cover - checklists for development and review of trash

Checklists for Developing and Reviewing Track 2 Trash

Implementation Plans

Guidance

October 2018

Ad hoc Trash Implementation Plan Work Group

California Stormwater Quality Association

i

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Statewide Trash Amendments Track 2 Trash Implementation Plan Checklist

October 2018

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Introduction In 2017, the State Water Resources Control Board (State Water Board) sent out 13383 Orders to the Phase II Traditional and Non-Traditional permittees and the Regional Water Boards each (except Region 21) sent slightly different 13383 Orders to Phase 1 permittees2 specifying, among other things, the requirements for the development and submittal of Track 2 Implementation Plans, which are due to the State / Regional Water Boards between November 30, 2018 and February 18, 2019, depending on the geographic region.

To assist in the development and review of the plans and to ensure that they are consistent with the 13383 Order requirements, CASQA developed guidance in the form of Track 2 Implementation Plan Checklists for each of the Regions and Phase II Permittees (consistent with the Trash Amendments and 13383 Orders).

The checklists are intended to be tools that can be used during the development and review of the Track 2 Implementation Plans and could, if desired, be completed and submitted by the Permittees with their respective Implementation Plan. The 13383 Order requirements are indicated with italics and blue shaded boxes. Optional sections and/or general text are included as regular text and, while they may provide context for the Implementation Plan, they are not required to be submitted with the Implementation Plan pursuant to the 13383 Orders. Additionally, while CASQA identified where a 13383 Order required section may fit within the overall context of an Implementation Plan, it is recognized that a Permittee may structure their Plan differently based on local needs and/or interests.

Statewide Trash Amendments Track 2 Implementation Plan Checklists are provided as follows:

Geographic Area Permittees PDF Page

North Coast Regional Water Board (Region 1) Phase I 4 San Francisco Bay Regional Water Board (Region 2) Phase I 6 Central Coast Regional Water Board (Region 3) Phase I 7 Los Angeles Regional Water Board (Region 4) Phase I 10 Central Valley Regional Water Board (Region 5) Phase I 13 Lahontan Regional Water Board (Region 6) Phase I 15 Colorado River Regional Water Board (Region 7) Phase I 17 Santa Ana Regional Water Board (Region 8) Phase I 20 San Diego Regional Water Board (Region 9) Phase I 22 Statewide – Phase II Traditional Phase II - Traditional 25 Statewide – Phase II Non-Traditional Phase II – Non-Traditional 28

1 Region 2 Phase I permittees’ trash requirements are specified in the Municipal Regional Stormwater Permit, which covers all 76 Phase I permittees in the San Francisco Bay Region. 2 Region 4 Phase I permittees’ trash requirements are specified in the Los Angeles countywide stormwater permit, which covers all Phase I permittees in the Los Angeles Region, except those in Long Bach and Ventura county.

Region 1 – Phase I

Statewide Trash Amendments - Track 2 Implementation Plan Checklist (Due December 1, 2018)

North Coast Regional Water Quality Control Board (Region 1) - Phase I Permittees

Page 1 of 1

The checklist below was developed as a tool that can be used during the review of the Track 2 Implementation Plans and could be completed and submitted with the Implementation Plans. The requirements outlined in the 13383 Order are indicated with italics and blue shaded boxes. Optional sections and/or general text are included as regular text and, while they may provide context for the Implementation Plan, they are not required to be submitted with the Implementation Plan.

13383 Order Requirements Potential

Implementation Plan Sections

Description Included in Plan?

Location in Implementation

Plan

Certification ☐ Overview Introduction to the Track 2 Implementation Plan Not

required

Jurisdictional map(s) identifying the following: • All PLU areas discharging to

the MS4 system(s); • The corresponding MS4

network, including the location of all storm drain inlets and collection areas that receive storm water discharges from the identified PLU areas;

• Proposed locations of all certified FCS and where any combination of controls will be implemented to achieve FCSE.

• Proposed equivalent alternative land uses for PLUs, a justification demonstrating that the alternative land uses generate trash at rates that are equivalent to or greater than the PLUs for which they are being substituted.

If proposing to substitute equivalent alternative land uses for PLUs, a justification demonstrating that the alternative land uses generate trash at rates that are equivalent to or greater than the PLUs for which they are being substituted.

Priority Land Use (PLU) Maps

Updated jurisdictional maps.

☐

Full Capture System Equivalency (FCSE)

Overview of the methodology used to estimate the full capture system equivalency value. This may include:

• Development of trash generation rates; and • Calculation of FCSE value

Not required

The combination of FCS, Multi-Benefit Projects, other Treatment Controls, and/or Institutional Controls selected by the permittee and the rationale for the selection.

Combination of Controls Full Capture Systems (FCS) (Treatment Controls)

Summary of the FCS currently implemented and/or new FCS that may be implemented. This includes those systems/devices approved by the State Water Resources Control Board 1,2.

☐

Institutional Controls (Source Controls)

Summary of current and/or proposed institutional controls. This may include, but is not limited to street sweeping, sidewalk trash bins, collection of trash, anti-litter educational and outreach programs, producer take-back for packaging, and ordinances.3

☐

How the combination of controls is designed to achieve FCSE4.

FCSE Attainment

Summary of how the combination of controls is anticipated to achieve the FCSE value. ☐

How FCSE will be demonstrated5. Monitoring

Plan/Approach

A summary of the monitoring approach (e.g., on-land visual trash assessments) that demonstrates progress towards full capture system equivalency6.

☐

Annual Reporting

Overview of the annual reporting, which may include, but not be limited to GIS mapped locations and drainage area served for each of the full capture systems, multi-benefit projects, other treatment controls, and/or institutional controls installed or utilized by the MS4 permittee.7

Not required

Schedule

Summary of the implementation schedule for the compliance period [the final compliance date must not be later than fifteen (15) years from the effective date of the Trash Amendments. (i.e. December 2, 2030] and identification of the interim milestones to demonstrate progress to full implementation8.

Not required

1 https://www.waterboards.ca.gov/water_issues/programs/stormwater/docs/trash_implementation/a1_certified_fcd_rev_10aug18_.pdf 2 https://www.waterboards.ca.gov/water_issues/programs/stormwater/docs/trash_implementation/mbtscoversheet_revised_09mar18b.pdf 3 Text of the final Part 1 Trash Provisions proposed to Appendix A: Glossary of the ISWEBE Plan. Page E-10. 4 Appendix E: Final Part 1 Trash Provisions. Section 5.a.(1)A, Page E-5. 5 Appendix E: Final Part 1 Trash Provisions. Section 5.a.(1)A, Page E-5. 6 Appendix E: Final Part 1 Trash Provisions. Section 6b. Page E-8. 7 Appendix E: Final Part 1 Trash Provisions. Section 6c. Page E-8. 8 Appendix E: Final Part 1 Trash Provisions. Section 5.a.(4), Page E-6.

https://www.waterboards.ca.gov/water_issues/programs/stormwater/docs/trash_implementation/a1_certified_fcd_rev_10aug18_.pdf

https://www.waterboards.ca.gov/water_issues/programs/stormwater/docs/trash_implementation/mbtscoversheet_revised_09mar18b.pdf

Region 2 – Phase I (Not applicable; see Municipal Regional Permit)

Statewide Trash Amendments - Track 2 Implementation Plan Checklist (Due January 2, 2019)

Central Coast Regional Water Quality Control Board (Region 3)

Page 1 of 2






Plan


required

Updated jurisdictional map identifying the following: • All PLU areas and selected

locations, other than PLU areas, discharging to the MS4 network;

• The corresponding MS4 network;

• Proposed locations of all certified FCS and where any combination of controls will be implemented that will achieve FCSE.

• Trash levels, using the methodology described in Visual Trash Assessment Approach or other equivalent trash assessment methodology, for all PLUs, and for other selected locations or land uses within the MS4s’ jurisdiction if proposing to implement any combination of controls in locations other than PLUs.

Requests by the City, if any, for authorization to substitute a PLU with an Equivalent Alternate Land Use that generates rates of trash equivalent to, or greater than, the PLU being substituted. The City must provide data or information which establishes that trash generation rates from the Alternate Land Use(s) are greater than the PLUs(s) being substituted.



☐




Not required

The combination of controls selected by the City and the rationale for each selection.1



☐



☐

How the combination of controls is designed to achieve FCSE5.

FCSE Attainment


How FCSE will be demonstrated6. How the trash implementation plans will be monitored and assessed in Annual Reports.

Monitoring Plan/Approach


☐

Annual Reporting


Not required

1 Appendix E: Final Part 1 Trash Provisions. Section 5.a.(1)A, Page E-5. 2 https://www.waterboards.ca.gov/water_issues/programs/stormwater/docs/trash_implementation/a1_certified_fcd_rev_10aug18_.pdf 3 https://www.waterboards.ca.gov/water_issues/programs/stormwater/docs/trash_implementation/mbtscoversheet_revised_09mar18b.pdf 4 Text of the final Part 1 Trash Provisions proposed to Appendix A: Glossary of the ISWEBE Plan. Page E-10. 5 Appendix E: Final Part 1 Trash Provisions. Section 5.a.(1)A, Page E-5. 6 Appendix E: Final Part 1 Trash Provisions. Section 5.a.(1)A, Page E-5. 7 Appendix E: Final Part 1 Trash Provisions. Section 6b. Page E-8. 8 Appendix E: Final Part 1 Trash Provisions. Section 6c. Page E-8.



Statewide Trash Amendments - Track 2 Implementation Plan Checklist (Due January 2, 2019)

Central Coast Regional Water Quality Control Board (Region 3)

Page 2 of 2





Plan

A compliance time schedule based on the shortest practicable time to achieve full compliance with the trash discharge prohibition, including interim milestones (such as average load reductions of ten percent per year) and a final compliance date. Full compliance shall occur within ten years of the effective date of the first implementing permit and shall in no case later than fifteen years from the effective date of the Trash Provisions (i.e. no later than December 2, 2030)

Schedule


☐

Note – the 13383 Order also requires the following:

• Coordination with Caltrans. The City must submit (by January 2, 2019), a description of how it will coordinate its efforts to install, operate, and maintain FCS, multi-benefit projects, and other controls with Caltrans in significant trash generating areas and/or PLUs, as applicable.

• Transient Encampments. The City must submit (by January 2, 2019), a description of how trash generated from transient encampments will be addressed.

9 Appendix E: Final Part 1 Trash Provisions. Section 5.a.(4), Page E-6.

Region 4 – Phase I (Applicable to Long Beach and Ventura county permittees)

Statewide Trash Amendments - Track 2 Implementation Plan Checklist (Due February 18, 2019)

Los Angeles Regional Water Quality Control Board (Region 4) - Phase I Permittees

Page 1 of 2






Plan


required

A jurisdictional or watershed map(s) identifying the following: • All PLU areas and selected

locations and land uses, other than PLU areas, discharging to the storm drain network;

• Any drainage areas addressed by existing trash TMDLs;

• The corresponding storm drain network;


• Trash levels, using the methodology described in the recommended Visual Trash Assessment Approach or other equivalent trash assessment methodology, for all PLUs and for other selected locations or land uses within the MS4s jurisdiction if proposing to implement any combination of controls in locations other than PLUs.

If proposing to select locations or land uses other than PLUs, a rationale demonstrating that the alternative land uses generate trash at rates that are equivalent to or greater than the PLUs.



☐




Not required



Not required



Not required

The rationale for how the selected combination of controls will achieve FCSE4.

FCSE Attainment


The rationale for how FCSE will be demonstrated5. If using a methodology other than the recommended Visual Trash Assessment Approach to determine trash levels, a description of the methodology used and rationale of how the alternative methodology is equivalent to the recommended Visual Trash Assessment Approach.



☐

1 https://www.waterboards.ca.gov/water_issues/programs/stormwater/docs/trash_implementation/a1_certified_fcd_rev_10aug18_.pdf 2 https://www.waterboards.ca.gov/water_issues/programs/stormwater/docs/trash_implementation/mbtscoversheet_revised_09mar18b.pdf 3 Text of the final Part 1 Trash Provisions proposed to Appendix A: Glossary of the ISWEBE Plan. Page E-10. 4 Appendix E: Final Part 1 Trash Provisions. Section 5.a.(1)A, Page E-5. 5 Appendix E: Final Part 1 Trash Provisions. Section 5.a.(1)A, Page E-5. 6 Appendix E: Final Part 1 Trash Provisions. Section 6b. Page E-8.



Statewide Trash Amendments - Track 2 Implementation Plan Checklist (Due February 18, 2019)

Los Angeles Regional Water Quality Control Board (Region 4) - Phase I Permittees

Page 2 of 2





Plan

Annual Reporting


Not required

Schedule


Not required

Note –

• Permittees whose jurisdictional area is partly addressed by an existing trash TMDL(s) identified in footnote 3 (of the 13383 Order), shall address the portion of the jurisdiction that is not being addressed by the trash TMDL(s).

• A permittee or group of permittees that has already installed trash controls pursuant to Part 4.G.5.(e)(1) of the Ventura County MS4 Permit, Part VI.D.9.h.vii of the Los Angeles County MS4 Permit, or Part VII.L.8.vii of the Long Beach MS4 Permit (pertaining to “Additional Trash Management Practices”) that fulfill the requirements of Track 1 or Track 2 may provide evidentiary documentation to the Board.19 Such documentation should be equivalent to that required in Track 1 and/or Track 2, above, depending on the approach(es) employed by the permittee(s).

• Permittees selecting Track 2, and that are participating in an EWMP, are strongly encouraged to submit their Implementation Plan(s) as a proposed modification to the approved EWMP through the adaptive management process in Part VI.C.8.a.ii. of the Los Angeles County MS4 Permit. Permittees participating in an EWMP are required to implement an adaptive management process in spring 2018, and submit the results of the adaptive management process in the 2017-18 Annual Report due on December 15, 2018.

7 Appendix E: Final Part 1 Trash Provisions. Section 6c. Page E-8. 8 Appendix E: Final Part 1 Trash Provisions. Section 5.a.(4), Page E-6.


Central Valley Regional Water Quality Control Board (Region 5) - Phase I Permittees

Page 1 of 1






Plan


required

Full Capture

System Equivalency (FCSE)


• Priority Land Uses and mapping; • Development of trash generation rates; and • Calculation of FCSE value

Not required

A description of the combination of controls selected by the MS4 permittee and the rationale for the selection.1



☐



☐

The rationale for how the combination of controls is designed to achieve Full Capture System Equivalency5.

FCSE Attainment

Summary of how the combination of controls is anticipated to achieve the FCSE value.

☐

The rationale for how Full Capture System Equivalency will be demonstrated6 The example Visual Trash Assessment Approach may be useful in explaining the rationale, and in collecting, analyzing, and reporting data on trash control.


A summary of the monitoring approach (e.g., on-land visual trash assessments) that demonstrates progress towards full capture system equivalency7. ☐

Annual Reporting


Not required

Schedule8


Not required

1 Appendix E: Final Part 1 Trash Provisions. Section 5.a.(1)A, Page E-5. 2 https://www.waterboards.ca.gov/water_issues/programs/stormwater/docs/trash_implementation/a1_certified_fcd_rev_10aug18_.pdf 3 https://www.waterboards.ca.gov/water_issues/programs/stormwater/docs/trash_implementation/mbtscoversheet_revised_09mar18b.pdf 4 Text of the final Part 1 Trash Provisions proposed to Appendix A: Glossary of the ISWEBE Plan. Page E-10. 5 Appendix E: Final Part 1 Trash Provisions. Section 5.a.(1)A, Page E-5. 6 Appendix E: Final Part 1 Trash Provisions. Section 5.a.(1)A, Page E-5. 7 Appendix E: Final Part 1 Trash Provisions. Section 6b. Page E-8. 8 Appendix E: Final Part 1 Trash Provisions. Section 6c. Page E-8. 9 Appendix E: Final Part 1 Trash Provisions. Section 5.a.(4), Page E-6.




Lahontan Regional Water Quality Control Board (Region 6) - Phase I Permittees

Page 1 of 1






Plan


required



• Priority land uses and mapping; • Development of trash generation rates; or • Calculation of FCSE value

Not required

Proposed locations where any combination of control will be implemented that will achieve FCSE.



☐



☐

The rationale for how the selected combination of controls will achieve Full Capture System Equivalency4.

FCSE Attainment


☐

A description and rationale for how Full Capture System Equivalency will be demonstrated5



☐

Annual Reporting


Not required

Schedule8


Not required

1 https://www.waterboards.ca.gov/water_issues/programs/stormwater/docs/trash_implementation/a1_certified_fcd_rev_10aug18_.pdf 2 https://www.waterboards.ca.gov/water_issues/programs/stormwater/docs/trash_implementation/mbtscoversheet_revised_09mar18b.pdf 3 Text of the final Part 1 Trash Provisions proposed to Appendix A: Glossary of the ISWEBE Plan. Page E-10. 4 Appendix E: Final Part 1 Trash Provisions. Section 5.a.(1)A, Page E-5. 5 Appendix E: Final Part 1 Trash Provisions. Section 5.a.(1)A, Page E-5. 6 Appendix E: Final Part 1 Trash Provisions. Section 6b. Page E-8. 7 Appendix E: Final Part 1 Trash Provisions. Section 6c. Page E-8. 8 Appendix E: Final Part 1 Trash Provisions. Section 5.a.(4), Page E-6.




Colorado River Basin Regional Water Quality Control Board (Region 7) - Phase I Permittees

Page 1 of 2






Plan


required

Updated jurisdictional map(s) identifying the following: • All PLU areas and selected

locations and land uses, other than PLU areas, discharging to the MS4 network;







☐




Not required



Not required



Not required


FCSE Attainment


The rationale for how FCSE will be demonstrated5. If using a methodology other than the recommended Visual Trash Assessment Approach to determine trash levels, a description of the methodology used and rationale of how the alternative methodology is equivalent to the recommended Visual Trash Assessment Approach.



☐





Colorado River Basin Regional Water Quality Control Board (Region 7) - Phase I Permittees

Page 2 of 2





Plan

Annual Reporting


Not required

Schedule


Not required

Note –

• The requirements above are for Permittees with regulatory authority over PLUs

• For those Permittees without regulatory authority over PLUs (Riverside County Flood Control and Water Conservation District and Coachella Valley Water District), submit a report identifying land uses or locations within its jurisdiction or control including, but not limited to, stormwater channels, washes, drainage structures, and catch basins, description of programs implemented by the Permittee to control trash, and estimates of approximate trash levels at these locations.


Statewide Trash Amendments - Track 2 Implementation Plan Checklist (Due November 30, 2018)

Santa Ana Regional Water Quality Control Board (Region 8) - Phase I Permittees

Page 1 of 1






Plan


required

If proposing to select locations or land uses other than Priority Land Uses, a justification demonstrating that the alternative land uses generate trash at rates that are equivalent to or greater than the Priority Land Uses.



• Priority land uses and mapping; • Development of trash generation rates; or • Calculation of FCSE value

Only required if proposing alternative locations

☐

The combination of controls selected and the rationale for the selection.1



☐



☐

How the combination of controls is designed to achieve Full Capture System Equivalency5.

FCSE Attainment


☐

How Full Capture System Equivalency will be demonstrated6 If using a methodology other than the recommended Visual Trash Assessment Approach to determine trash levels, a description of the methodology used.



☐

Annual Reporting


Not required

Schedule8


Not required





San Diego Regional Water Quality Control Board (Region 9) - Phase I Permittees

Page 1 of 2






Plan


required

Full Capture

System Equivalency (FCSE)


• Priority Land Uses and mapping; • Development of trash generation rates; and • Calculation of FCSE value

Not required

The combination of controls selected by the MS4 permittee and the rationale for each selection.1



☐



☐

How the combination of controls is designed to achieve Full Capture System Equivalency5. Proposals by MS4 permittees, if any, to substitute PLUs with other locations or land uses, provided that the total trash generated in other locations or land uses is equivalent to, or greater then, the total trash generated in the PLU being substituted.

FCSE Attainment


☐

How Full Capture System Equivalency will be demonstrated6 How the implemented controls identified in the trash implementation plans will be monitored and assessed in jurisdictional runoff management program or Water Quality Improvement Plan Annual Reports.



☐

Annual Reporting


Not required

A time schedule to achieve full compliance with the trash discharge prohibition, including interim milestones (such as average load reductions of ten percent per year or other progress) to full implementation. The proposed final compliance date must not be later than fifteen years from the effective date of the Trash Amendments (i.e. December 2, 2030).

Schedule8


☐

Note – the 13383 Order also requires the following:

• Identification of Substantial Trash Generating Land Uses or Locations Within Riverside County Flood Control and Water Conservation District’s Jurisdiction. Submit a report identifying land uses or locations within its jurisdiction or control including, but not limited to, facilities, drainage structures, and easements that generate a substantial amount of trash.





San Diego Regional Water Quality Control Board (Region 9) - Phase I Permittees

Page 2 of 2

• Coordination with Caltrans. Each MS4 permittee must submit (by December 3, 2018), a description of how MS4 Permittees will coordinate their efforts to install, operate, and maintain FCS, multi-benefit projects, and other controls with Caltrans in significant trash generating areas and/or PLUs, as applicable.

Statewide – Phase II Traditional


State Water Resources Control Board (Statewide) - Phase II Permittees (Traditional)

Page 1 of 2






Plan


required

Updated jurisdictional map(s) identifying the following: • All PLU areas and selected

locations and land uses, other than PLU areas, discharging to the storm drain network;

• The corresponding storm drain network;






☐




Not required



Not required



Not required


FCSE Attainment


The rationale for how FCSE will be demonstrated5. If using a methodology other than the on-land Visual Trash Assessment Approach to determine trash levels, a description of the methodology used and rationale of how the alternative methodology is equivalent to the recommended Visual Trash Assessment Approach.



☐





State Water Resources Control Board (Statewide) - Phase II Permittees (Traditional)

Page 2 of 2





Plan

Annual Reporting


Not required

Schedule


Not required


Statewide – Phase II Non-Traditional


State Water Resources Control Board (Statewide) - Phase II Permittees (Non-Traditional)

Page 1 of 2






Plan


required

Updated jurisdictional map(s) identifying the following: • All land uses and locations

discharging substantial amounts of trash to the MS4 network;



• Trash levels, using the methodology described in the recommended Visual Trash Assessment Approach or other equivalent trash assessment methodology, for all land uses and locations discharging substantial amounts of trash to the MS4 network.

Jurisdictional Maps


☐




Not required



Not required



Not required


FCSE Attainment


The rationale for how FCSE will be demonstrated5. If using a methodology other than the recommended Visual Trash Assessment Approach to determine (1) land uses and locations that discharge substantial amounts of trash, and (2) trash levels, a description of the methodology used and rationale of how the alternative methodology is equivalent to the recommended Visual Trash Assessment Approach.



☐

Annual Reporting


Not required

1 https://www.waterboards.ca.gov/water_issues/programs/stormwater/docs/trash_implementation/a1_certified_fcd_rev_10aug18_.pdf 2 https://www.waterboards.ca.gov/water_issues/programs/stormwater/docs/trash_implementation/mbtscoversheet_revised_09mar18b.pdf 3 Text of the final Part 1 Trash Provisions proposed to Appendix A: Glossary of the ISWEBE Plan. Page E-10. 4 Appendix E: Final Part 1 Trash Provisions. Section 5.a.(1)A, Page E-5. 5 Appendix E: Final Part 1 Trash Provisions. Section 5.a.(1)A, Page E-5. 6 Appendix E: Final Part 1 Trash Provisions. Section 6b. Page E-8. 7 Appendix E: Final Part 1 Trash Provisions. Section 6c. Page E-8.




State Water Resources Control Board (Statewide) - Phase II Permittees (Non-Traditional)

Page 2 of 2





Plan

Schedule


Not required

8 Appendix E: Final Part 1 Trash Provisions. Section 5.a.(4), Page E-6.

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