach City Council APPROVAL OF IMPACT LEVEL III NEW SPECIAL EVENT – AFTER DARK TOUR LA 2026
Continued from meeting of February 24, 2026
(Lead Special Events and Filming Coordinator Kalyn Kaemerle) Recommended Action:
Staff recommends City Council hold a public hearing to consider and provide direction regarding the following options:
1. Approve the inclusion of the After Dark Tour LA 2026 on the 2026 Special Events Calendar on Saturday, October 17 to Sunday, October 18;
2. Approve the inclusion of the After Dark Tour LA 2026 on the 2026 Special Events Calendar on Saturday, October 24 to Sunday, October 25;
3. Deny the inclusion of the After Dark Tour LA 2026 on the 2026 Special Events Calendar, regardless of dates; or
4. Approve the inclusion of the After Dark Tour LA 2026 on the 2026 Special Events Calendar contingent on additional negotiations or event elements, as directed by City Council, between staff and Nike, the event producer.
Executive Summary:
The Parks and Recreation Department is tasked with overseeing special events on public property.
Staff has recently engaged in discussions with Nike regarding the potential to host a 13.1 mile women’s race that would begin in Redondo Beach, pass through Hermosa Beach and possible other South Bay cities to be determined, and conclude in Redondo Beach.
As a result of these discussions, the City received a formal special event application from Nike on January 8, 2026 proposing the After Dark Tour LA 2026 in the month of October 2026.
At its February 10, 2026 meeting, the Parks and Recreation Advisory Commission (Commission) held a public hearing and recommended City Council hold a public hearing to consider including Impact Level III new special event, After Dark Tour LA 2026, on the 2026 Special Events Calendar.
City of Hermosa Beach | Page 2 of 5
Background:
The City’s Special Events Policy Guide, available on the City website, provides event producers with detailed information regarding application requirements, review and approval procedures, applicable fees, relevant policies, and Hermosa Beach Municipal Code provisions related to special events. Events are evaluated using the Impact Characteristics Matrix and classified as Impact Level I, II, or III. The assigned impact level determines application deadlines and the level of review and approval required.
Based on the proposed event logistics, and anticipated impacts, the After Dark Tour LA 2026 qualifies as an Impact Level III event, which requires review by the Commission and City Council approval through a formal public hearing.
Past Commission Action
Meeting Date Description
February 10, 2026
The Parks and Recreation Advisory Commission
recommended City Council hold a public hearing to consider including Impact Level III new special event, After Dark Tour LA 2026, on the 2026 Special Events Calendar.
Discussion:
Commission Review
At its February 10, 2026 meeting, the Commission reviewed the proposed After Dark Tour LA 2026 event through a public hearing and expressed concern that residents and businesses did not have adequate time or sufficient information to provide meaningful input regarding potential impacts from the event as the event proposes use of various City streets and the Strand. As a result, the Commission suggested Nike distribute physical public notices to residents and businesses in advance of the March 10, 2026 City Council meeting to increase public participation and feedback. Nike subsequently mailed a postcard (Attachment 1) during the week of March 1, 2026 to all residents and businesses in the City notifying them of the City Council’s March 10, 2026 consideration of the event through a public hearing.
In addition to concerns regarding public outreach, the Commission shared concern over potential impacts associated with the proposed event, including visitor and resident parking availability and residential access, particularly along Hermosa Avenue and adjacent streets; potential conflicts with other permitted events occurring the same weekend, including Volley4Sound, scheduled for Saturday, October 17 on the beach volleyball courts north of the Pier, and Skechers Pier to Pier Friendship Walk, scheduled for Sunday, October 18 on The Strand and Pier Plaza; and impacts to businesses within the event footprint due to street closures, restricted access, and changes in traffic circulation.
City of Hermosa Beach | Page 3 of 5
Post-Commission Review Event Format Changes
Following the Commission’s February 10, 2026 meeting, Nike submitted modifications to the original route along Hermosa Avenue in an effort to minimize community impacts and incorporate feedback from the Commission and City staff. The modifications, reflected in Table 1 below, reduce the overall length of the route on Hermosa Avenue and limit use to the west (southbound) lane only, thereby maintaining two-way traffic flow in the east (northbound) lane. The course map is provided with the After Dark Tour LA 2026 Event Overview (Attachment 2). The revised footprint along the southbound lane would affect approximately 31% of curb parking. Nike has indicated that additional off-site parking areas and shuttle services within Hermosa Beach would be provided to mitigate parking impacts. Nike further indicated that shifting the course from the northbound lanes to the southbound lanes of Hermosa Avenue would reduce overall impacts and allow for smoother two-way traffic operations.
Event Details
Nike’s After Dark Tour LA 2026 would be a 13.1 mile women’s race titled “After Dark Tour LA 2026” that begins in Redondo Beach, passes through Hermosa Beach, and may include other South Bay cities (to be determined), and concludes in Redondo Beach. The race would take place on various City streets and The Strand, as indicated in Table 1 below, with estimated closure times for each location. The proposed event date is Saturday, October 17, 2026, with teardown scheduled for Sunday, October 18, 2026, by 7:00 a.m.
Table 1: Race Route and Times of Street/Strand Closure
STREET START FINISH LANE CLOSED OPEN
Herondo St. N. Francisca Ave. N. Harbor Dr. Eastbound 4:30 p.m. 9:30 p.m.
Hermosa Ave. Herondo St. 10th St. Southbound 4:45 p.m. 9:30 p.m. 10th St. Beach Dr. The Strand All 4:45 p.m. 9:15 p.m.
Beach Dr. 10th St. 14th St. All 4:45 p.m. 9:15 p.m.
14th St. Beach Dr. The Strand All 4:45 p.m. 9:45 p.m.
Hermosa Ave. 14th St. 26th St. Southbound 4:45 p.m. 10:00 p.m. 26th St. Hermosa Ave. The Strand All 4:45 p.m. 9:30 p.m.
The Strand 26th St. N. Harbor Dr. All 5:00 p.m. 10:00 p.m.
Nike has shared its plans to utilize course marshals, a licensed traffic control company, and provide all necessary staff, volunteers, and security personnel to ensure that all safety concerns are addressed. Nike is also considering the inclusion of on-course activations, including music such as DJ(s) or local youth band(s), lighting of the course for event participant safety, and branding elements such as temporary signage along the route.
Staff would work with Nike to ensure such on-course activations would be least impactful to surrounding residences and businesses.
City of Hermosa Beach | Page 4 of 5
Nike would be providing a community impact donation, valued at approximately $50,000, consisting of sporting apparel, equipment, and service sponsorship to local Hermosa Beach youth sports organizations; 30 complimentary entries each to Mira Costa High School and Redondo Union High School track teams; and 100 complimentary entries for Hermosa Beach residents.
Nike anticipates a positive economic impact for the City from event staff, participants and spectators of up to $1.68 million through dining, retail, services, and entertainment. This is further detailed in Nike’s After Dark Tour LA 2026 presentation (Attachment 3).
The estimated number of participants is approximately 12,000. Nike plans to provide multiple designated spectator areas in locations to be determined and approved by staff that would allow for up to 250 spectators at each location, approximately 1,000 spectators in total, divided along the race route. Nike would be committed to timely load-out procedures to avoid interference with other scheduled events and to restore normal traffic patterns as quickly as possible.
Should City Council have concerns with Nike’s first event date request of Saturday, October 17, with teardown on Sunday, October 18, due to potential conflicts with Volley4Sound (Saturday, October 17) and Skechers Pier to Pier Friendship Walk (Sunday, October 18), Nike has proposed an alternate event date of Saturday, October 24, with teardown Sunday, October 25. There are other permitted events occurring during that weekend include the IBVL Tournament Series on Saturday, October 24 and Beach Tennis Tournament on Saturday, October 24 to Sunday, October 25.
Nike has also committed to implementing a comprehensive business and resident notification plan to ensure that the community is adequately informed of the event and its impacts. Additional details are provided in the After Dark Tour LA 2026 Event Overview (Attachment 2), and Nike’s After Dark Tour LA 2026 presentation (Attachment 3) and the requested dates are included on the 2026 Special Events Calendar (Attachment 4).
Special Event Policy Guide Exceptions
Per the Special Events Policy Guide, only two events on any given day are permitted in the City. Nike’s first event date request of October 17, with teardown on Sunday, October 18, would result in three events on Sunday, October 18, including the Skechers Pier to Pier Friendship Walk and AAU High School Beach Volleyball League Matches. Approval of this first date request would therefore require an exception to the Special Events Policy Guide to allow for activity related to more than two events on that day. Similarly, Nike’s second event date request of Saturday, October 24, with teardown Sunday, October 25, would require the same exception for Saturday, October 24 due to the IBVL Tournament Series and Beach Tennis Tournament scheduled that day.
City of Hermosa Beach | Page 5 of 5
Lastly, if the event is approved by City Council, Nike would continue working with the City’s Special Event Team, which includes representatives from all applicable City departments, the Hermosa Beach Police Department, and the Los Angeles County Fire Department, throughout the planning and permitting process. Coordination will focus on ensuring all public safety requirements are met, including overnight security for event equipment, crowd management, emergency access lanes, accessible seating areas, and compliance with all permit conditions. Staff would also work with the event producers to develop a targeted marketing strategy consistent with City standards.
Fiscal Impact:
If approved, the event is anticipated to generate approximately $30,000 in revenue to the General Fund. The $30,000 would consist of location fees for the street closures, the Strand, Pier Plaza, and the teardown day. Since the event is planned for October 2026, it would be budgeted for the upcoming Fiscal Year 2026-27.
Direct costs for staff and services would be determined later, if approved. All costs would be the responsibility of the event producer.
Attachments:
1. After Dark Tour LA 2026 Postcard
2. After Dark Tour LA 2026 Event Overview
3. After Dark Tour LA 2026 Presentation
4. 2026 Special Event Calendar
Respectfully Submitted by: Kalyn Kaemerle, Lead Special Events and Filming Coordinator
Reviewed by: Brian Sousa, Senior Recreation Supervisor
Concur: Lisa Nichols, Parks and Recreation Director
Noted for Fiscal Impact: Henry Chao, Finance Manager
Concur: Brandon Walker, Administrative Services Director Approved: Steve Napolitano, City Manager
At its March 10, 2026 meeting, City Council will hold a public hearing to consider approval of the Nike After Dark Tour on either October 17 or October 24 of 2026. More information on how to view and provide public comment on the matter can be found at the City of Hermosa Beach website, www.hermosabeach.gov.
To host this event safely, the following temporary road closures and traffic adjustments would be in place:
The southbound lane of Hermosa Ave between Herondo Street and 25th Street would be closed from 4:30 PM–9:30 PM. During this time, traffic would either be diverted or managed as two‑way traffic in the northbound lane.
During this closure, designated time windows would allow vehicles to cross the race course to reach open roads. Additional parking options would also be provided to offset the temporary loss of on‑street parking on Hermosa Ave.
To maintain access to Pier Plaza and the nearby parking garages, the race route would briefly divert onto Beach Drive between 10th Street and 15th Street. Access to Pier Plaza would be maintained via Pier Avenue.
The Strand would be partially closed to pedestrian traffic between 5:00 PM–10:00 PM for the race route.
A dedicated pedestrian walkway would remain open on the east side of the Strand to ensure access for residents. Intermittent crossing points and a pedestrian bridge at Pier Plaza would also remain available to maintain convenient east–west access.
THE NIKE AFTER DARK TOUR IS A WOMEN LED 13.1‑MILE
HALF MARATHON. THE RACE IS REQUESTING CITY COUNCIL
APPROVAL TO TAKE PLACE IN HERMOSA BEACH ON EITHER
OCTOBER 17 OR OCTOBER 24 (DATE TO BE CONFIRMED).
HERMOSA AVE.
HERANDO ST.
HERMOSA AVE.
THE STRAND.
THE STRAND.
N. HARBOR
DRIVE.
BEACH DR.
14th St.
26th St.
10th St.
HERMOSA PIER.
PRSRT STANDARD
U.S. POSTAGE
PAID
PERMIT NO. 2101
WHITE PLAINS, NY
2026
City of Hermosa Beach Special Event Permit Application Overview Event Title: After Dark Tour LA 2026
Impact Level: III
Applicant Name: Jake Wanamaker
Organization Name: Nike
Non-Profit: NO/YES
Event Date(s): Saturday, October 17 and Sunday, October 18 (tear-down) Event Time: Saturday, October 17: 5:00 p.m. – 10:00 p.m.
Event Summary: Nike After Dark Tour 2026 – half marathon. This is a part of a global women's race series, happening in 7 cities
Returning Event: NO/YES
Event Location: The Strand, Pier Plaza, City streets (See page 2) Maximum Number of Participants: Up to 12,000
Maximum Number of Spectators: Up to 1,000
Age of Participants: Women- all ages
Participant Fee: Yes
Parking: Yes
Amplified Sound: Yes
Generator(s): Yes
Fenced Area(s): Yes
Stage(s), Structure(s) or Tent(s): Yes, lighting, signage, barricades, pedestrian bridges, and pop-up tents Security: Yes, to monitor event activities and infrastructure Sponsor(s): Yes
Vendor(s): Yes
Filming/Still Photography: Yes
Applicable Fees:
Application $1,094
Category IV $6,962 per location (2) = $13,924
Pier Plaza Use $14,574
Teardown fee $330 daily per location (2) = $660
Amplified Sound Permit $214
Cosponsor $368 per cosponsor (total TBD)
Parking TBD
*Additional fees may apply due to required staffing and/or services from the City of Hermosa Beach’s Community Resources Department, Community Services Department, Public Works Department, Police Department, and the Los Angeles County Fire Department.
Race Route and Times of Street/Strand Closure
STREET START FINISH LANE CLOSED OPEN
Herondo St. N. Francisca Ave. N. Harbor Dr. Eastbound 4:30 p.m. 9:30 p.m.
Hermosa Ave. Herondo St. 10th St. Southbound 4:45 p.m. 9:30 p.m. 10th St. Beach Dr. The Strand All 4:45 p.m. 9:15 p.m.
Beach Dr. 10th St. 14th St. All 4:45 p.m. 9:15 p.m.
14th St. Beach Dr. The Strand All 4:45 p.m. 9:45 p.m.
Hermosa Ave. 14th St. 26th St. Southbound 4:45 p.m. 10:00 p.m. 26th St. Hermosa Ave. The Strand All 4:45 p.m. 9:30 p.m.
The Strand 26th St. N. Harbor Dr. All 5:00 p.m. 10:00 p.m.
AFTER DARK TOUR
LOS ANGELES 13.1
HERMOSA BEACH
A GLOBAL RACE SERIES HELD IN
6 DIFFERENT COUNTRIES.
Designed to empower women runners, reclaiming the night as a safe space for community, strength, and celebration through sport.
THE NIKE AFTER DARK TOUR
12,000
Runners.
All ages
welcome.
43% first time
Half-Marathoners.
The Only
Stop in the US.
*2025 Pinnacle Stop
BUILD
COMMUNITY
INSPIRE
RUNNERS
CELEBRATE
BIG GOALS X X
ANNOUNCE
AFTER DARK
LOS ANGELES
CELEBRATE
RACE DAY Training Journey
SPRING July
Registration EXPO
10.14 10.17
Strong local sports
culture, with broad
participation across
youth, high school
and community clubs.
WHY THE SOUTH BAY?
Leader in healthy and
active living, with a
strong outdoor and
fitness community, a
natural fit to host an
aspirational race.
The California Dream:
Idyllic beach town
with high community
engagement.
Demonstrated
commitment to health
and wellness,
community
engagement, and
responsible event
operations.
Kevin Hart Attends
RUHS XC Practice
For Men’s Health - 2016
NIKE HAS LONG SUPPORTED SOUTH BAY HS ATHLETES
Nike elevates South
Bay Athletes in global
brand campaign.
2016 2025 2014 - Present
Nike Redondo Invitational:
serving +4,000 High school
athletes.
Mira Costa XC invited
to premier event: Nike
Cross Nationals in
PDX.
NIKE ATHLETE & OLYMPIAN RAI BENJAMIN DELIVERS CUSTOM
STATE CHAMPIONS JACKETS TO RUHS BOYS XC TEAM
JAN 2026
Nike comp’ed entry
for 12 High School
Girls XC Team to
participate in After
Dark 2025.
AFTER DARK 2025: A MEMORABLE MILESTONE
Personalized delivery to
practice including gear, VIP
experience race weekend.
30x Race Bibs to
Redondo Union HS
Girls XC Team.
Krista, thank you such an amazing experience for our girls. Their confidence is sky high after this event. Partially because of the fact that they finished an amazing half marathon, which is life changing. But to also be included as a guest made them feel like they were special. Their confidence and self belief is beyond where they ever imagined.
Thank you for all you do for our kids and this sport we love, Bob Leetch
Redondo Union High School
Track and Cross Country
INSPIRING RUNNERS
RANDY’S DONUTS
Dedicated Run Crew Cheer zone
Nike partnered with
Randy’s Donuts to be
an official Run Crew
Cheer Zone.
Nike directed
spectators to Randy’s
and purchased +1,000
Donuts and
giveaways to
spectators.
High energy moment
on-course, Elevated
branding, lighting and
DJ playing music.
Example of how Nike partnered with local businesses in ‘25
AFTER DARK LA
UPLIFTS LOCAL BUSINESSES
CHEER ZONE
PIER PLAZA
Pinnacle Spectator
experience, designed to
drive foot traffic.
Local Business Cheer Locations
Vista
Lighthouse Cafe
Hennessy’s Tavern
Barnacles
AFTER DARK EXPO RACE WEEKEND ON-COURSE
LOCAL VENDORS
EXPO FOOTPRINT
Identify local businesses to
partner pop-up
at race expo.
Local Businesses
Creamy Boys
Good Sol
The Baked Bear
Etc
ULTIMATE GIRLS WKND
LOCAL PARTNERS
Runner, spectator and Nike
employee incentives at local
businesses.
Local Business Locations
• BOLT
Sand Spa
• Mimosa Salon
• Healing Hands by Lani
• Radici
COMMUNITY BENEFITS
Sports Equipment & Service
Sponsorship
Race
Access
To Hermosa Youth
Sports Org. ($50K Retail Value)
100 Race Bibs
Hermosa Residents
30 Race Bibs
Mira Costa HS
30 Race Bibs
Redondo Union HS
ECONOMIC IMPACT
Direct Spending Impact
$1.2M–$1.68M projected runner + spectator spending
• Based on 70% of runners spending $150–$200 avg
• Includes dining, retail, services, and entertainment
Local Business Revenue Projections
Restaurants & Bars
• +18% to +32% increase in Saturday revenue
Coffee Shops & Quick Service
• +25% to +40% increase
Meaningful Weekend Lift for Hermosa Beach.
Retail (Apparel, Surf, Boutique)
• +12% to +20% increase
Service Businesses (Salons, Wellness, Fitness)
• +10% to +18% increase
• Driven by “Girls Weekend” incentives
Nike-Directed Spend
• $15K in production catering allocated to Hermosa
restaurants
• 1-2 room blocks in Hermosa for Nike VIPs
• Local hiring for event staffing, security, and operations
Nike After Dark Tour LA 13.1
13 Jan-Feb
- Initial outreach to cities
- Course Development
- Start conversations with
key stake holders and
venues that will
participate in the course
March-May
- RACE
ANNOUNCEMENT
- Engage local partners
- Identify and create
priority list to include
business, hotels,
theaters, churches,
residential along the
route to determine
access needs
- Begin “Save The Date”
email and phone
communication to
Priority List.
June-Aug
- 60 DAYS OUT
- Finalize special access
and parking needs
- Continue course visits
to finalize access plans
for priority businesses,
etc
- Schedule direct mailer
for residents + partner
with city to utilize
advance notification
systems
- Resident email hotline
to support resident
needs
May/June Sep-Oct
- 30 DAYS OUT
- Schedule second direct
mailer
- “Reminder” email blast
sent to priority list
- Continue
communication with
priority list
Race Week
- Final “reminder” sent to
all impacted residents
and businesses
- “No parking” signs
distributed along
course 72 hours prior in
partnership with DOT
- Advance notification
signs placed throughout
entire route 5-7 days
prior
- Final meeting with
Traffic Control company
and DOT to review final
plans
- All hands meetings with
DOT, PD, FD, city
partners
Minimize Impact - Hermosa Ave + Beach Dr
• Updated route option to reduce overall impact and number of affected residents • Decreased length of route on Hermosa Ave
• Route currently only utilizing West (Southbound) Lane of Hermosa Ave • Allows two-way flow of traffic on East (Northbound) Lane of Hermosa Ave • Current route footprint on Southbound lane affects only 31% of curb parking - Nike to provide parking + shuttle solutions at addl lots in Hermosa
• Detour from Hermosa Ave to Beach Dr based on Traffic engineers suggestion, keeping access to critical parking and traffic areas
• Rolling street closures & openings to minimize traffic and resident impact • Vehicle access windows/areas during street closures schedules • Pedestrian bridge at Pier Plaza - pinnacle spectator + business area, preserves pedestrian access • Pedestrian path along The Strand - preserving access for affected residents + pedestrians • Course staff to facilitate intermittent pedestrian on The Strand crossing during runner gaps • Runner wave release allows for dispersed runner traffic throughout Hermosa (8 wave starts) • Cohesive Business & Resident Notice plan
• Holistic Traffic, Safety, & Trash Plans
• Quick load-out times - eliminating impact on other events and restoring traffic to normal ASAP • Vehicle access “valve” along Hermosa Ave to permit traffic flow adjacent to course - to be determined
Redondo Beach / Hermosa Beach
Continued route on North Catalina Avenue and transition from Redondo Beach into Hermosa Beach (black line)
at Herondo Street / Hermosa Avenue
Hermosa Beach
Continued route on Hermosa Avenue / The Strand
Vehicle Crossing Point (purple line) – 2nd Street – Open 16:30 – 17:30 & 21:00 – 21:30
Hermosa Beach
Continued route on Hermosa Avenue / The Strand
Vehicle Crossing Point (purple line) – 22nd Street – Open 16:45 – 17:45 & 21:15 – 21:30
Street Closure Schedule - Hermosa Ave + Beach Dr
THANK YOU
TENTATIVE
2026 SPECIAL EVENTS
CALENDAR
City of Hermosa Beach
Community Resources Department
710 Pier Avenue, Hermosa Beach, CA 90254
(310) 318-0280
[email protected]
Sun Mon Tue Wed Thu Fri Sat
1 2 3
4 AAU Southern Pacific
Grand Prix Series
North Volleyball Courts
5 6 7 8 9 10
11 IBVL Tournament Series
North Volleyball Courts
12 13 14 15 16 17
18 19 AAU Southern Pacific
Grand Prix Series
North Volleyball Courts
20 21 22 23 Sidewalk Sale
Hermosa Avenue,
Pier Avenue & Pier Plaza
Impact Level II
24 IBVL Tournament Series
North Volleyball Courts
Sidewalk Sale
Hermosa Avenue,
Pier Avenue & Pier Plaza
Impact Level II
25 IBVL Tournament Series
North Volleyball Courts
Sidewalk Sale
Hermosa Avenue,
Pier Avenue & Pier Plaza
Impact Level II
26 27 28 29 30 31
January 2026
Impact Level I
Impact Level II
Impact Level III
Long-term Agreement
City Hosted
City Contracted Event
Sun Mon Tue Wed Thu Fri Sat
1 AAU Southern Pacific
Grand Prix Series
North Volleyball Courts
2 3 4 5 6 Winter Challenge
North Volleyball Courts
(Setup)
7 Winter Challenge
North Volleyball Courts
8 9 10 11 12 13 14 SoCal
Beach Foundation
North Volleyball Courts
15 16 AAU Southern Pacific
Grand Prix Series
North Volleyball Courts
17 18 19 20 21
22 AAU Southern Pacific
Grand Prix Series
North Volleyball Courts
23 24 25 26 27 28 HBLL Opening Day
Clark Field
Impact Level II
February 2026
Impact Level I
Impact Level II
Impact Level III
Long-term Agreement
City Hosted
City Contracted Event
Sun Mon Tue Wed Thu Fri Sat
1 IBVL Tournament Series
North Volleyball Courts
2 3 4 5 6 Beach Tennis Tournament
Beach Tennis Courts
7 Beach Tennis
Tournament
Beach Tennis Courts
8 Beach Tennis
Tournament
Beach Tennis Courts
9 10 11 12 13 14 St. Patrick’s Day Parade
Valley Drive, Pier Avenue,
Hermosa Avenue,
Schumacher Plaza, & Pier Plaza
Impact Level III
PENDING
SoCal
Beach Foundation
North Volleyball Courts
15 AAU Southern Pacific
Grand Prix Series
North Volleyball Courts
16 17 18 19 20 21
22 CBVA
North Volleyball Courts
23 24 25 26 27 28 SoCal
Beach Foundation
North Volleyball Courts
29 AAU Southern Pacific
Grand Prix Series
North Volleyball Courts
30 31
March 2026
Impact Level I
Impact Level II
Impact Level III
Long-term Agreement
City Hosted
City Contracted Event
Sun Mon Tue Wed Thu Fri Sat
1 2 3 4
5 Easter Sunrise Mass
South of Pier
AAU Southern Pacific
Grand Prix Series
North Volleyball Courts
6 7 8 9 10 Beach Tennis Tournament
Beach Tennis Courts
11 CBVA
North Volleyball Courts
Beach Tennis Tournament
Beach Tennis Courts
12 AAU Southern Pacific
Grand Prix Series
North Volleyball Courts
Beach Tennis Tournament
Beach Tennis Courts
13 14 15 16 17
Sidewalk Sale
Hermosa Avenue,
Pier Avenue & Pier Plaza
Impact Level II
18 Sidewalk Sale
Hermosa Avenue,
Pier Avenue & Pier Plaza
Impact Level II
SoCal
Beach Foundation
North Volleyball Courts
19 IBVL Tournament Series
North Volleyball Courts
Sidewalk Sale
Hermosa Avenue,
Pier Avenue & Pier Plaza
Impact Level II
PENDING
20 21 22 23 24 Surfers Walk of Fame
Kick-off Party
Community Theatre
Impact Level II
25 Surfers Walk of Fame
Spyder Surf Fest
Pier Plaza
Impact Level III
26 Tower 12 South Bay
Surf Series
South of the Pier
27 28 29 30
April 2026 Impact Level I
Impact Level II
Impact Level III
Long-term Agreement
City Hosted or City Contracted Event
Sun Mon Tue Wed Thu Fri Sat
1 2 Classic Car Show
Schumacher Plaza & Pier Plaza
Impact Level II
Pets in the Park
Valley Park
Impact Level II
HBLL Night at the Ballpark
Clark Field
Impact Level II
3 AAU Southern Pacific Grand Prix Series
North Volleyball Courts
4 5 6 7 8 9 CBVA
North Volleyball Courts
Impact Level III
Glow Ride for Cystic Fibrosis
Schumacher Plaza and the
Strand
10 AAU Southern Pacific Grand Prix Series
North Volleyball Courts
11 12 13 14 15 16 State of the Art
Cypress Avenue & 6th St.
Impact Level III
SoCal Beach Foundation
North Volleyball Courts
17 SoCal
Beach Foundation
North Volleyball Courts
18 19 20 21 Fiesta Hermosa
Pier Avenue, Hermosa Avenue,
Pier Plaza,
Schumacher Plaza, Lot A
(Setup)
Impact Level III
PENDING
22 CBVA
North Volleyball Courts
(Setup)
Fiesta Hermosa
Pier Avenue, Hermosa Avenue, Pier
Plaza, Schumacher Plaza, Lot A
(Setup)
Impact Level III
PENDING
23 CBVA
North Volleyball Courts
Fiesta Hermosa
Pier Avenue, Hermosa Avenue, Pier
Plaza,
Schumacher Plaza, Lot A
Impact Level III
PENDING
24 CBVA
North Volleyball Courts
Fiesta Hermosa
Pier Avenue, Hermosa Avenue, Pier Plaza, Schumacher Plaza, Lot A Impact Level III
PENDING
25 CBVA
North Volleyball Courts
Fiesta Hermosa
Pier Avenue, Hermosa Avenue, Pier Plaza,
Schumacher Plaza, Lot A
(Teardown)
Impact Level III
PENDING
26 Fiesta Hermosa
Pier Avenue, Hermosa
Avenue, Pier Plaza,
Schumacher Plaza,
Lot A
(Teardown)
Impact Level III
PENDING
27 28 Beach Tennis
Tournaments
Beach Tennis Courts
(Setup)
29 Beach Tennis Tournaments
Beach Tennis Courts
30 You Are Enough 5k
Schumacher Plaza &
Strand North of Pier
Beach Tennis
Tournaments
Beach Tennis Courts
31 Beach Tennis Tournaments
Beach Tennis Courts
AAU Southern Pacific Grand Prix Series
North Volleyball Courts
May 2026
Impact Level I
Impact Level II
Impact Level III
Long-term Agreement
City Hosted
City Contracted Event
June 2026
Impact Level I
Impact Level II
Impact Level III
Long-term Agreement
City Hosted
City Contracted Event
Sun Mon Tue Wed Thu Fri Sat
1 2 3 4 5 6 NOTHING WEEKEND
7 NOTHING WEEKEND 8 9 Beach Collegiate
National Team
Training Block
North Volleyball Courts
10 Beach Collegiate
National Team
Training Block
North Volleyball Courts
11 Beach Collegiate
National Team
Training Block
North Volleyball Courts
12 Fine Arts Festival
Community Center Lawn
(Load-in)
Impact Level III
Beach Collegiate National
Team Training Block
North Volleyball Courts
13 Fine Arts Festival
Community Center Lawn
Impact Level III
Out of System 4 Eyes
Tournament
North Volleyball Courts
14 Fine Arts Festival
Community Center Lawn
Impact Level III
15 World Championship Trials
North Volleyball Courts
16 World Championship Trials
North Volleyball Courts
17 World Championship Trials
North Volleyball Courts
18 World Championship Trials
North Volleyball Courts
19 AAU Southern Pacific
Grand Prix Series
North Volleyball Courts
20 AAU Southern Pacific
Grand Prix Series
North Volleyball Courts
South Bay Paddle
South of Pier
21 AAU Southern Pacific
Grand Prix Series
North Volleyball Courts
22 23 24 25 26 Beach Tennis
Tournament
Beach Tennis Courts
27 Smackfest Co-ed 4’s
Volleyball Tournament
North Volleyball Courts
28 Beach Tennis
Tournament
Beach Tennis Courts
29 30
July 2026
Sun Mon Tue Wed Thu Fri Sat
1 2 3 4
5 6 JVA/BVCA
National Championships
North & South
Volleyball Courts &
Beach Tennis Courts
(Setup)
Impact Level III
7 JVA/BVCA National Championships
North & South Volleyball Courts &
Beach Tennis Courts
Impact Level III
8 JVA/BVCA
National Championships
North & South
Volleyball Courts &
Beach Tennis Courts
Impact Level III
Shakespeare by the Sea
Valley Park
Impact Level I
9 JVA/BVCA
National Championships
North & South
Volleyball Courts &
Beach Tennis Courts
Impact Level III
Shakespeare by the Sea
Valley Park
Impact Level I
10 JVA/BVCA
National Championships
North & South
Volleyball Courts &
Beach Tennis Courts
Impact Level III
11 JVA/BVCA
National Championships
North & South
Volleyball Courts &
Beach Tennis Courts
Impact Level III
12 AAU
Hermosa Beach Championships
North & South
Volleyball Courts &
Beach Tennis Courts
(Setup)
Impact Level III
LA Galaxy Soccer Celebration
South of the Pier
Impact Level III
(Setup)
PENDING
13 AAU
Hermosa Beach
Championships
North & South
Volleyball Courts &
Beach Tennis Courts
Impact Level III
LA Galaxy Soccer Celebration
South of the Pier
Impact Level III
(Setup)
PENDING
14 AAU
Hermosa Beach Championships
North & South Volleyball Courts &
Beach Tennis Courts
Impact Level III
LA Galaxy Soccer Celebration
South of the Pier
Impact Level III
PENDING
15 AAU
Hermosa Beach
Championships
North & South
Volleyball Courts &
Beach Tennis Courts
Impact Level III
LA Galaxy Soccer Celebration
South of the Pier
Impact Level III
PENDING
16 AAU
Hermosa Beach
Championships
North & South
Volleyball Courts &
Beach Tennis Courts
Impact Level III
LA Galaxy Soccer Celebration
South of the Pier
Impact Level III
PENDING
17 AAU
Hermosa Beach
Championships
North & South
Volleyball Courts &
Beach Tennis Courts
Impact Level III
LA Galaxy Soccer Celebration
South of the Pier
Impact Level III
PENDING
18 AAU
Hermosa Beach
Championships
North & South
Volleyball Courts &
Beach Tennis Courts
Impact Level III
LA Galaxy Soccer Celebration
South of the Pier
Impact Level III
PENDING
19 AAU
Hermosa Beach Championships
North & South Volleyball Courts &
Beach Tennis Courts
Impact Level III
LA Galaxy Soccer Celebration
South of the Pier
Impact Level III
PENDING
20 AAU
Hermosa Beach Championships
North & South Volleyball Courts &
Beach Tennis Courts
Impact Level III
LA Galaxy Soccer Celebration
South of the Pier
(Teardown)
Impact Level III
PENDING
21 AAU
Hermosa Beach Championships
North & South Volleyball Courts &
Beach Tennis Courts
Impact Level III
AVP Junior National Championships
North & South Volleyball Courts &
Beach Tennis Courts
(Setup)
Impact Level III
PENDING
22 AVP Junior National
Championships
North & South
Volleyball Courts &
Beach Tennis Courts
Impact Level III
23 AVP Junior National
Championships
North & South
Volleyball Courts &
Beach Tennis Courts
Impact Level III
24 AVP Junior National
Championships
North & South
Volleyball Courts &
Beach Tennis Courts
Impact Level III
25 AVP Junior National
Championships
North & South
Volleyball Courts &
Beach Tennis Courts
Impact Level III
26 AVP Junior National Championships
North & South Volleyball Courts &
Beach Tennis Courts
Impact Level III
27 AVP Junior National
Championships
North & South
Volleyball Courts &
Beach Tennis Courts
(Teardown)
Impact Level III
28 29
International
Surf Festival
North & South of Pier &
North Volleyball Courts
(Setup)
Impact Level III
30 International
Surf Festival
North & South of Pier &
North Volleyball Courts
(Setup)
Impact Level III
31 International
Surf Festival
North & South of Pier &
North Volleyball Courts
Impact Level III
Impact Level I
Impact Level II
Impact Level III
Long-term Agreement
City Hosted
City Contracted Event
Sun Mon Tue Wed Thu Fri Sat
1 International
Surf Festival
North & South of Pier &
North Volleyball Courts (CBVA)
Impact Level III
2 International
Surf Festival
North & South of Pier
Impact Level III
3 International
Surf Festival
North & South of Pier
(Load-out)
Impact Level III
4 5 6 7 Triathlon
Downtown
(Load-in)
Impact Level III
8 Triathlon
Downtown
(Load-in)
Impact Level III
CBVA
North Volleyball Courts
9 Triathlon
Downtown
Impact Level III
CBVA
North Volleyball Courts
10 11 12 13 14 Sidewalk Sale
Hermosa Avenue,
Pier Avenue & Pier Plaza
Impact Level II
PENDING
Beach Tennis Tournament
Beach Tennis Courts
15 Sidewalk Sale
Hermosa Avenue, Pier Avenue & Pier Plaza
Impact Level II
PENDING
Beach Tennis Tournament
Beach Tennis Courts
16 Sidewalk Sale
Hermosa Avenue, Pier Avenue & Pier
Plaza
Impact Level II
PENDING
Beach Tennis Tournament
Beach Tennis Courts
17 18 19 20 21 22 NOTHING WEEKEND
23 NOTHING WEEKEND 24 25 26 27 28 29 AAU High School Boys Beach Volleyball League Matches
North Volleyball Courts
30 31
August 2026
Impact Level I
Impact Level II
Impact Level III
Long-term Agreement
City Hosted
City Contracted Event
Sun Mon Tue Wed Thu Fri Sat
1 2 3 Fiesta Hermosa
Pier Avenue, Hermosa
Avenue, Pier Plaza,
Lot A, Lot B
(Setup)
Impact Level III
PENDING
4 CBVA
North Volleyball Courts
and Schumacher Plaza
(Setup)
Fiesta Hermosa
Pier Avenue, Hermosa
Avenue, Pier Plaza,
Lot A, Lot B
Impact Level III
PENDING
5 CBVA
North Volleyball Courts
and Schumacher Plaza
Fiesta Hermosa
Pier Avenue, Hermosa
Avenue, Pier Plaza,
Lot A, Lot B
Impact Level III
PENDING
6 CBVA
North Volleyball Courts and Schumacher Plaza
Fiesta Hermosa
Pier Avenue, Hermosa Avenue,
Pier Plaza,
Lot A, Lot B
(Teardown)
Impact Level III
PENDING
7 8 Hermosa Beach
Open
North Volleyball Courts
(Set-up)
Impact Level III
9 Hermosa Beach Open
North Volleyball Courts
(Set-up)
Impact Level III
10 Hermosa Beach
Concert Series
South of Pier
(Setup)
Impact Level III
Hermosa Beach Open
North Volleyball Courts
Impact Level III
11 Hermosa Beach
Concert Series
South of Pier
(Setup)
Impact Level III
Hermosa Beach Open
North Volleyball Courts
Impact Level III
12 Movies at the Beach
South of Pier
(Utilizing Hermosa Beach
Concert Series
Infrastructure)
Impact Level III
Hermosa Beach Open
North Volleyball Courts
Impact Level III
13 Hermosa Beach Concert Series
South of Pier
Impact Level III
Hermosa Beach Open
North Volleyball Courts
Impact Level III
14 Hermosa Beach
Concert Series
South of Pier
(Event Infrastructure
Only)
Impact Level III
15 Hermosa Beach
Concert Series
South of Pier
(Event Infrastructure
Only)
Impact Level III
16 Hermosa Beach
Concert Series
South of Pier
(Event Infrastructure Only)
Impact Level III
17 Hermosa Beach
Concert Series
South of Pier
(Event Infrastructure Only)
Impact Level III
18 Hermosa Beach
Concert Series
South of Pier
(Event Infrastructure Only)
Impact Level III
19 Movies at the Beach
South of Pier
(Utilizing Hermosa Beach
Concert Series
Infrastructure)
Impact Level III
Coastal Cleanup Day
Schumacher Plaza,
North & South of Pier
Impact Level I
20 Hermosa Beach Concert Series
South of Pier
Impact Level III
21 Hermosa Beach
Concert Series
South of Pier
(Teardown)
Impact Level III
22 23 24 25 SoCal
Beach Foundation
North Volleyball Courts
(Setup)
26 SoCal
Beach Foundation
North Volleyball Courts
27 AAU High School Boys Beach
Volleyball League Matches
North Volleyball Courts
28 29 30
September 2026
Impact Level I
Impact Level II
Impact Level III
Long-term Agreement
City Hosted
City Contracted Event
Sun Mon Tue Wed Thu Fri Sat
1 2 3
AAU High School Boys Beach
Volleyball League Matches
North Volleyball Courts
4 5 6 7 8 9 10 Pumpkins in the Park
Edith Rodaway Park
Impact Level II
Walk to End Alzheimer's
Pier Plaza and Strand North of Pier
11 AAU High School Boys Beach
Volleyball League Matches
North Volleyball Courts
12 13 14 15 16 17 Volley4Sound
North Volleyball Courts
After Dark Tour LA 2026
City streets & Strand (North and
South of Pier)
PENDING
18 Skechers Pier to Pier
Friendship Walk
Strand (North of Pier) &
Pier Plaza
Impact Level III
AAU High School Boys Beach
Volleyball League Matches
North Volleyball Courts
After Dark Tour LA 2026
City streets & Strand (North and
South of Pier)
(Teardown)
PENDING
19 20 21 22 23 Beach Tennis Tournament
Beach Tennis Courts
24 IBVL Tournament Series
North Volleyball Courts
Beach Tennis Tournament
Beach Tennis Courts
After Dark Tour LA 2026
City streets & Strand (North and
South of Pier)
PENDING
25 Beach Tennis Tournament
Beach Tennis Courts
After Dark Tour LA 2026
City streets & Strand (North and
South of Pier)
(Teardown)
PENDING
26 27 28 29 30 31 AAU Southern Pacific
Grand Prix Series
North Volleyball Courts
October 2026
Impact Level I
Impact Level II
Impact Level III
Long-term Agreement
City Hosted
City Contracted Event