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9A LEAGUE, CSAC AND RCRC SUBMIT LETTER TO WATER BOARD ON NUMERIC LIMITS Page 4 Earlier this week, the League. the California rate capacity of the BMP. Stormwater aaencles State Association of Counties (CSAC) and the should not be held accountable for Dol/utant Regional Council of Rural Counties (RCRC) removal from storms bevond the size for submitted a joint comment to the State Water which a BMP Is deslaned." (Paae 10) [Empha- Resources Control Board on the recently released sis added] report on how to proceed with the findings of the Storm Water Panel of Experts {Panel} regarding "Monitoring for the enforcement of nu- the feasibility of establishing numeric effluent limits meric effluent limits would also be challenging. in storm water monitoring. The joint letter in- While spot checks could be made at some of the eluded, among other statements, the following many outtalls in an areas, there is wide variation comments: in storm water quality from place to place, facility to facility, and storm to storm." (Page 6) 1. The Board should adopt a policy which directs staff and regional boards not to set nu- As MS4 permit holders, we are concerned meric effluent limits for municipal best manage- that many local governments will be expected to men! practices (BMPs). enforce numeric effluent limits if the Water Board implements them as statewide policy. Currently, We support the panel's overall finding that it is municipal permittees are responsible for monitor- not feasible at this time to set enforceable numeric ing, inspecting, and enforcement of industrial and effluent criteria for municipal BMPs. We would ask construction facilities that discharge to MS4s. that the Water Board adopt a policy directing staff While it is reasonable and plausible for municipali- and the regional boards to refrain from setting ties to enforce BMP requirements, the prospect of numeric effluent limits for municipal discharges enforcing numeric effluent limit requirements is until additional monitoring and research enables complex, uncertain, and even if possible, will the Water Board to adopt additional policy on the greatly increase our program costs. Any such application of numeric effluent criteria to municipal cost increases will constitute an unfunded man- BMPs. date, and must be addressed by the Water Board before making any statewide policy decisions on 2. If numeric effluent limits are implemented in the use of numeric effluent limits." future permits, the Water Board must address the enforcement role of local agencies and subse- The Water Board is accepting comments until quent costs. We agree with the observations of the September 1. A copy of the League-CSAC- panel regarding the ability of municipal agencies to RCRC letter is posted on the League's website on =:.~.:::m~: ::4~:~::a:: any ;.,[~~J_~\~;~~,~1it~~~~i~j;!i outfall can be high, it may be unreasonable to ... . ..... "?i,:.... ..... ........... expect all events to be below a numeric value. In a similar circumstance, there are a number of storms each year that are sufficiently large in volume and/or intensity, to exceed the design capacity volume or flow rates of most BMPs. (Page 6) The panel acknowledged that several to more times each year, the runoff volume or flow rate from a storm will exceed the design volume or ..,..,..".----.....,.-..,.....,.-.-.:..-,..;., ;':-.:-' '......::..:..-..'.....:',.,'. ....:..,..,......',.-...,...........".,.,......-.,..,.-... "-'"..--.,".-.-' .,......... .....i.:.n.... ... .... PAGE 4 . PRIORITY FOCUS Visit the League's Official Website-www.cacities.org August 4, 2006 . Issue #31