HomeMy WebLinkAbout06-08-2021 - Agenda Pkg - CC Regular MeetingTuesday, June 8, 2021
5:00 PM
City of Hermosa Beach
City Hall
1315 Valley Drive
Hermosa Beach, CA 90254
City Council
Mayor
Justin Massey
Mayor Pro Tem
Michael Detoy
Councilmembers
Stacey Armato
Mary Campbell
Raymond Jackson
Regular Meeting Agenda
Closed Session - 5:00 PM
Regular Meeting - 6:00 PM
Duly Posted on June 3, 2021 at 8:30 p.m. by E.S.
Executive Team
Eduardo Sarmiento, City Clerk
Viki Copeland, Finance Director
Marnell Gibson, Public Works Director
Paul LeBaron, Chief of Police
Angela Crespi, Deputy City Manager
Ken Robertson, Community Development Director
Vanessa Godinez, Human Resources Manager
John Jones, Interim Community Resources Manager
City Treasurer
Karen Nowicki
City Attorney
Michael Jenkins
Suja Lowenthal, City Manager
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June 8, 2021City Council Regular Meeting Agenda
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June 8, 2021City Council Regular Meeting Agenda
5:00 P.M. - CLOSED SESSION
CALL TO ORDER
ROLL CALL
PUBLIC COMMENT ON THE CLOSED SESSION AGENDA
JOIN THE VIRTUAL MEETING AT:
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ATTENDEES WILL BE MUTED UNTIL THE PUBLIC PARTICIPATION PERIOD IS OPENED.
If you are joining by phone, press * 6 to unmute your line. Comments from the public are
limited to 3 minutes per speaker.
RECESS TO CLOSED SESSION
a.21-0330 MINUTES: Approval of minutes of Closed Session held on May 25, 2021.
b.21-0331 CONFERENCE WITH LEGAL COUNSEL: Existing Litigation
Government Code Section 54956.9(d)(1)
The City finds, based on advice from legal counsel, that discussion in open
session will prejudice the position of the City in the litigation.
Donna Bauer v. Hermosa Beach, et al. Los Angeles County
Superior Court Case No. 19 STCV 32667
ADJOURNMENT OF CLOSED SESSION
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June 8, 2021City Council Regular Meeting Agenda
6:00 P.M. - REGULAR AGENDA
PUBLIC COMMENT
City Hall will be closed to the public until further notice. Virtual Meetings are held pursuant to Executive
Order N-29-20 issued by Governor Gavin Newsom on March 17, 2020. Members of the public may
email comments to Esarmiento@hermosabeach.gov or submit eComments until 3:00 p.m. on the
meeting date. Members of the public may also participate by phone.
JOIN THE VIRTUAL MEETING AT:
https://us02web.zoom.us/j/87032785286?pwd=RGVVZnduNGVIVGJLOFlvaFNuYTBlUT09
OR PARTICIPATE BY PHONE:
•Toll Free: 877-853-5257
•Meeting ID: 870 3278 5286
•Participant ID: 513185
ATTENDEES WILL BE MUTED UNTIL THE PUBLIC PARTICIPATION PERIOD IS OPENED.
If you are joining by phone, press * 6 to unmute your line. Comments from the public are
limited to 3 minutes per speaker.
Oral and Written Communication
Persons who wish to have written materials included in the agenda packet at the time the agenda is
published on the City's website must submit the written materials to the City Manager's office by email
(esarmiento@hermosabeach.gov) or in person by noon of the Tuesday, one week before the meeting
date.
Written materials pertaining to matters listed on the posted agenda received after the agenda has been
posted will be added as supplemental materials under the relevant agenda item on the City's website at
the same time as they are distributed to the City Council by email. Supplemental materials may be
submitted via eComment (instructions below) or emailed to esarmiento@hermosabeach.gov.
Supplemental materials must be received before 4:00 p.m. on the date of the meeting to ensure
Council and staff have the ability to review materials prior to the meeting. Supplemental materials
submitted after 4:00 p.m. on the date of the meeting or submitted during the meeting will be posted
online the next day.
Submit Supplemental eComments in three easy steps:
Note: Your comments will become part of the official meeting record. You must provide your full name,
but please do not provide any other personal information (i.e. phone numbers, addresses, etc) that you
do not want to be published.
1. Go to the Agendas/Minutes/Video webpage and find the meeting you’d like to submit comments on.
Click on the eComment button for your selected meeting.
2. Find the agenda item for which you would like to provide a comment. You can select a specific
agenda item/project or provide general comments under the Oral/Written Communications item.
3. Sign in to your SpeakUp Hermosa Account or as a guest, enter your comment in the field provided,
provide your name, and if applicable, attach files before submitting your comment.
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June 8, 2021City Council Regular Meeting Agenda
I. CALL TO ORDER
II. PLEDGE OF ALLEGIANCE
III. ROLL CALL
IV. CLOSED SESSION REPORT
V. ANNOUNCEMENTS - UPCOMING CITY EVENTS
VI. APPROVAL OF AGENDA:This is the time for the City Council to change the order
in which it takes up items on this agenda, remove and/or continue agenda items and
pull items from the consent calendar for separate consideration.
VII. PROCLAMATIONS / PRESENTATIONS
a.21-0332 COVID-19 HEALTH UPDATE FROM
BEACH CITIES HEALTH DISTRICT
VIII. CITY MANAGER REPORT - The City Manager and staff may provide brief reports
on pending City business. Longer oral reports to be provided are as follows:
a.21-0334 COVID-19 UPDATE
City Managers Comments for 6-8-21Attachments:
b.21-0335 INFORMATION ITEM: UPDATE OF ENHANCED
WATERSHED MANAGEMENT PLAN (EWMP)
Link to Info Items WebpageAttachments:
c.21-0336 UPDATE FROM CHIEF LEBARON ON
ENFORCEMENT MEASURES
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June 8, 2021City Council Regular Meeting Agenda
IX. PUBLIC PARTICIPATION -- ORAL AND WRITTEN COMMUNICATIONS FROM THE
PUBLIC: This is the time for members of the public to address the City Council on
any items within the Council's jurisdiction not on this agenda, on items on this
agenda as to which public comment will not be taken (City Manager Reports, City
Councilmember Reports Consent Calendar items that are not pulled for separate
consideration and Future Agenda Items), on written communications, and to request
the removal of an item from the consent calendar. Public comments on the agenda
items called City Manager Reports, City Councilmembers Reports, Consent Calendar
items that are not pulled for separate consideration and Future Agenda Items will
only be heard at this time. Further, comments on public hearing items are heard only
during the public hearing. Members of the audience may also speak during
discussion of items removed from the Consent Calendar for separate consideration;
during Public Hearings; and, during discussion of items appearing under Municipal
Matters.
All comments from the public under this agenda item are limited to three minutes per
speaker, but this time allotment may be reduced due to time constraints. The City
Council acknowledges receipt of the written communications listed below. No action
will be taken on matters raised in oral and written communications, except that the
Council may take action to schedule issues raised in oral and written
communications for a future agenda. Speakers with comments regarding City
management or departmental operations are encouraged to submit those comments
directly to the City Manager.
a.21-0329 WRITTEN COMMUNICATION
Recommendation:Staff recommends City Council receive and file the written communication.
1. WRITTEN COMMUNICATION from Tony Higgins (Submitted 5-24-21
at 5.16 p.m.)
2. WRITTEN COMMUNICATION from Matt McCool (Submitted 6-1-21 at
11.55 a.m.)
Attachments:
X. CITY COUNCILMEMBER COMMENTS: Councilmembers may briefly respond to
public comments, may ask a question for clarification or make a brief announcement
or report on his or her own activities or meetings attended.
a.21-0337 UPDATES FROM CITY COUNCIL AD HOC SUBCOMMITTEES
AND STANDING COMMITTEE DELEGATES/ALTERNATES
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June 8, 2021City Council Regular Meeting Agenda
XI. CONSENT CALENDAR: The following matters will be acted upon collectively with
a single motion and vote to approve with the majority consent of the City Council.
Councilmembers may orally register a negative vote on any consent calendar item
without pulling the item for separate consideration prior to the vote on the consent
calendar. There will be no separate discussion of these items unless a Council
member removes an item from the Consent Calendar, either under Approval of the
Agenda or under this item prior to the vote on the consent calendar. Items removed
will be considered under Agenda Item XII (12), with public comment permitted at that
time. The title is deemed to be read and further reading waived of any ordinance
listed on the consent calendar for introduction or adoption.
a.REPORT
21-0338
CITY COUNCIL MEETING MINUTES
(City Clerk Eduardo Sarmiento)
Recommendation:Staff recommends City Council approve the following minutes:
1. May 25, 2021 Regular City Council Meeting
05-25-21 Regular City Council Mtg. MinutesAttachments:
b.REPORT
21-0343
CHECK REGISTERS
(Finance Director Viki Copeland)
Recommendation:Staff recommends City Council ratify the following check registers.
1. 5-13-21
2. 5-20-21
Attachments:
c.REPORT
21-0344
ACTION MINUTES OF THE PARKS, RECREATION AND
COMMUNITY RESOURCES ADVISORY COMMISSION
MEETING OF MAY 4, 2021
(Interim Community Resources Manager John Jones)
Recommendation:Staff recommends City Council receive and file the action minutes of the Parks,
Recreation and Community Resources Advisory Commission meeting of May 4, 2021.
Minutes of May 4, 2021Attachments:
d.REPORT
21-0346
LOS ANGELES COUNTY FIRE SERVICES AND AMBULANCE
MONTHLY REPORT FOR APRIL 2021
(Emergency Management Coordinator Brandy Villanueva)
Recommendation:Staff recommends City Council receive and file the April 2021 Fire and Ambulance
monthly report.
Fire and ambulance monthly report_April 2021Attachments:
e.REPORT
21-0326
APPROVAL OF A SPECIAL EVENT LONG-TERM AGREEMENT
WITH THE ARTS GROUP OF HERMOSA BEACH TO PROVIDE
THE FINE ARTS FESTIVAL TO BE HELD ON
THE COMMUNITY CENTER LAWN
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June 8, 2021City Council Regular Meeting Agenda
(Interim Community Resources Manager John Jones)
Recommendation:Staff recommends City Council:
1. Approve a special event long-term agreement with the Arts Group of Hermosa Beach
to provide the Fine Arts Festival; and
2. Authorize the Mayor and the City Clerk to execute the agreement, subject to approval
by the City Attorney (Attachment 1).
Agreement between the City of Hermosa Beach and Arts Group of
Hermosa Beach to Provide the Fine Arts Festival
Attachments:
f.REPORT
21-0341
APPROVAL OF THE PARKS, RECREATION AND COMMUNITY
RESOURCES ADVISORY COMMISSION’S RECOMMENDATION
TO APPROVE THE FIRST AMENDMENT TO AGREEMENT FOR USE
OF THE HERMOSA BEACH COMMUNITY CENTER GYMNASIUM
BETWEEN THE CITY OF HERMOSA BEACH AND THE HERMOSA
BEACH YOUTH BASKETBALL LEAGUE
(Recreation Coordinator Nick Shattuck)
Recommendation:Staff recommends City Council:
1. Approve the Parks, Recreation and Community Resources Advisory Commission
recommendation to approve the first amendment to an Agreement for Use of the Hermosa
Beach Community Center Gymnasium between the City of Hermosa Beach and the
Hermosa Beach Youth Basketball League to allow temporary use of the Kelly Basketball
Courts for games during the 2021 Summer Season; and
2. Authorize the City Manager to execute and the City Clerk to attest the attached first
amendment subject to approval by the City Attorney (Attachment 3).
1. HBYB Agreement
2. HBYB Summer Season Proposal
3. First Amendment to Agreement HBYB Agreement
Attachments:
g.REPORT
21-0340
HERMOSA BEACH LANDSCAPING AND STREET LIGHTING
DISTRICT 2021-2022 ADOPTION OF RESOLUTIONS REGARDING
THE ENGINEER’S REPORT AND SETTING JULY 13, 2021
FOR A PUBLIC HEARING
(Interim Public Works Director Angela Crespi)
Recommendation:Staff recommends City Council:
1. Adopt the attached Resolution approving the Engineer's Report in connection with
Hermosa Beach Landscaping and Street Lighting District 2021-2022 (District) made
pursuant to the requirements of Resolution No. 21-7278; and
2. Adopt the attached Resolution declaring the City's intention to order certain
improvements and to levy and collect assessments within the Hermosa Beach
Landscaping and Street Lighting District 2021-2022 for the Fiscal Year beginning July 1,
2021 through June 30, 2022, and appointing July 13, 2021, at the hour of 6:30 p.m. in the
Civic Center Council Chambers as the time and place for a public hearing in relation
thereto.
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June 8, 2021City Council Regular Meeting Agenda
1. Resolution approving Engineer Report In Connection to HB
Landscaping & Lighting
2. Resolution declaring the City’s intention to order certain improvements
and to levy and collect assessments within the Hermosa Beach
Landscaping and Street Lighting District 2021–2022 for the Fiscal Year
beginning July 1, 2021 through June 30, 2022, an
Attachments:
h.REPORT
21-0342
APPROVAL OF THE SUPPLEMENTAL LAW ENFORCEMENT
SERVICES AGREEMENT BY AND BETWEEN COUNTY OF LOS
ANGELES AND CITY OF HERMOSA BEACH
(Police Chief Paul LeBaron)
Recommendation:Staff recommends City Council
1. Approve the Supplemental Law Enforcement Services Agreement by and between
County of Los Angeles and City of Hermosa Beach; and
2. Authorize the City Manager to execute and the City Clerk to attest the attached
agreement subject to approval by the City Attorney (Attachment 1).
Hermosa Beach SLESA 2021-2026Attachments:
XII. ITEMS REMOVED FROM THE CONSENT CALENDAR FOR SEPARATE
DISCUSSION - Items pulled from the Consent Calendar will be handled separately.
Public comment will be taken prior to Council deliberation and action on each item
pulled from the Consent Calendar.
XIII. PUBLIC HEARINGS - TO COMMENCE AT 6:30 P.M.
NONE
XIV. MUNICIPAL MATTERS
a.REPORT
21-0339
VACANCIES-PARKS, RECREATION AND COMMUNITY
RESOURCES ADVISORY COMMISSION TERM
EXPIRATIONS-SCHEDULE APPLICANT INTERVIEWS
(City Clerk Eduardo Sarmiento)
Recommendation:Staff recommends City Council schedule interviews for Tuesday, July 13, 2021 at 4:00
p.m., to interview Parks, Recreation and Community Resources Advisory Commission
applicants for the three terms due to expire June 30, 2021.
1. Jani Lange Application
2. Lauren Pizer Mains Application
3. E. Thomas Moroney Application 2021
4. Isabel Rodriguez Application
5. Tara McNamara Stabile Application
Attachments:
b.REPORT
21-0345
APPROVAL OF THE REVISED ENHANCED WATERSHED
MANAGEMENT PROGRAM AND REASONABLE ASSURANCE
ANALYSIS FOR THE BEACH CITIES WATERSHED
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June 8, 2021City Council Regular Meeting Agenda
MANAGEMENT GROUP
(Environmental Programs Manager Douglas Krauss)
Recommendation:Staff recommends City Council approve the Revised Enhanced Watershed Management
Program (EWMP) and Reasonable Assurance Analysis (RAA) for the Beach Cities
Watershed Management Group.
1. 2013 MOU for Development of EWMP and CIMP
2. Current EWMP
3. Draft Updated EWMP
4. SUPPLEMENTAL attachment Amendment to MOU Dissolution
Agreement (Submitted 6-8-21 at 1.46 p.m.)
Attachments:
c.REPORT
21-0296
APPROVAL OF SECOND AMENDMENT TO AGREEMENT FOR
JANITORIAL MAINTENANCE SERVICES WITH COMMERCIAL
BUILDING MAINTENANCE (FORMERLY GOLDEN TOUCH
CLEANING, INC.)
(Interim Public Works Director Angela Crespi)
Recommendation:Staff recommends City Council:
1. Approve the proposed second amendment to an agreement with Commercial Building
Maintenance for janitorial maintenance services to extend the contract by one year,
through June 30, 2022, and to increase the total amount of the agreement by $133,890
for services during the extended contract year, resulting in a total amended contact term
of five years and a total amended contract amount of $590,619; and
2. Authorize the Mayor to execute and the City Clerk to attest the attached second
amendment subject to approval by the City Attorney (Attachment 2).
1. Agreement for Janitorial Maintenance Services Agreement with
Commercial Building Maintenance
2. Proposed Second Amendment to Commercial Building Maintenance
3. Proposal from Commercial Building Maintenance Proposal for FY
2021-22 Services
Attachments:
d.REPORT
21-0297
APPROVAL OF FIRST AMENDMENT TO AGREEMENT FOR
SANITARY SEWER HYDRO-FLUSHING AND VIDEO INSPECTION
MAINTENANCE SERVICES WITH EMPIRE PIPE CLEANING &
EQUIPMENT, INC.
(Interim Public Works Director Angela Crespi)
Recommendation:Staff recommends City Council:
1. Approve the proposed first amendment to an agreement with Empire Pipe Cleaning &
Equipment, Inc. for sanitary sewer hydro-flushing and video inspection maintenance
services to extend the contract by one year, through June 30, 2022, and to maintain the
annual amount of $160,310 for fixed services during the extended contract year, resulting
in a total amended contract term of four years and total amended contract amount of
$637,020; and
2. Authorize the Mayor to execute and the City Clerk to attest the attached first
amendment subject to approval by the City Attorney (Attachment 2).
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June 8, 2021City Council Regular Meeting Agenda
1. Agreement for Sanitary Sewer Hydro-Flushing and Video Inspection
Maintenance Services with Empire Pipe Cleaning and & Equipment, Inc.
2. Proposed First Amendment to Empire Pipe Cleaning and &
Equipment, Inc. Agreement
3. Letter Dated February 22, 2021 from Empire Pipe Cleaning and &
Equipment, Inc.
Attachments:
e.REPORT
21-0350
UPDATE TO COMMERCIAL AND RESIDENTIAL EVICTION
MORATORIUMS
(City Attorney Michael Jenkins)
(Assistant City Attorney Monica Castillo)
Recommendation:Staff recommends City Council:
1. Option 1:
a. Allow the Commercial Eviction Moratorium to sunset on June 30, 2021;
b. Take no action to readopt a Residential Eviction Moratorium;
c. Extend the requirement that residential landlords obtain building permits before evicting
tenants to demolish or substantially remodel property; and
d. Aggressively promote the state rental assistance program on the City's website and
other local media.
2. Option 2:
a. Allow the Commercial Eviction Moratorium to sunset on June 30, 2021;
b. Adopt a new Residential Eviction Moratorium, effective July 1, 2021, with amendments
to reflect current economic, regulatory, and public health climate;
c. Extend the requirement that residential landlords obtain building permits before evicting
tenants to demolish or substantially remodel property;
d. Consider extending the requirement that commercial landlords obtain building permits
before evicting tenants to demolish or substantially remodel property; and
e. Aggressively promote the state rental assistance program on the City's website and
other local media.
3. Option 3:
a. Provide other direction to staff.
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June 8, 2021City Council Regular Meeting Agenda
1. Table of Covid-19 Related Items
2. SUPPLEMENTAL Ecomment from David Grethen (Submitted 6-4-21
at 8.27 a.m.)
3. SUPPLEMENTAL Ecomment from Eric Jones (Submitted 6-4-21 at
4.33 p.m.)
4. SUPPLEMENTAL Email from Karynne Thim (Submitted 6-7-21 at 4.15
p.m.)
5. SUPPLEMENTAL Email from Bill Morris (Submitted 6-7-21 at 6.01
p.m.)
6. SUPPLEMENTAL Email from Alya Lucas (Submitted 6-7-21 at 7.36
p.m.)
7. SUPPLEMENTAL Email from James Pousson (Submitted 6-7-21 at
7.33 p.m.)
8. SUPPLEMENTAL Email from Dan Inskeep (Submitted 6-7-21 at 10.55
p.m.)
9. SUPPLEMENTAL Email from Fred Nichols (Submitted 6-8-21 at 3.40
p.m.)
10. SUPPLEMENTAL Email from Don & Joann (Submitted 6-8-21 at
3.59 p.m.)
Attachments:
XV. FUTURE AGENDA ITEMS - Requests from Councilmembers for possible future
agenda items and questions from Councilmembers regarding the status of future
agenda items. No discussion or debate of these requests shall be undertaken; the
sole action is whether to schedule the item for consideration on a future agenda. No
public comment will be taken. Councilmembers should consider the city's work plan
when considering new items. The existing list of future agenda items below is for
information only.
a.21-0351 MAYOR MASSEY REQUESTS THE CITY COUNCIL DIRECT STAFF
TO PLACE ON THE CITY COUNCIL’S NEXT REGULAR SESSION
AGENDA A LETTER OF SUPPORT FOR THE HERMOSA BEACH
CITY SCHOOL DISTRICT’S EFFORTS TO IMPLEMENT ITS EQUITY
AND INCLUSION GOALS
b.21-0347 TENTATIVE FUTURE AGENDA ITEMS
Tentative Future Agenda.pdfAttachments:
XVI. ADJOURNMENT
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June 8, 2021City Council Regular Meeting Agenda
FUTURE MEETINGS AND CITY HOLIDAYS
CITY COUNCIL MEETINGS:
June 22, 2021 - Tuesday - 5:00 PM - Closed Session,
6:00 PM - City Council Meeting
July 13, 2021 - Tuesday - 5:00 PM - Closed Session,
6:00 PM - City Council Meeting
July 22, 2021 - Thursday - Adjourned Regular Meeting:
6:00 PM - Joint Meeting with all Boards/Commissions
July 27, 2021 - Tuesday - 5:00 PM - Closed Session,
6:00 PM - City Council Meeting
August 10, 2021 - Tuesday - 5:00 PM - Closed Session,
6:00 PM - City Council Meeting
August 24, 2021 - Tuesday - No Meeting (Dark)
September 14, 2021 - Tuesday - 5:00 PM - Closed Session,
6:00 PM - City Council Meeting
September 28, 2021 - Tuesday - 5:00 PM - Closed Session,
6:00 PM - City Council Meeting
October 12, 2021 - Tuesday - 5:00 PM - Closed Session,
6:00 PM - City Council Meeting
October 23, 2021 - Saturday - Adjourned Regular Meeting:
9:00 AM - City Council Retreat
October 26, 2021 - Tuesday - 5:00 PM - Closed Session,
6:00 PM - City Council Meeting
November 9, 2021 - Tuesday - 5:00 PM - Closed Session,
6:00 PM - City Council Meeting (Mayor Transition)
November 23, 2021 - Tuesday - 5:00 PM - Closed Session,
6:00 PM - City Council Meeting
December 14, 2021 - Tuesday - 5:00 PM - Closed Session,
6:00 PM - City Council Meeting
December 28, 2020 - Tuesday - No Meeting (Dark)
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June 8, 2021City Council Regular Meeting Agenda
BOARDS, COMMISSIONS AND COMMITTEE MEETINGS:
June 15, 2021 - Tuesday - 6:00 PM - Planning Commission Meeting
July 6, 2021 - Tuesday - 7:00 PM - Parks and Recreation Advisory Commission Meeting
July 12, 2021 - Monday - 6:00 PM - Economic Development Committee Meeting
July 21, 2021 - Wednesday - 6:00 PM - Public Works Commission Meeting
July 20, 2021 - Tuesday - 6:00 PM - Planning Commission Meeting
August 2, 2021 - Monday - 6:00 PM - Economic Development Committee Meeting
August 3, 2021 - Tuesday - 7:00 PM - Parks and Recreation Advisory Commission Meeting
August 17, 2021 - Tuesday - 6:00 PM - Planning Commission Meeting
September 9, 2021 - Thursday - 7:00 PM - Parks and Recreation Advisory Commission Meeting
September 13, 2021 - Monday - 6:00 PM - Economic Development Committee Meeting
September 21, 2021 - Tuesday - 6:00 PM - Planning Commission Meeting
September 15, 2021 - Wednesday - 6:00 PM - Public Works Commission Meeting
October 4, 2021 - Monday - 6:00 PM - Economic Development Committee Meeting
October 5, 2021 - Tuesday - 7:00 PM - Parks and Recreation Advisory Commission Meeting
October 19, 2021 - Tuesday - 6:00 PM - Planning Commission Meeting
November 1, 2021 - Monday - 6:00 PM - Economic Development Committee Meeting
November 2, 2021 - Tuesday - 7:00 PM - Parks and Recreation Advisory Commission Meeting
November 16, 2021 - Tuesday - 6:00 PM - Planning Commission Meeting
November 17, 2021 - Wednesday - 6:00 PM - Public Works Commission Meeting
December 6, 2021 - Monday - 6:00 PM - Economic Development Committee Meeting
December 7, 2021 - Tuesday - 7:00 PM - Parks and Recreation Advisory Commission Meeting
December 13, 2021 - Monday - 6:00 PM - Planning Commission Meeting
CITY OFFICES CLOSED FRIDAY-SUNDAY AND ON THE FOLLOWING DAYS:
May 31, 2021 - Monday - Memorial Day
July 5, 2021 - Monday - Independence Day Observed
September 6, 2021 - Monday - Labor Day
November 11, 2021 - Thursday - Veteran's Day
November 25, 2021 - Thursday - Thanksgiving Day
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City of Hermosa Beach
Staff Report
City Hall
1315 Valley Drive
Hermosa Beach, CA 90254
Staff Report
21-0332
Honorable Mayor and Members of the Hermosa Beach City Council
Regular Meeting of June 8, 2021
COVID-19 HEALTH UPDATE FROM
BEACH CITIES HEALTH DISTRICT
City of Hermosa Beach Printed on 6/3/2021Page 1 of 1
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City of Hermosa Beach
Staff Report
City Hall
1315 Valley Drive
Hermosa Beach, CA 90254
Staff Report
21-0334
Honorable Mayor and Members of the Hermosa Beach City Council
Regular Meeting of June 8, 2021
COVID-19 UPDATE
City of Hermosa Beach Printed on 6/3/2021Page 1 of 1
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City Manager COVID-19 Update
June 8, 2021
Please note that the statement delivered during the City Council Meeting may vary due to
frequent changes in COVID-19 information and restrictions.
Vaccine Update
In partnership with Los Angeles County Department of Public Health, the City of Hermosa Beach
hosted two pop-up COVID-19 vaccination clinics in Downtown Hermosa Beach over the Memorial
Day weekend and administered Pfizer vaccines to 22 people. The City plans to host additional
vaccine opportunities later this summer.
Everyone age 12 and older in California are now eligible for COVID-19 vaccines. Appointments
for vaccines can be made by visiting myturn.ca.gov. The consent of a parent or legal guardian
may be needed for those between the ages of 12 and 17 to receive a vaccination. Please
visit Vaccinate All 58 to learn more about the safe and effective vaccines available.
City Hall In-person Services
We wanted to remind everyone that in-person services at Hermosa Beach’s City Hall have
resumed. We are using an appointment system for people to safely visit City Hall to conduct
business with the City in person. Please visit the appointment site on the City’s website to
schedule a time to visit City Hall.
We plan to resume in-person City Council meetings this Summer. As we outlined in our
reopening, recovery and resilience plan, Hermosa SHINES, our intent is to continue to take
advantage of the technologies and tools we began using during the pandemic to augment our
in-person services. We are working on being able to continue integrating remote technologies
with an in-person set-up to use Zoom so that residents and other participants in Council
meetings can provide their input from their homes, offices or other locations, if needed. This
would be in addition to providing in-person comments and input inside the Council chamber.
Our goal is to increase public access to the meetings, and we are working on an efficient
method for broadcasting online and in-person commentary from the Council chambers.
City Re-openings
The Hermosa Beach Rotary Club has reopened for reservations under the Protocol for Private
Events (Meetings, Receptions and Conferences): Appendix BB.
Summer Camp Registration Underway
Hermosa Beach’s 2021 Summer Camp Programs are still open for registration. Please take a look
at the 2021 Summer Camp Programs Brochure for camp and class offerings and register on the
City’s website at hermosabeach.gov/recreation.
19
As always, we ask that you continue to take precautions to prevent the spread of COVID-19 and
follow the public health experts’ advice to keep you and your loved ones safe.
20
City of Hermosa Beach
Staff Report
City Hall
1315 Valley Drive
Hermosa Beach, CA 90254
Staff Report
21-0335
Honorable Mayor and Members of the Hermosa Beach City Council
Regular Meeting of June 8, 2021
INFORMATION ITEM: UPDATE OF ENHANCED
WATERSHED MANAGEMENT PLAN (EWMP)
City of Hermosa Beach Printed on 6/3/2021Page 1 of 1
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City of Hermosa Beach
Staff Report
City Hall
1315 Valley Drive
Hermosa Beach, CA 90254
Staff Report
21-0336
Honorable Mayor and Members of the Hermosa Beach City Council
Regular Meeting of June 8, 2021
UPDATE FROM CHIEF LEBARON ON
ENFORCEMENT MEASURES
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City of Hermosa Beach
Staff Report
City Hall
1315 Valley Drive
Hermosa Beach, CA 90254
Staff Report
21-0329
Honorable Mayor and Members of the Hermosa Beach City Council
Regular Meeting of June 8, 2021
WRITTEN COMMUNICATION
Recommended Action:
Staff recommends City Council receive and file the written communication.
Attachments:
1.Email from Tony Higgins submitted May 24, 2021
2.Letter from Matt McCool submitted June 1, 2021
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From:tony higgins
To:Eduardo Sarmiento
Subject:Written communications - city Manager covid response
Date:Monday, May 24, 2021 5:16:05 PM
Mr. Sarmiento,
Could you please add this as a written communication for the next council meeting...
START
24 May 2021
Dear City Council,
It’s time to call for the resignation of our City Manager, Suja Lowenthal.
Our City Manager undermined the LA County Covid Safety Orders during the peak of the
pandemic by allowing restaurants owners to place their tables on public property immediately
adjacent to their restaurants to circumvent LA Counties outdoor dining ban.
She did so against the advice of the cities own medical experts from Beach Cities Health
district who repeatedly advised the that outdoor dining at that time was a bad idea. This is a
matter of public record.
What message do you think you sent the public?
Our city manager and city council sent the message that it was OK to ignore medical experts
and disregard State and County Covid safety orders.
Is that the kind of leadership Hermosa needs?
Let me remind you this was during the peak of the peak of the pandemic when people were
dying at our local hospitals at record rates, when LA County was the epicenter of of the
nations Covid crisis and our local healthcare workers were pleading for community support in
following the Covid safety protocols. And this was not the only failure. Ms. Lowenthal
continues to gaslight the public about the cities Covid response.
In the Hermosa Shines Plan in her page 1 introduction she says:
—————————————
The health crisis caused many economic and social shocks -- and many times these were not in
our control.”
“But where we could respond, we did.”
————————————-
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Attachment A. below offers a different perspective.
Council Members, there are some lines you cannot cross and remain in public service.
Subverting LA County Covid safety protocols during the peak of a pandemic is one of those
lines.
If our City Manager won’t resign over this reckless endangerment and breach of public trust,
then the city council must ask for her resignation without any further delay.
And if the city council won’t ask for Ms. Lowenthal’s resignation, one would have to ask is
the city council capable of performing their oversight role on behalf of vulnerable populations,
vulnerable neighborhoods and the general public.
Anthony Higgins
ATTACHMENT A.
OPEN LETTER TO HB CITY COUNCIL
April 20, 2021
To: City Council
City Manager Suja Lowenthal
City Attorney Michael Jenkins
HB Police Chief Paul LeBaron
Subject: Hermosa Beach Covid Response
In the HB City Council candidate forum on March 26th the Easyreader moderator
asked:
Face masks, agree required with enforcement?
https://easyreadernews.com/hermosa-beach-city-council-election-forum-five-
candidates-14-questions/?
fbclid=IwAR1sjF7CUPf5Q4WaRKFiX8miMSSjOZPYclVZ3PiHlNWlJyjQAbe6WDI8Fsc
This question belies a much larger auestion that none of the candidates spoke to: did
city officials undermine county health orders meant to protect vulnerable populations &
the general public AND if so should they be called to account and to what end?
Three examples point to a pattern of city behavior that if true can and should not be
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ignored.
During the 3rd wave of the pandemic (Nov-Jan), while our local hospitals were
overwhelmed, when doctors & nurses were pleading for community help and
vulnerable populations were dying at record rates, the HB the City Manager Suja
Lowenthal, the City Attorney Michael Jenkins and the Police Chief Paul LeBaron ignored
county health orders and allocated public space for restaurant-owned tables, to
undermine and bypass the LA County outdoor dining ban.
These officials knew this would lead to face to face multihousehold dining and that
knew it was violation of county health orders.
The city councils own health experts (BCHD) advised against outdoor dining in 2 city
council meetings but the HB council ignored their advice and allowed this thinly veiled
subversion, putting at risk populations in danger.
To add insult to injury, the City Council allowed restaurant owners that knowingly
participated in undermining the outdoor dining ban to qualify for a city lottery of
~$135,000 in federal tax payor covid relief funds. This is not the kind of leadership
Hermosa Beach deserves.
The rules were clear and contained in the health order, cities cannot weaken county
health orders, they can only strengthen them if local conditions warrant. The city
knowingly disregarded and undermined the county health order. There must be an
accounting.
In the second example, the city allowed organized flag football at Valley Park nearly
every weekend THROUGHOUT the peak of the pandemic.
On several occasions over the course of several weeks I emailed pictures of these
regularly occurring flag football games at Valley Park to HB city officials. I even provide
the times times the games seemed to be scheduled hoping they would do their duty
and intercede; but the games still went on, week after week throughout the peak of
the pandemic.
On one occasion captured by a HBPD police body cam video AND reviewed by Chief
LeBaron, the officer tried to justify not enforcing the county ban on multihousehold
sporting events and specifically flag football. Anyone can see in flag football there is
considerable face to face contact, blocking, physical contact, players sprinting down the
field and then huddling tightly together; breathing heavily.
How can that not be risky.
But apparently our police department thought it was just fine. Think about it, how can
26
you maintain 6 ft distance and pull a players flag unless you are an orangoutang?
Third, the city of Hermosa entered into a contract with a third party to enforce the
emergency health order (aka mask mandate) passed in July of 2020.
In justifying the expenditure city officials implied their sworn officers and community
service officers simply did not have the time to enforce a mask mandate to protect
Hermosa’s Covid vulnerable populations; basically saying they didn’t have the
resources.
Well no business or government entity ever has the resources it needs to do everything
it wants. Management is about prioritization and clearly identifying what won’t get
done if a new task (e.g. mask enforcement) is undertaken using existing resources. This
used to be called an impact analysis and is just management 101.
But our city manager didn’t think this impact analysis was needed or if it was done it
wasn’t shared with the public. Worse yet, our city council didn’t have the common
sense to demand it before opening the taxpayer checkbook.
Now here is the rub, while the city claimed Valley Park was patrolled by green-vested
Covid safety officers on at least 20 occasions between Nov-mid Feb and claimed that
hundreds of people were verbally warned to mask-up at Valley Park NOT A SINGLE
WRITTEN WARNING OR CITATION WAS EVER ISSUED at the park per a HB public
records search.
Also, anyone that regularly frequented the park between August & December knows
the mask ordinance was largely being ignored except by vulnerable seniors. So if the
city was serious about enforcement why, in the face of rampant mask non-compliance
and frequent multihousehold gatherings and regularly scheduled sporting events did
these contracted Covid safety officers fail to issue a single written warning or citation at
Valley Park?
Remember, this happened at the peak of the pandemic, when LA County was the
epicenter of the Covid crisis, when doctors and nurses were pleading for community
support.
There are many other examples I could cite from beach volleyball that was explicitly
prohibited by the county order to the crowds these volleyball games attracted to city
sponsored daycare where the city maintained masks were being worn as required by
county safety orders and were not, to the simple fact that on the beach, during the
peak of the pandemic virtually no one wore a mask. This continues to this day.
If the city were to respond they would probably say there was nothing they could do.
That would be a lie.
27
On many occasions I recommended the city take some kind of action including using
short term closures of the beach, strand and parks to send the message that mask
scofflaws would not be tolerated.
The city could have issued written warnings at our parks so repeat offenders could be
tracked and citations issued.
They could have put an end to the regularly scheduled flag football games and other
large regularly scheduled FOR-PROFIT activities that were happening every weekday
afternoon during the peak of the pandemic. I sent pictures of this too
The city could have removed the volleyball nets since the county order specifically
excluded volleyball for good reason; heavy exertion and face to face contact at the net.
Most of the nets were allowed to remain up throughout the peak of the pandemic
despite the ongoing violations.
And certainly no one forced the city officials to allocate public space so that restaurant
owners could subvert the county outdoor dining ban.
According to a Brookings Institute study published this March, ~ 400,000 died
unnecessarily and many more suffered debilitating long term consequences from
Covid.
https://www.google.com/amp/s/mobile.reuters.com/article/amp/idUSKBN2BH1DK
Look, there is a chance still more deadly antibody resistant varients will spring up and
reinfect vulnerable populations.
There is a chance that new varients could evolve to attack children. We need to be
prepared for this.
County safety protocols need to work and the city needs to do the work to make sure
that can happen if things go bad again.
And if you think I’m angry, think about how our local health care workers and family
members of those that died must feel. Betrayal might just about cover it.
So now the question that remains is will anyone on the city council or any of the the
city council candidates step up and ask for an investigation.
There must be reckoning before there can be a reconciliation.
But this is complicated.
28
An honest investigation is required, mistakes must be acknowledged and
improvements made.
Covid is not over and just like the 100 year storms that seem to be happening every
few years nowadays, a doubling of the worlds population by 2050 can only lead to
more frequent pandemics.
But I also believe that some of the city officials that made poor decisions during the
pandemic are honorable people that put themselves on the line and served, and have
done a lot of good for the community.
That cannot be forgotten either.
But I also believe the cities actions described above constitute culpable negligence for
which city officials should NOT have qualified immunity,
But LIKE the police officers in the George Floyd murder, there will not be accountability
unless the community demands it.
Anthony Higgins.
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Matt McCool
mccool.matt@gmail.com
June 1, 2021
VIA ELECTRONIC MAIL
Mayor Justin Massey
City of Hermosa Beach
1315 Valley Drive
Hermosa Beach, CA 90254-3885
RE: Public Records Request No. PRR-21-00080-McCool,Matt-05-10-2021
Dear Mayor Massey:
During the December 4, 2019, City Council meeting, you made the following statements regarding then
Councilman Fangary:
In addition to that, 2 months ago, Councilmember Fangary sought to do something, is which
in my opinion, sought to undermine and intimidate the City Manager. He hired a lawyer to
submit eight grossly overbroad public records act request seeking documents that were
plainly targeted at errors he perceived by the City Manager without revealing to any of us
that he was the one behind those requests or simply asking us or the City Manager about
the communications that he was requesting documents for or the issues that concerned
him. Responding to those public records requests has costs us thousands of dollars of staff
time and legal time...
Additionally, there is a video upload to the “Advocates for Hermosa Beach” Facebook group:
https://www.facebook.com/mccool.matt/videos/10161054040633378
In the spirit of open, honest, and transparent governance, I submitted a public records request for the
alleged public records request by then Councilman Fangary through a third-party lawyer.
Ms. Tanesha Hudson of the City Clerk's Office provided a copy of that public records request. (Exhibit A.)
Since these responses were already generated, this request should be simple to fulfil with minimum
expense. Since thousands of dollars were already accrued for these records, let them be made to the
public to review.
For the June 8, 2021, City Council meeting, I want to address the City Council regarding this matter.
Very respectfully,
Matt McCool
30
Exhibit A
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City of Hermosa Beach
Staff Report
City Hall
1315 Valley Drive
Hermosa Beach, CA 90254
Staff Report
21-0337
Honorable Mayor and Members of the Hermosa Beach City Council
Regular Meeting of June 8, 2021
UPDATES FROM CITY COUNCIL AD HOC SUBCOMMITTEES
AND STANDING COMMITTEE DELEGATES/ALTERNATES
City of Hermosa Beach Printed on 6/3/2021Page 1 of 1
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City of Hermosa Beach
Staff Report
City Hall
1315 Valley Drive
Hermosa Beach, CA 90254
Staff Report
REPORT 21-0338
Honorable Mayor and Members of the Hermosa Beach City Council
Regular Meeting of June 8, 2021
CITY COUNCIL MEETING MINUTES
(City Clerk Eduardo Sarmiento)
Recommended Action:
Staff recommends City Council approve the following minutes:
1.May 25, 2021 Regular City Council Meeting
Due to staffing shortages in the City Clerk’s office, the following minutes will be provided as soon as
they become available:
1.June 9, 2020 Regular Meeting
2.June 23, 2020 Special Meeting
3.October 13, 2020 Regular Council Meeting
4.October 19, 2020 Adjourned Regular Meeting
5.October 27, 2020 Regular Meeting
Respectfully Submitted by: Eduardo Sarmiento, City Clerk
Approved: Suja Lowenthal, City Manager
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Hermosa Beach City Council
Adjourned Regular Meeting Minutes
Tuesday, May 25, 2021
Closed Session-5:00 P.M.,
Regular Session 6:00 P.M.
Virtual Meeting via Zoom
City Council
Justin Massey, Mayor
Michael Detoy, Mayor Pro Tem
Stacey Armato, Councilmember
Mary Campbell, Councilmember
I.CALL TO ORDER
The City Council Regular Meeting of the City of Hermosa Beach met via a virtual
meeting held pursuant to Executive Order N-29-20 issued by Governor Gavin Newsom
March 17, 2020 on the above date. Meeting was called to order by Mayor Massey at
6:02 p.m.
II.PLEDGE OF ALLEGIANCE
The pledge of allegiance was led Mayor Massey.
III.ROLL CALL
Present: Councilmembers Armato, Campbell, Mayor Pro Tem Detoy, and Mayor
Massey
Absent: None
IV.CLOSED SESSION REPORT
City attorney Jenkins stated two items were listed on the closed session agenda, no
additional items were added, and no reportable action was taken.
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V. ANNOUNCEMENTS
Mayor Massey began his comments by congratulating Raymond Jackson on his election
to the City Council and thanked all the Council candidates for their willingness to seek
public office. He encouraged they stay engaged with the City and continue to play a role
in civic life. Mayor Massey indicated that more details about the swearing-in ceremony
will be shared through the City’s social media channels once confirmed.
Mayor Massey then announced the 10th and final mural by the Hermosa Beach Murals
Project will be completed by June 4th, with an official unveiling tentatively scheduled for
June 21, 2021 at 6 p.m. This completion date is a slight delay from what was announced
at the last Coffee with the Mayor event on Saturday May 22, 2021. He added that a
tentative completion date of June 4, 2021 has been set.
Mayor Massey provide a brief history of the Hermosa Beach Murals Project, sharing that
the project is led by a nonprofit organization started by Hermosa Beach residents to
beautify the downtown business district with murals that depict the City’s rich and eclectic
history and culture. The new mural is of the Surf and Sand Club, which was also known
as the Hermosa Biltmore Hotel. The hotel was located on the Strand between 14th and
15th Streets and was completed in 1926. The new mural is on the west wall of the Old
Bijou Theater at 1229 Hermosa Ave. He closed by thanking those who have worked so
hard to make these murals a reality.
VI. APPROVAL OF AGENDA
Mayor Massey requested that item 11p be pulled from the consent calendar for
separate consideration.
MOTION: Councilmember Armato motioned to approve the agenda with item 11p
being pulled from the consent calendar, seconded by Councilmember Campbell. Motion
carried by unanimous consent.
AYES: Councilmembers Armato, Campbell, Mayor Pro Tem Detoy, and Mayor Massey
NOES: None
VII. PROCLAMATIONS/PRESENTATIONS
a. COVID-19 HEALTH UPDATE FROM BEACH CITIES HEALTH DISTRICT
b. PROCLAMATION DECLARING JUNE 2021 AS PRIDE MONTH IN HERMOSA
BEACH
39
(Complete audio and video are available upon request at the City Clerk’s office or can
be accessed by clicking the following link. (May 25, 2021 Regular City Council Meeting)
VIII. CITY MANAGER REPORT
City Manager Suja Lowenthal began her remarks by sharing the 2021 AVP Hermosa
Beach Open will not take place in Hermosa Beach this year due to the uncertainty
surrounding the State’s and County’s COVID-19 protocols. AVP indicated to staff that
they are looking forward to bringing the Hermosa Beach Open back next year.
AVP would still like to host a junior event under the current COVID-19 protocols during
the 2021 Hermosa Beach Open dates of July 7−July 11. AVP is working with City staff
to make this possible.
Ms. Lowenthal then shared that in-person services at Hermosa Beach’s City Hall have
resumed, using an appointment system that will allow people to safely conduct business
with the City in person. Those interested can make an appointment by visiting the City’s
website.
City Manager Lowenthal then provided a reminder that community surveys are due May
31, 2021. The surveys are seeking the public’s input on some of the temporary programs
the City established during the pandemic to support local businesses. These include the
expanded outdoor dining and retail, the Temporary Lane Reconfiguration Project, limited
live music and entertainment and outdoor fitness classes offered in public parks and on
the beach. The community survey can be found on the home page of City’s website.
Ms. Lowenthal then shared that the City is resuming summer services under updated
COVID-19 protocols. Hermosa Beach’s 2021 Summer Camp Programs are open for
registration, and additional information can be found at the City’s website, including the
2021 Summer Camp Programs Brochure for camp and class offerings. Registration
information can be accessed on the City’s website at hermosabeach.gov/recreation.
City Manager Lowenthal then provided an update regarding COVID-19. She shared that
face mask requirements in Hermosa Beach have been aligned with the state and county
requirements, and the City no longer is utilizing private security to enforce mask
ordinances. The U.S. Centers for Disease Control and Prevention (CDC) have updated
its guidelines to advise Americans who are fully vaccinated against COVID-19 that they
can stop wearing masks or maintaining social distance in most settings.
But the Los Angeles County Department of Public Health is adhering to the California
Department of Public Health’s guidance, which has determined California will keep
existing mask guidance in place until June 15 when it aims to fully reopen the economy.
After that, the state has said it plans to allow fully vaccinated Californians to go without
a mask in most indoor settings.
Ms. Lowenthal added that everyone ages 12 and older in California are now eligible for
COVID-19 vaccines. Appointments for vaccines can be made by visiting myturn.ca.gov.
The consent of a parent or legal guardian may be needed for those between the ages of
40
12 and 17 to receive a vaccination. Please visit Vaccinate All 58 to learn more about the
safe and effective vaccines available. She then asked everyone to continue to take
precautions and follow the public health experts’ advice to keep all safe.
(Complete audio and video are available upon request at the City Clerk’s office or can
be accessed by clicking the following link. (May 25, 2021 Regular City Council Meeting).
IX. PUBLIC COMMUNICATIONS/ORAL AND WRITTEN COMMUNICATIONS
The following members of the public provided public comment:
1. Robert Aronoff
2. Sarah Harper
3. Jessica Accamando
4. Daniel Rittenhouse
5. Sheryl Main
6. Laura Pena
7. Ron Newman
8. Jon David
9. Ed Hart
(Complete audio and video are available upon request at the City Clerk’s office or can
be accessed by clicking the following link. (May 25, 2021 Regular City Council Meeting)
X. CITY COUNCIL COMMENTS
a. UPDATES FROM CITY COUNCIL AD HOC SUBCOMMITTEES
AND STANDING COMMITTEE DELEGATES/ALTERNATES
(Complete audio and video are available upon request at the City Clerk’s office or can
be accessed by clicking the following link. (May 25, 2021 Regular City Council Meeting)
XI. CONSENT CALENDAR
MOTION: Councilmember Armato moved to approve the balance of the consent
calendar with item 11p being pulled by Mayor Massey for separate
consideration, seconded by Councilmember Campbell. Motion carried by
unanimous consent.
AYES: Councilmembers Armato, Campbell, Mayor Pro Tem Detoy, and Mayor Massey
NOES: None
41
a. CITY COUNCIL MEETING MINUTES
b. CHECK REGISTERS
c. REVENUE REPORT, COVID-19 REVENUE TRACKING REPORT,
EXPENDITURE REPORT, AND CIP REPORT BY PROJECT FOR MARCH
2021 AND APRIL 2021
d. ACCEPTANCE OF DONATIONS
e. CITY TREASURER’S REPORT AND CASH BALANCE REPORT
f. CANCELATION OF CERTAIN CHECKS
g. CAPITAL IMPROVEMENT PROGRAM STATUS REPORT AS OF MAY 13,
2021
h. ACTION MINUTES OF THE PUBLIC WORKS COMMISSION MEETING OF
MARCH 17, 2021
i. ACTION SHEET OF THE PLANNING COMMISSION MEETING OF MAY 18,
2021
j. PLANNING COMMISSION TENTATIVE FUTURE AGENDA ITEMS
k. SUBJECT: FINAL MAP NO. 82295 (C.U.P. CON NO. 18-7, PDP NO. 18-10)
LOCATION: 1602 LOMA DRIVE APPLICANT/PROPERTY OWNER: 1602
LOMA DRIVE, LLC BY KIM KOMICK REQUEST: APPROVE FINAL PARCEL
MAP 82295 FOR A TWO-UNIT DETACHED RESIDENTIAL CONDIMINIUM
PROJECT
l. APPROVAL OF THE COMMENCEMENT OF SPECIAL EVENT LONG-TERM
AGREEMENT NEGOTIATIONS WITH THE INTERNATIONAL SURF FESTIVAL
m. SOUTH BAY WORKFORCE INVESTMENT BOARD QUARTERLY SUMMARY
n. CONSIDERATION OF ARAKELIAN ENTERPRISES, INC (DBA ATHENS
SERVICES) REQUEST FOR AN ANNUAL RATE ADJUSTMENT TO THE
MAXIMUM RATES FOR SOLID WASTE SERVICES
o. APPROVAL OF SIXTH AMENDMENT TO AGREEMENT FOR CROSSING
GUARD SERVICES BETWEEN THE CITY OF HERMOSA BEACH AND
AMERICAN GUARD SERVICES
p. CONSIDERATION OF A RESOLUTION EXPRESSING SUPPORT FOR
42
ACTIONS TO FURTHER STRENGTHEN LOCAL AUTHORITY AND CONTROL
AS RELATED TO LOCAL ZONING AND HOUSING ISSUES
q. REQUEST FOR APPROVAL TO UNFREEZE THE ASSISTANT ENGINEER
POSITION AS APPROVED IN THE 2020-2021 BUDGET
XII. ITEMS REMOVED FROM THE CONSENT CALENDAR FOR SEPARATE
DISCUSSION
p. CONSIDERATION OF A RESOLUTION EXPRESSING SUPPORT FOR
ACTIONS TO FURTHER STRENGTHEN LOCAL AUTHORITY AND CONTROL
AS RELATED TO LOCAL ZONING AND HOUSING ISSUES
MOTION: Councilmember Armato moved to approve staff recommendation, seconded
by Mayor Pro Tem Detoy. Motion carried by majority consent.
AYES: Councilmembers Armato, Campbell, and Mayor Pro Tem Detoy
NOES: Mayor Massey
(Complete audio and video are available upon request at the City Clerk’s office or can
be accessed by clicking the following link. (May 25, 2021 Regular City Council Meeting)
XIII. PUBLIC HEARINGS – TO COMMENCE AT 6:30 P.M.
a. APPROVAL OF THE PARKS, RECREATION AND COMMUNITY
RESOURCES ADVISORY COMMISSION’S RECOMMENDATION TO
INCLUDE DB EVENTS (VOLLEYBALL TOURNAMENTS) ON THE 2021
SPECIAL EVENT CALENDAR ON JUNE 19, AUGUST 21, AND OCTOBER 24
MOTION: Councilmember Armato moved to approve staff recommendation, seconded
by Mayor Pro Tem Detoy. Motion carried by unanimous consent.
AYES: Councilmembers Armato, Campbell, Mayor Pro Tem Detoy, and Mayor Massey
NOES: None
b. CITY COUNCIL REVIEW AND RECONSIDERATION OF THE APRIL 20, 2021
PLANNING COMMISSION DECISION TO DENY A REQUEST FOR A
CONDITIONAL USE PERMIT AMENDMENT TO PROVIDE ONSITE SALE,
SERVICE, AND CONSUMPTION OF GENERAL ALCOHOL INDOORS ONLY
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WITHIN THE HOTEL LOUNGE FOR REGISTERED GUESTS ONLY, SEVEN
DAYS A WEEK 7:00 A.M. TO 10:00 P.M. AT AN EXISTING HOTEL (H2O
HERMOSA) AT 1429 HERMOSA AVENUE, AND DETERMINATION THAT
THE PROJECT IS CATEGORICALLY EXEMPT FROM THE CALIFORNIA
ENVIRONMENTAL QUALITY ACT (CEQA)
Mayor Massey recused himself from the item due to conflict of interest.
The following members of the public provided public comment:
1. Trent Larson
2. Jessica Accamando
3. George Barks
MOTION: Councilmember Armato moved to continue the item to September 14, 2021,
motion died due to lack of second.
MOTION: Councilmember Campbell moved to continue the item to July 13, 2021,
seconded by Mayor Pro Tem Detoy. Motion carried by majority consent.
AYES: Councilmember Campbell, and Mayor Pro Tem Detoy
NOES: Councilmember Armato
RECUSED: Mayor Massey
c. INTRODUCTION OF ORDINANCE 21-1431 OF THE CITY OF HERMOSA
BEACH, CALIFORNIA, AMENDING VARIOUS SECTIONS OF CHAPTER 8.12
OF AND ADDING CHAPTER 8.14 TO THE HERMOSA BEACH MUNICIPAL
CODE REGARDING SOLID WASTE
The following members of the public provided public comment:
4. Amanda Mejia
MOTION: Councilmember Campbell moved to approve staff recommendation,
seconded by Councilmember Armato. Motion carried by unanimous consent.
AYES: Councilmembers Armato, Campbell, Mayor Pro Tem Detoy, and Mayor Massey
NOES: None
(Complete audio and video are available upon request at the City Clerk’s office or can
44
be accessed by clicking the following link. (May 25, 2021 Regular City Council Meeting)
XIV. MUNICIPAL MATTERS
a. MIDDLE INCOME/WORKFORCE RENTAL HOUSING PROGRAMS
The following members of the public provided public comment:
5. Dean Francois
MOTION: Councilmember Armato moved to receive and file, seconded by
Councilmember Campbell. Motion carried by unanimous consent.
AYES: Councilmembers Armato, Campbell, Mayor Pro Tem Detoy, and Mayor Massey
NOES: None
(Complete audio and video are available upon request at the City Clerk’s office or can
be accessed by clicking the following link. (May 25, 2021 Regular City Council Meeting)
XV. FUTURE AGENDA ITEMS
a. TENTATIVE FUTURE AGENDA ITEMS
No comments were made regarding future agenda items.
ADJOURNMENT
City Attorney Michael Jenkins adjourned the Adjourned Regular City Council meeting to
May 25, 2021 at 5:00 p.m. for closed session followed by regular session at 6:00 p.m.
The Council meeting concluded at 10:10 p.m.
Eduardo Sarmiento, City Clerk
45
City of Hermosa Beach
Staff Report
City Hall
1315 Valley Drive
Hermosa Beach, CA 90254
Staff Report
REPORT 21-0343
Honorable Mayor and Members of the Hermosa Beach City Council
Regular Meeting of June 8, 2021
CHECK REGISTERS
(Finance Director Viki Copeland)
Recommended Action:
Staff recommends City Council ratify the following check registers.
Attachments:
1.Check Register 5/13/2021
2.Check Register 5/20/2021
Respectfully Submitted by: Viki Copeland, Finance Director
Approved: Suja Lowenthal, City Manager
City of Hermosa Beach Printed on 6/3/2021Page 1 of 1
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05/13/2021
Check Register
CITY OF HERMOSA BEACH
1
5:38:55PM
Page:
Bank code :boa
Voucher Date Vendor Invoice Description/Account Amount
97333 5/13/2021 A.J. KIRKWOOD & ASSOCIATES K210412 CLARK FLD BASEBALL LIGHT EMERGENCY REPAI21688
105-2601-4201 595.00
Total : 595.0021688
97334 5/13/2021 ABSOLUTE INTERNATIONAL SECURIT 2020102712 SECURITY/COVID VACCINE CLINIC/APR2121086
157-2702-4201 372.52
Total : 372.5221086
97335 5/13/2021 ACCESS, INC.1002 ADA CONSULTING SRVCS/APR2121696
301-8602-4201 8,695.00
Total : 8,695.0021696
97336 5/13/2021 AHN, PHILLIP PO 36127 DISMISSED CITATION 43012221 REFUND22274
001-3302 10.00
Total : 10.0022274
97337 5/13/2021 AMERICAN GUARD SERVICES, INC. INV14704 CROSSING GUARD SERVICES/MAR2120685
001-2102-4201 22,518.70
Total : 22,518.7020685
97338 5/13/2021 AMERICAN PUBLIC WORKS ASSOCIAT Member ID 65927 7 STAFF/MEMBERSHIP/JAN21-DEC2100401
001-4202-4315 1,531.25
Total : 1,531.2500401
97339 5/13/2021 ATHENS SERVICES 10364295 SHREDDING/2 BINS/MAY2116660
001-2101-4309 45.00
Total : 45.0016660
97340 5/13/2021 BEECASSO LIVE BEE REMOVAL INC 1944 COMM CTR PALM TREE BEE REMOVAL20705
001-6101-4201 225.00
Total : 225.0020705
97341 5/13/2021 BRAUN LINEN SERVICE 1673208 thru 1677755 PRISONER LAUNDRY/APR2100163
001-2101-4306 215.67
Total : 215.6700163
97342 5/13/2021 BROWN, GARY W Parcel 4182-012-002 STREET LIGHT & SEWER TAX REBATE16089
001-6871 75.96
105-3105 24.61
2b (1)47
05/13/2021
Check Register
CITY OF HERMOSA BEACH
2
5:38:55PM
Page:
Bank code :boa
Voucher Date Vendor Invoice Description/Account Amount
(Continued)Total : 100.57 97342 5/13/2021 BROWN, GARY W16089
97343 5/13/2021 CALIFORNIA WATER SERVICE Acct 4286211111 WATER USAGE/MAR2100016
105-2601-4303 3,264.33
001-6101-4303 27,475.05
001-4204-4303 1,622.60
001-3304-4303 293.98
Total : 32,655.9600016
97344 5/13/2021 CAPITAL WHOLESALE LIGHTING 438354 & 439745 STREET LIGHTING MATERIALS/APR2121720
105-2601-4309 863.63
Total : 863.6321720
97345 5/13/2021 CEROFECI, WILLIAM A Parcel 4169-027-033 STREET LIGHT & SEWER TAX REBATE14808
001-6871 126.60
105-3105 24.61
Total : 151.2114808
97346 5/13/2021 CHARM-TEX, INC.0248218-IN JAIL SUPPLIES19277
001-2101-4306 298.50
Total : 298.5019277
97347 5/13/2021 CHIEF LEADERSHIP 1051 PHILLIPS/MGMT TRAINING/PMT 222253
001-2101-4317 1,500.00
Total : 1,500.0022253
97348 5/13/2021 COLLISTER, CHASE PO 36142 DUPLICATE CITATION PMT REFUNDS22271
001-3302 692.00
Total : 692.0022271
97349 5/13/2021 CONWAY, KRISTINE Receipt 10211960.001 CLASS 9300 WITHDRAWAL REFUND21905
001-2111 189.70
Total : 189.7021905
97350 5/13/2021 COUNTY OF LOS ANGELES RE-PW-21041205754 ARTESIA BOULEVARD MEDIAN MAINT/MAR2100879
105-2601-4303 109.20
Total : 109.2000879
97351 5/13/2021 CPCA, CA POLICE CHIEFS ASSOC 18324 MEMBERSHIP THRU 6/30/2200480
001-2101-4315 145.00
48
05/13/2021
Check Register
CITY OF HERMOSA BEACH
3
5:38:55PM
Page:
Bank code :boa
Voucher Date Vendor Invoice Description/Account Amount
97351 5/13/2021 (Continued)CPCA, CA POLICE CHIEFS ASSOC00480
MEMBERSHIP THRU 6/30/2218596
001-2101-4315 695.00
Total : 840.0000480
97352 5/13/2021 CROWN CASTLE FIBER LLC PO 36153 DESIGN & COST ESTIMATE22282
001-2133 8,800.00
Total : 8,800.0022282
97353 5/13/2021 DE LA TORRE, YESENIA PO 36129 DISMISSED CITATION 31026731 REFUND22273
001-3302 53.00
Total : 53.0022273
97354 5/13/2021 EASY READER HD21-011 to HD21-020 MAT REQ 708588/LEGAL ADS/APR2100181
001-1121-4323 1,535.75
Total : 1,535.7500181
97355 5/13/2021 FEUERSTINE, CHARLES S PO 36130 DISMISSED CITATION 43012250 REFUND22275
001-3302 48.00
Total : 48.0022275
97356 5/13/2021 FJR PACIFIC, INC.23384 QUARTERLY CITYWIDE A/C MAINT/MAR2121217
001-4204-4201 1,750.00
Total : 1,750.0021217
97357 5/13/2021 GRAHAM CO.37827 PARKING STRUCT EMERGENCY LIGHT BATTERIES10466
001-3304-4201 3,339.50
001-3304-4201 248.85
Total : 3,588.3510466
97358 5/13/2021 HAILE, PAMELA Parcel 4169-029-029 STREET LIGHT & SEWER TAX REBATE17925
105-3105 24.61
001-6871 126.60
Total : 151.2117925
97359 5/13/2021 HARCRO SALES, LTD PO 36132 DISMISSED CITATION 41004079 REFUND22277
001-3302 68.00
Total : 68.0022277
97360 5/13/2021 HDL COREN & CONE SIN008297 PROPERTY TAX AUDIT SRVCS/APR21-JUN2103131
49
05/13/2021
Check Register
CITY OF HERMOSA BEACH
4
5:38:55PM
Page:
Bank code :boa
Voucher Date Vendor Invoice Description/Account Amount
97360 5/13/2021 (Continued)HDL COREN & CONE03131
001-1202-4201 1,375.00
Total : 1,375.0003131
97361 5/13/2021 HERMOSA LOCK & SAFE SHOP IN98417 CITY HALL FRONT DOOR LOCK REPAIR00279
001-4204-4201 205.00
Total : 205.0000279
97362 5/13/2021 IPS GROUP INC INV54873 PARKING METER PARTS/SUPPLIES19314
001-3302-4309 1,179.30
Total : 1,179.3019314
97363 5/13/2021 K9 SERVICES LLC HBPD-13 K9 OFFICER MAINTENANCE TRAINING/APR2121552
170-2105-4317 250.00
Total : 250.0021552
97364 5/13/2021 LOBSENZ, JAMES MATTHEW PO 36133 CITATION OVERPAYMENT REFUNDS22280
001-3302 56.00
Total : 56.0022280
97365 5/13/2021 LONG, MICHAEL A.Parcel 4182-023-018 STREET LIGHT & SEWER TAX REBATE21410
001-6871 126.60
105-3105 24.61
Total : 151.2121410
97366 5/13/2021 LONG, YVONNE C Parcel 4185-018-001 SEWER & STREET LIGHT TAX REBATE11601
001-6871 126.60
105-3105 24.61
Total : 151.2111601
97367 5/13/2021 MANION, EMMITT L.Parcel 4169-027-032 STREET LIGHT & SEWER TAX REBATE07174
001-6871 126.60
105-3105 24.61
Total : 151.2107174
97368 5/13/2021 MERCHANTS LANDSCAPE SERVICES 57861 HERMOSA AVE/PLANT 3 PALM TREES18071
001-6101-4201 375.00
SOUTH PARK SLOPE CLEAN-UP57863
301-8603-4201 1,752.48
50
05/13/2021
Check Register
CITY OF HERMOSA BEACH
5
5:38:55PM
Page:
Bank code :boa
Voucher Date Vendor Invoice Description/Account Amount
(Continued)Total : 2,127.48 97368 5/13/2021 MERCHANTS LANDSCAPE SERVICES18071
97369 5/13/2021 MOST DEPENDABLE FOUNTAINS INV63510 22ND ST RESTROOM SHOWER REPLACEMENT11454
001-6101-4309 2,525.00
001-6101-4309 204.25
Total : 2,729.2511454
97370 5/13/2021 NOURIAN, SARKIS PO 36134 DISMISSED CITATION 31026641 REFUND22272
001-3302 53.00
Total : 53.0022272
97371 5/13/2021 OCHOA, MICHAEL PO 36143 CITATION 42003495 OVERPAYMENT REFUND22279
001-3302 28.00
Total : 28.0022279
97372 5/13/2021 OFFICE DEPOT 165590627001 REQ 791334/2 KEYBOARD/MOUSE COMBO13114
001-2101-4305 93.05
MAT REQ 791327/SANITIZER REFILLS165722281001
157-2702-4201 88.30
Total : 181.3513114
97373 5/13/2021 OPSAHL, JOHN Parcel 4181-056-019 STREET LIGHT & SEWER TAX REBATE10922
001-6871 126.60
105-3105 24.61
Total : 151.2110922
97374 5/13/2021 PARTEK SOLUTIONS INC 25095 PARKING METER PAPER ROLLS/FEB2114694
001-3302-4309 698.36
Total : 698.3614694
97375 5/13/2021 PLUMBERS DEPOT INC PD-48193 SEWER SNAKE CABLE REPAIR15103
160-3102-4201 277.63
Total : 277.6315103
97376 5/13/2021 PUBLIC SAFETY CENTER INC 5992670 6 STINGER 2020 FLASHLIGHTS02715
001-2101-4350 864.88
001-2101-4350 79.79
Total : 944.6702715
97377 5/13/2021 RACE COMMUNICATIONS RC496180 DEDICATED INTERNET SERVICE/MAY2122179
51
05/13/2021
Check Register
CITY OF HERMOSA BEACH
6
5:38:55PM
Page:
Bank code :boa
Voucher Date Vendor Invoice Description/Account Amount
97377 5/13/2021 (Continued)RACE COMMUNICATIONS22179
715-1206-4201 1,020.00
Total : 1,020.0022179
97378 5/13/2021 REDONDO BEACH, CITY OF 572542 CITY PROSECUTOR SERVICES/MAR2103282
001-1132-4201 16,667.00
Total : 16,667.0003282
97379 5/13/2021 RICHIE, JOHNATHAN PO 36136 INSTRUCTOR PMT/CLASSES 9248-54/5820932
001-4601-4221 4,189.50
Total : 4,189.5020932
97380 5/13/2021 ROSS, SHERI E HM4-2021 CITATION HEARING OFFICER/APR2122138
001-1201-4201 375.00
Total : 375.0022138
97381 5/13/2021 ROUND STAR WEST LLC PO 36074 INSTRUCTOR PMT/CLASSES 9235/616921
001-4601-4221 1,680.00
Total : 1,680.0016921
97382 5/13/2021 SCHAAF & WHEELER CONSULTING 33901 FLOODPLAIN POLICY UPDATE/FEB2120263
161-8417-4201 1,995.00
Total : 1,995.0020263
97383 5/13/2021 SCHWADTMANN, CORNELIA PO 36145 CITATION 35019881 OVERPAYMENT REFUND22237
001-3302 30.00
Total : 30.0022237
97384 5/13/2021 SITEONE LANDSCAPE SUPPLY, LLC 108044598-001 REQ 586790/EROSION CONTROL STAPLES19829
301-8603-4201 171.63
Total : 171.6319829
97385 5/13/2021 SOUTHERN CALIFORNIA EDISON CO 700057262780 ELECTRICITY/APR2100159
105-2601-4303 51.02
ELECTRICITY/MAR21-APR21700156101336
001-4204-4303 368.02
001-6101-4303 1,051.36
001-4204-4303 7,932.15
105-2601-4303 256.80
ELECTRICITY/MAR21-APR21700222378305
52
05/13/2021
Check Register
CITY OF HERMOSA BEACH
7
5:38:55PM
Page:
Bank code :boa
Voucher Date Vendor Invoice Description/Account Amount
97385 5/13/2021 (Continued)SOUTHERN CALIFORNIA EDISON CO00159
001-6101-4303 1,338.93
ELECTRICITY/APR21700234897163
001-3304-4201 1,966.11
ELECTRICITY/APR21700304673105
160-3102-4201 86.88
ELECTRICITY/MAR21-APR21700313445137
105-2601-4303 16,006.15
Total : 29,057.4200159
97386 5/13/2021 SPARKLETTS 4472788042221 REQ 435256/DRINKING WATER/APR2100146
001-4601-4305 151.26
Total : 151.2600146
97387 5/13/2021 SPRINT 269424317-232 CSO TRUNK MODEMS/MAR2110098
001-3302-4304 262.94
COMM RES/CELL PHONES/MAR21551834312-232
001-4601-4304 161.57
Total : 424.5110098
97388 5/13/2021 STEINHOFF, ANDREA Receipt 1021292.001 CLASS 9232 WITHDRAWAL REFUND22293
001-2111 86.80
Total : 86.8022293
97389 5/13/2021 TARANGO, CHERYL Receipt 4184-019-027 SEWER & STREET LIGHT TAX REBATE11818
001-6871 126.60
105-3105 24.61
Total : 151.2111818
97390 5/13/2021 T-MOBILE Acct 954297746 YARD/CELL PHONES/HOTSPOTS/APR2119082
001-4202-4304 325.06
Total : 325.0619082
97391 5/13/2021 TOTH, LAYLI PO 36146 CITATION OVERPAYMENT REFUNDS22278
001-3302 90.00
Total : 90.0022278
97392 5/13/2021 TU, MEILEN Receipt 2002637.003 CLASS 9263 WITHDRAWAL REFUND22294
001-2111 78.50
53
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Check Register
CITY OF HERMOSA BEACH
8
5:38:55PM
Page:
Bank code :boa
Voucher Date Vendor Invoice Description/Account Amount
(Continued)Total : 78.50 97392 5/13/2021 TU, MEILEN22294
97393 5/13/2021 UNION BANK OF CALIFORNIA, PARS #6746019200PO 35414 PARS/OPEB CONTRIBUTIONS/MAY2114528
001-1101-4190 141.00
001-1121-4190 607.00
001-1201-4190 2,349.00
001-1202-4190 1,908.00
001-1203-4190 721.00
001-1204-4190 1,062.00
001-2101-4190 14,819.00
001-3104-4190 995.00
001-3301-4190 100.00
001-3302-4190 3,197.00
001-4101-4190 1,378.00
001-4201-4190 1,414.00
001-4202-4190 2,267.00
001-4204-4190 734.00
001-4601-4190 1,095.00
001-6101-4190 944.00
105-2601-4190 199.00
160-3102-4190 257.00
161-3109-4190 179.00
715-4206-4190 536.00
Total : 34,902.0014528
97394 5/13/2021 UPS 000023R146191 REQ 791383/SHIP TO V&V (VENDOR)14148
001-2101-4305 9.44
Total : 9.4414148
97395 5/13/2021 VERIZON BUSINESS SERVICES 71809827 VOIP PHONES/COMM RES/MAR2118666
001-4601-4304 143.18
VOIP PHONES/BARD/MAR2171809892
001-3302-4304 70.26
VOIP PHONES/EOC OVER GYM/MAR2171809997
001-1201-4304 62.27
VOIP PHONES/BASE 3/MAR2171810450
001-3302-4304 109.37
Total : 385.0818666
54
05/13/2021
Check Register
CITY OF HERMOSA BEACH
9
5:38:55PM
Page:
Bank code :boa
Voucher Date Vendor Invoice Description/Account Amount
97396 5/13/2021 VOERMAN, DIRK PO 36147 DISMISSED CITATION 37016433 REFUND22276
001-3302 53.00
Total : 53.0022276
97397 5/13/2021 VOIGHT, ANNA Rcpts 2002639/40 CLASS 9276 WITHDRAWAL REFUND22292
001-2111 262.20
Total : 262.2022292
97398 5/13/2021 WATUMULL, MEGAN Receipt 1021830.001 CLASS 9273 WITHDRAWAL REFUND22291
001-2111 123.60
Total : 123.6022291
97399 5/13/2021 WHITLOW, ROBERT L Parcel 4184-015-022 STREET LIGHT TAX REBATE14051
105-3105 24.61
Total : 24.6114051
97400 5/13/2021 ZUMAR INDUSTRIES INC 92483 MAT REQ 987199/STREET SIGN MAINTENANCE01206
001-3104-4309 257.15
MAT REQ 854453/NO OUTLET SIGNS92543
001-3104-4309 280.69
MAT REQ 854452/STREET NAME SIGNS92623
001-3104-4309 568.62
MAT REQ 854029/NO LEFT TURN SIGNS92624
001-3104-4309 502.70
6 DO NOT BLOCK INTERSECTION SIGNS92633/Req 854457
001-3104-4309 307.78
MAT REQ 854456/STREET NAME SIGNS92684
001-3104-4309 843.49
Total : 2,760.4301206
130104612 4/23/2021 SOCAL GAS 5/13/21 Check Run CITY BLDGS/NATURAL GAS/MAR2100170
001-4204-4303 254.37
Total : 254.3700170
Bank total : 193,580.72 69 Vouchers for bank code :boa
193,580.72Total vouchers :Vouchers in this report 69
55
05/13/2021
Check Register
CITY OF HERMOSA BEACH
10
5:38:55PM
Page:
Bank code :boa
Voucher Date Vendor Invoice Description/Account Amount
"I hereby certify that the demands or claims covered by the
checks listed on pages 1 to 10 inclusive, of the check
register for 5/18/2021 are accurate funds are available for
payment, and are in conformance to the budget."
By
Finance Director
Date 5/26/2021
56
05/20/2021
Check Register
CITY OF HERMOSA BEACH
1
5:21:37PM
Page:
Bank code :boa
Voucher Date Vendor Invoice Description/Account Amount
97401 5/20/2021 ACCESS, INC.1003 ADA CONSULT/GREENBELT/APR2121696
301-8602-4201 1,850.00
Total : 1,850.0021696
97402 5/20/2021 AMERICAN GUARD SERVICES, INC. INV16963 CROSSING GUARD SERVICES/APR2120685
001-2102-4201 22,130.10
Total : 22,130.1020685
97403 5/20/2021 AT&T 960 461-1985 555 7 PD COMPUTER CIRCUITS/MAY2100321
001-2101-4304 212.84
Total : 212.8400321
97404 5/20/2021 ATHENS SERVICES 10310580 CITYWIDE SWEEP/STEAM CLEAN/APR2116660
001-3104-4201 16,353.92
001-3301-4201 10,898.50
001-3304-4201 1,501.69
001-6101-4201 1,601.23
CITYWIDE STEAM CLEANING/APR2110310580A
001-3301-4201 4,971.99
001-3304-4201 1,427.64
STREET SWEEPING/APR2110310580B
001-3301-4201 6,500.32
001-3304-4201 764.74
Total : 44,020.0316660
97405 5/20/2021 CALIFORNIA FENCE AND SUPPLY CO 7682 COMM CTR PARKING LOT ADA STAIR RAILING03621
001-4204-4201 995.00
FORT LOTS OF FUN FENCE HOLE REPAIRM3632IN
001-6101-4201 543.00
Total : 1,538.0003621
97406 5/20/2021 CHARM-TEX, INC.0248974-IN DISPOSABLE JAIL CLOTHING/MEN'S BRIEFS19277
001-2101-4306 114.52
Total : 114.5219277
97407 5/20/2021 COLLINS, DENNIS L.PO 36196 INSTRUCTOR PMT/CLASSES 9284/7/90/305970
001-4601-4221 2,408.00
Total : 2,408.0005970
2b (2)57
05/20/2021
Check Register
CITY OF HERMOSA BEACH
2
5:21:37PM
Page:
Bank code :boa
Voucher Date Vendor Invoice Description/Account Amount
97408 5/20/2021 COMMERCIAL BUILDING MANAGEMENT 68051 JANITORIAL/COVID PORTER/CITY BLDGS/APR2120627
001-4204-4201 6,861.00
157-2702-4201 3,866.69
Total : 10,727.6920627
97409 5/20/2021 CONTINENTAL MAPPING SERVICE 050621 PUBLIC NOTICE SRVCS/MAY2120398
001-4101-4201 1,550.00
Total : 1,550.0020398
97410 5/20/2021 COUNTY OF LOS ANGELES C0009838 FIRE PROTECTION SERVICES/JUN2120781
001-2202-4251 458,524.00
180-2202-4251 3,583.00
001-2202-4111 10,625.00
301-2202-4251 30,306.00
Total : 503,038.0020781
97411 5/20/2021 DOWNSTREAM SERVICES, INC.104708 STORM DRAIN CATCH BASIN MAINT/MAR2121034
161-3109-4201 4,454.00
Total : 4,454.0021034
97412 5/20/2021 FRONTIER COMMUNICATIONS PO 36197 DESIGN IMPROVEMENT DEPOSIT22288
001-2133 20,000.00
Total : 20,000.0022288
97413 5/20/2021 GROH, MARK LEE HB-016 CITATION HEARING EXAMINER/MAY2121597
001-1204-4201 192.00
Total : 192.0021597
97414 5/20/2021 HAWTHORNE, CITY OF PO 36166 PUBLIC SAFETY SOFTWARE/JAN20-DEC2005345
001-2101-4251 32,909.29
Total : 32,909.2905345
97415 5/20/2021 INEZ, DANIEL DIHb-050321 HB LOGO REFRESH/APR2121505
001-1201-4201 4,800.00
Total : 4,800.0021505
97416 5/20/2021 INTERNATIONAL SECURITY PRODUCT 228566 BUSINESS LICENSE CERTIFICATE PAPER17474
001-1204-4305 372.85
001-1204-4305 68.39
58
05/20/2021
Check Register
CITY OF HERMOSA BEACH
3
5:21:37PM
Page:
Bank code :boa
Voucher Date Vendor Invoice Description/Account Amount
(Continued)Total : 441.24 97416 5/20/2021 INTERNATIONAL SECURITY PRODUCT17474
97417 5/20/2021 LANDSCAPE STRUCTURES, INC.INV-097319 22ND ST/PULL UP BAR12190
001-6101-4309 264.05
001-6101-4309 22.81
CITYWIDE SWING SEATS/SPARE NUTSINV-097609
001-6101-4309 39.40
001-6101-4309 2.79
Total : 329.0512190
97418 5/20/2021 LAW OFFICE OF C PATRICK HAMBLI 3303 PERSONNEL LEGAL SERVICES/APR2122299
001-1203-4201 519.75
Total : 519.7522299
97419 5/20/2021 LEBARON, PAUL TR 848 PER DIEM/PARTNERING FOR SUCCESS22191
001-1201-4317 100.00
Total : 100.0022191
97420 5/20/2021 LONG BEACH BMW MOTORCYCLE 40160 BMW MOTORCYCLE 2 ANNUAL MAINT12739
715-2101-4311 1,186.95
BMW MOTORCYCLE 2 BATTERY REPAIR40219
715-2101-4311 194.48
Total : 1,381.4312739
97421 5/20/2021 M6 CONSULTING INC 1636 LAND USE PLAN CHECKS/MAR2119487
001-4201-4201 9,970.00
LAND USE PLAN CHECKS/APR211647
001-4201-4201 6,212.50
PLAN CHECKS/SKECHERS/APR211648
001-2131 1,155.00
Total : 17,337.5019487
97422 5/20/2021 MAGNUM VENTURE PARTNERS po 36169 INSTRUCTOR PAYMENT18274
001-4601-4221 18,921.00
Total : 18,921.0018274
97423 5/20/2021 MILLER PLANNING ASSOCIATES 20007-0421-05 ZONING ORDINANCE UPDATE/APR2121660
150-4105-4201 6,105.00
Total : 6,105.0021660
59
05/20/2021
Check Register
CITY OF HERMOSA BEACH
4
5:21:37PM
Page:
Bank code :boa
Voucher Date Vendor Invoice Description/Account Amount
97424 5/20/2021 REDONDO BEACH, CITY OF 572543 DIESEL VEHICLE FUEL/NOV2008837
715-2201-4310 566.57
715-3104-4310 261.56
DIESEL VEHICLE FUEL/OCT20572544
715-2201-4310 632.27
715-3104-4310 96.37
DIESEL VEHICLE FUEL/DEC20572545
715-2201-4310 562.67
Total : 2,119.4408837
97425 5/20/2021 RODRIGUEZ, LUIS "LUCHO"PO 36192 REIMB/MEMBERSHIPS20753
001-4202-4315 230.00
Total : 230.0020753
97426 5/20/2021 SHERWIN-WILLIAMS 26491 thru 28679 PAINTING SUPPLIES/APR2117903
001-3104-4309 933.38
001-4204-4309 1,061.73
Total : 1,995.1117903
97427 5/20/2021 SIEMENS INDUSTRY INC 5620031109 TRAFFIC SIGNAL MAINTENANCE/MAR2107158
001-3104-4201 852.50
Total : 852.5007158
97428 5/20/2021 SOCAL GAS Acct 115 404 6900 1 734 PIER/CITY BLDGS/NATURAL GAS/MAR2100170
001-4204-4303 178.10
Total : 178.1000170
97429 5/20/2021 SOUTH BAY REGIONAL PUBLIC COMM 03993 VEHICLE MAINTENANCE/JAN21-MAR2108812
715-2101-4311 31,150.48
Total : 31,150.4808812
97430 5/20/2021 SPECIALIZED ELEVATOR SERVICES 26080 PARKING STRUCTURE ELEVATOR MAINT/APR2121538
001-3304-4201 160.00
CITY HALL ELEVATOR MAINT/APR2126081
001-4204-4201 160.00
Total : 320.0021538
97431 5/20/2021 SPRINT 269424317-233 CSO TRUNK MODEMS/APR2110098
001-3302-4304 262.94
60
05/20/2021
Check Register
CITY OF HERMOSA BEACH
5
5:21:37PM
Page:
Bank code :boa
Voucher Date Vendor Invoice Description/Account Amount
(Continued)Total : 262.94 97431 5/20/2021 SPRINT10098
97432 5/20/2021 TRANSTECH ENGINEERS, INC 20211215 WIRELESS PLAN CHECKS/APR2115901
001-4202-4201 700.00
Total : 700.0015901
97433 5/20/2021 VERIZON BUSINESS SERVICES 71809768 VOIP PHONES/CITY HALL/PD/MAR2118666
001-1101-4304 38.62
001-1121-4304 60.94
001-1132-4304 18.25
001-1141-4304 36.49
001-1201-4304 149.49
001-1202-4304 91.09
001-1203-4304 72.91
001-1204-4304 109.50
001-1208-4304 6.79
001-2101-4304 764.33
001-4101-4304 133.88
001-4201-4304 146.78
001-4202-4304 182.28
001-4204-4321 18.21
160-3102-4201 18.23
715-1206-4304 18.24
VOIP PHONES/YARD/MAR2171810456
001-4202-4304 145.80
Total : 2,011.8318666
97434 5/20/2021 VILLANUEVA, BRANDY PO 36186 REIMB/PPE SUPPLIES/FEDEX20204
157-2702-4305 346.01
001-1201-4305 29.55
REIMB/PW DIRECTOR RETIREMENT GIFTPO 36195
001-1203-4201 135.80
Total : 511.3620204
Bank total : 735,411.20 34 Vouchers for bank code :boa
735,411.20Total vouchers :Vouchers in this report 34
61
05/20/2021
Check Register
CITY OF HERMOSA BEACH
6
5:21:37PM
Page:
Bank code :boa
Voucher Date Vendor Invoice Description/Account Amount
"I hereby certify that the demands or claims covered by the
checks listed on pages 1 to 6 inclusive, of the check
register for 5/20/2021 are accurate funds are available for
payment, and are in conformance to the budget."
By
Finance Director
Date 5/26/2021
62
City of Hermosa Beach
Staff Report
City Hall
1315 Valley Drive
Hermosa Beach, CA 90254
Staff Report
REPORT 21-0344
Honorable Mayor and Members of the Hermosa Beach City Council
Regular Meeting of June 8, 2021
ACTION MINUTES OF THE PARKS, RECREATION AND
COMMUNITY RESOURCES ADVISORY COMMISSION
MEETING OF MAY 4, 2021
(Interim Community Resources Manager John Jones)
Recommended Action:
Staff recommends City Council receive and file the action minutes of the Parks, Recreation and
Community Resources Advisory Commission meeting of May 4, 2021.
Attachments:
Minutes of May 4, 2021
Approved: John Jones, Interim Community Resources Manager
City of Hermosa Beach Printed on 6/3/2021Page 1 of 1
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MINUTES
REGULAR MEETING of the PARKS, RECREATION AND COMMUNITY RESOURCES
ADVISORY COMMISSION
May 4, 2021 – Council Chambers, City Hall
1315 Valley Drive – 7:00 P.M.
Parks, Recreation and Community Resources Advisory Commission
Lauren Pizer Mains, Chairperson
Barbara Ellman, Vice Chairperson
Jani Lange
Traci Horowitz
************************************************************************************************************************
THIS MEETING WAS HELD PURSUANT TO EXECUTIVE ORDER N-29-20 ISSUED BY GOVERNOR
GAVIN NEWSOM ON MARCH 17, 2020. ANY OR ALL COMMISSIONERS MAY ATTEND AND
PARTICIPATE BY TELECONFERENCE/VIRTUAL MEETING.
MEMBERS OF THE PUBLIC MAY PARTICIPATE BY TELECONFERENCE.
************************************************************************************************************************
Parks, Recreation and Community Resources Advisory Commission agendas and staff
reports are available for review on the City’s web site at www.hermosabeach.gov
Written materials distributed to the Parks, Recreation and Community Resources Advisory
Commission within 72 hours of the meeting are available for public inspection immediately
upon distribution in the Community Resources Department during normal business hours
from Monday through Thursday, 7:00 a.m. - 6:00 p.m.
1. Call to Order
2. Pledge of Allegiance
3. Roll Call
4. Announcements
Present: Chairperson Pizer Mains, Vice Chairperson Ellman, and Commissioners Lange and Horowitz;
Recreation Coordinator Nick Shattuck, Senior Recreation Supervisor Lisa Nichols, Interim Community
Resources Manager John Jones, and Associate City Attorney Patrick Donegan.
5. Presentations
A. None.
6. Miscellaneous Items and Reports – Community Resources Manager
A. COVID-19 Updates
B. Updates Regarding Items Previously on the Commission’s Agenda
7. Public Comment
Anyone wishing to address the Commission on items pertaining to parks and recreation
that are not listed on the agenda may do so at this time. The Brown Act generally
prohibits the Commission from taking action on any matter not listed on the posted
agenda. Comments from the public are limited to three minutes per speaker.
64
None.
8. Correspondence
A. Letter from Tony Higgins
9. Consent Calendar
A. Approval of the Regular Meeting Action Minutes of April 12, 2021
Motion by Commissioner Horowitz to approve Item A. Approval of the Regular Meeting Action Minutes of
April 12, 2021 on the Consent Calendar. Commissioner Ellman seconded the motion. Motion passed with
a 4-0 vote.
10. Items Removed from the Consent Calendar for Separate Discussion
11. Public Hearings
A. Approval of the DB Events (Volleyball Tournaments) to the 2021 Special Event
Calendar on Saturday, June 19; Saturday, August 21; and Sunday, October 24 on
the Beach Volleyball Courts North of the Pier
Recommendation: Staff recommends that the Parks, Recreation and Community
Resources Advisory Commission hold a Public Hearing to make a recommendation to
the City Council to approve the inclusion of the DB Events (volleyball tournaments) on
the 2021 special event calendar on the beach volleyball courts north of the pier on the
following dates:
• Saturday, June 19
• Saturday, August 21; and
• Sunday, October 24.
Coming forward to address the Commission at this time: (01:18:22)
David Brandin, DB Events representative
Motion by Commissioner Ellman to approve the DB Events (Volleyball Tournaments) to the 2021 Special
Event Calendar on Saturday, June 19; Saturday, August 21; and Sunday, October 24 o n the beach
volleyball courts north of the Pier. Commissioner Horowitz seconded the motion. Motion passed with a 4-
0 vote.
12. Matters for Commission Consideration
A. Approval of First Amendment to Hermosa Beach Youth Basketball League
Agreement
Recommendation: Staff recommends that the Parks, Recreation and Community
Resources Advisory Commission recommend the City Council’s approval of an
amendment to the Hermosa Beach Youth Basketball League Agreement to allow a
temporary use of the two (2) Kelly basketball courts for games for only the 2021 Hermosa
Beach Youth Basketball Summer season.
Coming forward to address the Commission at this time: (01:30:44)
Brian Pettigrew, Hermosa Beach Youth Basketball representative
Motion by Commissioner Lange to approve the first amendment to Hermosa Beach Youth Basketball
League Agreement. Commissioner Horowitz seconded the motion. Motion passed with a 4-0 vote.
B. Approval of the Addition of Hermosa Beach Chamber of Commerce Summer
Sidewalk Celebration to the 2021 Special Event Calendar on Friday, August 6,
Saturday, August 7 and Sunday, August 8 at Various Downtown Locations
Recommendation: Staff recommends that the Commission approve the addition of the
Hermosa Beach Chamber of Commerce Summer Sidewalk Celebration to the 2021
Special Event Calendar on Friday, August 6, Saturday, August 7 and Sunday, August 8
at various downtown locations.
Coming forward to address the Commission at this time: (01:38:40)
65
Jessica Accamando, Chamber of Commerce President
Motion by Commissioner Ellman to approve the addition of Hermosa Beach Chamber of Commerce
Summer Sidewalk Celebration to the 2021 Special Event Calendar on Friday, August 6, Saturday, August
7 and Sunday, August 8 at various downtown locations. Commissioner Lange seconded the motion.
Motion passed with a 4-0 vote.
13. Commissioner’s Reports
A. Sub-committees
i. Special Event (Lange and Ellman)
ii. Community Theatre (Lange and Pizer Mains)
iii. Municipal Leases (Pizer Mains and Horowitz)
iv. Community Resources Department Use Policies (Ellman)
v. Clark Building Improvements (Ellman and Pizer Mains)
vi. Naming Policy (Horowitz)
B. Commission Liaison Roles
i. Surfers Walk of Fame (Lange)
ii. Access Hermosa (Ellman) – on hold
14. Items Requested by Commissioners
A. None
15. Other Matters
16. Adjournment
This meeting was adjourned to the regular Tuesday, June 1, 2021 meeting by Chairperson Pizer-Mains at
9:00pm.
66
City of Hermosa Beach
Staff Report
City Hall
1315 Valley Drive
Hermosa Beach, CA 90254
Staff Report
REPORT 21-0346
Honorable Mayor and Members of the Hermosa Beach City Council
Regular Meeting of June 8, 2021
LOS ANGELES COUNTY FIRE SERVICES AND AMBULANCE MONTHLY REPORT FOR APRIL
2021
(Emergency Management Coordinator Brandy Villanueva)
Recommended Action:
Staff recommends City Council receive and file the April 2021 Fire and Ambulance monthly report.
Executive Summary:
City departments generate monthly reports to provide a snapshot of activities performed each month.
Prior to the transition of fire and ambulance transport services to the County of Los Angeles,the
Hermosa Beach Fire Department developed monthly response reports.After the transition,the
monthly report was updated to include Los Angeles County Fire Department and McCormick
Ambulance information and continues to be uploaded to the website.The following report provides
details regarding services provided for the month of April 2021.
Background:
At the February 11,2020,Council meeting,City Council requested monthly reports be placed onto
the City Council agenda under consent calendar.On the July 14,2020 City Council agenda,the
monthly reports began to appear. This report reflects the services for April 2021.
Discussion:
The April 2021 monthly report provides an overview of services provided by LACoFD and McCormick
Ambulance (Attachment 1: April 2021 LACoFD and McCormick Ambulance Monthly Report).
General Plan Consistency:
This report and associated recommendation have been evaluated for their consistency with the City’s
General Plan. Relevant Policies are listed below:
Safety Element
Goal 5. High quality police and fire protection services provided to residents and visitors.
City of Hermosa Beach Printed on 6/3/2021Page 1 of 2
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Staff Report
REPORT 21-0346
Policies:
·5.2 High level of response.Achieve optimal utilization of allocated public safety resources
and provide desired levels of response, staffing, and protection within the community.
Fiscal Impact:
Fire and ambulance services are contracted and accounted for during the annual budget process.
Attachments:
1.Fire and ambulance monthly report-April 2021.
Respectfully Submitted by: Brandy Villanueva, Emergency Management Coordinator
Noted for Fiscal Impact: Viki Copeland, Finance Director
Approved: Suja Lowenthal, City Manager
City of Hermosa Beach Printed on 6/3/2021Page 2 of 2
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E100 S100 Total
RESCUE, EMS
300 ‐ Rescue, emergency medical call (EMS) call, other 4 3 7 3.54%
321 ‐ EMS call, excluding vehicle accident with injury 66 57 123 62.12%
353 ‐ Removal of victim(s) from stalled elevator 1 1 0.50%
RESCUE, EMS Total 71 60 131 66.16%
HAZARDOUS CONDITION
444 ‐ Power line down 1 1 0.50%
HAZARDOUS CONDITION Total 1 1 0.50%
SERVICE CALL
520 ‐ Water problem, other 2 2 1.01%
531 ‐ Smoke or odor removal 2 1 3 1.52%
550 ‐ Public service assistance, other 2 2 1.01%
553 ‐ Public service 1 1 0.50%
SERVICE CALL Total 7 1 8 4.04%
GOOD INTENT CALL
600 ‐ Good intent call, other 30 11 41 20.71%
611 ‐ Dispatched & cancelled enroute 6 2 8 4.04%
GOOD INTENT CALL Total 36 13 49 24.75%
FALSE ALARM, FALSE CALL
700 ‐ False alarm or false call, other 1 1 0.50%
733 ‐ Smoke detector activation due to malfunction 1 1 0.50%
735 ‐ Alarm system sounded due to malfunction 2 2 1.01%
743 ‐ Smoke detector activation, no fire ‐ unintentiona 1 1 0.51%
744 ‐ Detector activation, no fire ‐ unintentional 3 3 1.52%
FALSE ALARM, FALSE CALL Total 8 8 4.04%
SPECIAL OR OTHER INCIDENT TYPE
900 ‐ Special type of incident, other 1 1 0.50%
SPECIAL OR OTHER INCIDENT TYPE Total 1 1 0.50%
Grand Total 124 74 198 100.000%
Note:
Data based on updated fireview ‐ apparatus 2021 data. Hermosa Beach units responses.
LOS ANGELES COUNTY FIRE DEPARTMENT
HERMOSA BEACH
FOR THE MONTH OF APRIL 2021
Incident Type UNIT RESPONSES Percentage
Submitted by Brandy Villanueva, Emergency Management Coordinator 1 69
DAY OF THE WEEK E100 S100 Total
Sunday 17 11 28
Monday 15 10 25
Tuesday 20 9 29
Wednesday 11 8 19
Thursday 22 11 33
Friday 17 9 26
Saturday 22 16 38
Grand Total 124 74 198
Note:
Data based on updated fireview ‐ apparatus 2021 data. Hermosa Beach units responses.
LOS ANGELES COUNTY FIRE DEPARTMENT
HERMOSA BEACH
FOR THE MONTH OF APRIL 2021
UNIT RESPONSES
‐
5
10
15
20
25
E100
S100
Submitted by Brandy Villanueva, Emergency Management Coordinator 2 70
TIME OF THE DAY E100 S100 Total
00:00:00 TO 00:59:59 2 1 3
01:00:00 TO 01:59:59 1 1 2
02:00:00 TO 02:59:59 2 2
03:00:00 TO 03:59:59 1 1
04:00:00 TO 04:59:59 3 3 6
05:00:00 TO 05:59:59 2 1 3
06:00:00 TO 06:59:59 2 1 3
07:00:00 TO 07:59:59 4 2 6
08:00:00 TO 08:59:59 8 5 13
09:00:00 TO 09:59:59 2 1 3
10:00:00 TO 10:59:59 8 3 11
11:00:00 TO 11:59:59 8 7 15
12:00:00 TO 12:59:59 3 3 6
13:00:00 TO 13:59:59 5 3 8
14:00:00 TO 14:59:59 9 6 15
15:00:00 TO 15:59:59 3 3
16:00:00 TO 16:59:59 5 5 10
17:00:00 TO 17:59:59 8 4 12
18:00:00 TO 18:59:59 13 8 21
19:00:00 TO 19:59:59 9 5 14
20:00:00 TO 20:59:59 8 3 11
21:00:00 TO 21:59:59 2 2 4
22:00:00 TO 22:59:59 7 6 13
23:00:00 TO 23:59:59 9 4 13
Grand Total 124 74 198
Note:
Data based on updated fireview ‐ apparatus 2021 data. Hermosa Beach units responses.
LOS ANGELES COUNTY FIRE DEPARTMENT
HERMOSA BEACH
FOR THE MONTH OF APRIL 2021
UNIT RESPONSES
‐
2
4
6
8
10
12
14
00:00:00 TO 00:59:5901:00:00 TO 01:59:5902:00:00 TO 02:59:5903:00:00 TO 03:59:5904:00:00 TO 04:59:5905:00:00 TO 05:59:5906:00:00 TO 06:59:5907:00:00 TO 07:59:5908:00:00 TO 08:59:5909:00:00 TO 09:59:5910:00:00 TO 10:59:5911:00:00 TO 11:59:5912:00:00 TO 12:59:5913:00:00 TO 13:59:5914:00:00 TO 14:59:5915:00:00 TO 15:59:5916:00:00 TO 16:59:5917:00:00 TO 17:59:5918:00:00 TO 18:59:5919:00:00 TO 19:59:5920:00:00 TO 20:59:5921:00:00 TO 21:59:5922:00:00 TO 22:59:5923:00:00 TO 23:59:59E100
S100
Submitted by Brandy Villanueva, Emergency Management Coordinator 3 71
Ad Hoc Report:
Name:
Date:
Description:
Seizure Date Seizure Time ALI City Answer Secs Call Type ID ALI Class
4/1/2021 10:18:14 HMB 16 911 Calls WPH2
4/1/2021 11:35:43 HERMOSA BEACH 2 911 Calls BUSN
4/2/2021 10:40:16 HERM BCH 2 911 Calls WPH2
4/3/2021 07:52:11 HERMOSA BEACH 2 911 Calls RESD
4/3/2021 23:56:43 HERMOSA BEACH 2 911 Calls RESD
4/4/2021 18:25:56 HERMOSA BEACH 2 911 Calls RESD
4/4/2021 22:42:31 HMB 2 911 Calls WPH2
4/5/2021 11:48:42 HERM BCH 23 911 Calls WPH2
4/6/2021 08:24:12 HERMOSA BEACH 2 911 Calls BUSN
4/8/2021 11:15:10 HERM BCH 1 911 Calls WPH2
4/9/2021 08:32:05 HERMOSA BEACH 2 911 Calls RESD
4/9/2021 08:39:52 HMB 2 911 Calls WPH2
4/9/2021 14:56:08 HMB 82 911 Calls WPH2
4/10/2021 14:32:59 HMB 6 911 Calls WPH2
4/10/2021 19:29:16 HMB 2 911 Calls WPH2
4/10/2021 23:45:36 HERM BCH 9 911 Calls WPH2
4/11/2021 10:07:31 HERM BCH 2 911 Calls WPH2
4/13/2021 01:30:00 HMB 2 911 Calls WPH2
4/14/2021 09:29:31 HERM BCH 2 911 Calls W911
4/14/2021 22:08:45 HERMOSA BEACH 2 911 Calls BUSN
4/15/2021 21:14:26 HERM BCH 2 911 Calls WPH2
4/16/2021 23:42:17 HERMOSA BEACH 2 911 Calls RESD
4/17/2021 16:34:34 HERM BCH 2 911 Calls WPH2
4/17/2021 22:03:05 HERM BCH 2 911 Calls WPH2
4/18/2021 18:48:18 HERMOSA BEACH 2 911 Calls VOIP
4/19/2021 18:54:26 HERM BCH 2 911 Calls WPH2
4/20/2021 02:54:54 HERM BCH 17 911 Calls WPH2
4/20/2021 10:02:08 HERMOSA BEACH 17 911 Calls BUSN
4/20/2021 17:50:57 HERMOSA BEACH 2 911 Calls RESD
4/20/2021 17:51:55 HERMOSA BEACH 2 911 Calls RESD
4/21/2021 11:59:19 HERM BCH 2 911 Calls WPH2
4/21/2021 12:03:47 HMB 2 911 Calls WPH2
4/23/2021 15:36:01 HB 2 911 Calls WPH2
4/24/2021 08:04:30 HMB 2 911 Calls WPH2
4/24/2021 14:21:05 HERMOSA BEACH 2 911 Calls WPH2
4/24/2021 20:31:32 HMB 3 911 Calls WPH2
4/24/2021 22:03:55 HERMOSA BEACH 2 911 Calls BUSN
Hermosa Call Answer Time
5/1/2021
April 2021
Los Angeles County Fire
Submitted by Brandy Villanueva, Emergency Management Coordinator 4
72
4/25/2021 06:21:40 HMB 2 911 Calls WPH2
4/25/2021 13:48:50 HERMOSA BEACH 2 911 Calls BUSN
4/25/2021 16:56:34 HERMOSA BEACH 2 911 Calls RESD
4/25/2021 19:14:33 HERM BCH 47 911 Calls WPH2
4/27/2021 04:39:04 HERMOSA BEACH 2 911 Calls RESD
4/27/2021 19:17:17 HERMOSA BEACH 17 911 Calls BUSN
4/28/2021 18:21:01 HERMOSA BEACH 143 911 Calls VOIP
4/29/2021 18:23:51 HMB 2 911 Calls WPH2
4/30/2021 18:12:11 HMB 2 911 Calls WPH2
4/30/2021 18:18:48 HMB 2 911 Calls WPH2
4/30/2021 19:01:34 HERMOSA BEACH 2 911 Calls VOIP
Average Call Answer Time (seconds)9
Submitted by Brandy Villanueva, Emergency Management Coordinator 5
73
McCormick Ambulance
April 2021
Total Number of Dispatched Calls
Dispatched Calls Totals
Transported 58
Cancelled 26
Grand Total 84
NOTE: None
58, 69%
26, 31%
Total Dispatched Calls
Transported
Cancelled
Submitted by Brandy Villanueva, Emergency Management Coordinator 6 74
Calls per the day of the week
Day of the Week Completed Cancelled Total
Sunday 9 2 11
Monday 8 5 13
Tuesday 9 1 10
Wednesday 4 3 7
Thursday 6 9 15
Friday 9 1 10
Saturday 13 5 18
Grand Total 58 26 84
0
2
4
6
8
10
12
14
Completed
Canceled
Submitted by Brandy Villanueva, Emergency Management Coordinator 7 75
Response by the Time of Day
Time of Day Total Response
00:00:00 TO 00:59:59 1
01:00:00 TO 01:59:59 1
02:00:00 TO 02:59:59 1
03:00:00 TO 03:59:59 0
04:00:00 TO 04:59:59 3
05:00:00 TO 05:59:59 1
06:00:00 TO 06:59:59 0
07:00:00 TO 07:59:59 2
08:00:00 TO 08:59:59 6
09:00:00 TO 09:59:59 1
10:00:00 TO 10:59:59 3
11:00:00 TO 11:59:59 8
12:00:00 TO 12:59:59 3
13:00:00 TO 13:59:59 4
14:00:00 TO 14:59:59 6
15:00:00 TO 15:59:59 1
16:00:00 TO 16:59:59 5
17:00:00 TO 17:59:59 4
18:00:00 TO 18:59:59 8
19:00:00 TO 19:59:59 6
20:00:00 TO 20:59:59 5
21:00:00 TO 21:59:59 2
22:00:00 TO 22:59:59 7
23:00:00 TO 23:59:59 6
Grand Total 84
0
1
2
3
4
5
6
7
8
9
00:00:00 TO 00:59:5901:00:00 TO 01:59:5902:00:00 TO 02:59:5903:00:00 TO 03:59:5904:00:00 TO 04:59:5905:00:00 TO 05:59:5906:00:00 TO 06:59:5907:00:00 TO 07:59:5908:00:00 TO 08:59:5909:00:00 TO 09:59:5910:00:00 TO 10:59:5911:00:00 TO 11:59:5912:00:00 TO 12:59:5913:00:00 TO 13:59:5914:00:00 TO 14:59:5915:00:00 TO 15:59:5916:00:00 TO 16:59:5917:00:00 TO 17:59:5918:00:00 TO 18:59:5919:00:00 TO 19:59:5920:00:00 TO 20:59:5921:00:00 TO 21:59:5922:00:00 TO 22:59:5923:00:00 TO 23:59:59Time of Day
Responses
Submitted by Brandy Villanueva, Emergency Management Coordinator 8 76
Response Times Within Allowable
Time
Delayed Response Cancelled Total
Code 3: Response
Time of 8:59 or less
16 6 0 22
Code 2: Response
Time of 15:00 or
less
36 0 0 36
Cancelled
Responses
0 0 26 26
Grand Total 52 6 34 84
Submitted by Brandy Villanueva, Emergency Management Coordinator 9 77
City of Hermosa Beach
Staff Report
City Hall
1315 Valley Drive
Hermosa Beach, CA 90254
Staff Report
REPORT 21-0326
Honorable Mayor and Members of the Hermosa Beach City Council
Regular Meeting of June 8, 2021
APPROVAL OF A SPECIAL EVENT LONG-TERM AGREEMENT
WITH THE ARTS GROUP OF HERMOSA BEACH TO PROVIDE
THE FINE ARTS FESTIVAL TO BE HELD ON
THE COMMUNITY CENTER LAWN
(Interim Community Resources Manager John Jones)
Recommended Action:
Staff recommends City Council:
1.Approve a special event long-term agreement with the Arts Group of Hermosa Beach to
provide the Fine Arts Festival; and
2.Authorize the Mayor and the City Clerk to execute the agreement, subject to approval
by the City Attorney (Attachment 1).
Background:
As part of the approval process for the special event LTA policy pilot program,staff received an LTA
application on September 21,2020 from the Arts Group of Hermosa Beach to provide the Fine Arts
Festival to be held on the Community Center lawn.At its October 6,2020 meeting,the Parks,
Recreation and Community Resources Advisory Commission reviewed the LTA application from the
Arts Group of Hermosa Beach and approved commencement of negotiations for the Fine Arts
Festival.The City Council approved the Commission’s recommendation to commence negotiations at
its October 27, 2020 meeting.
Discussion:
Since City Council approval to initiate long-term agreement negotiations,staff has worked with the
Arts Group of Hermosa Beach to develop mutually agreeable terms for an agreement to hold the
Fine Arts Festival on the Community Center lawn.This event would include art displays by local
artists and students,with approximately 80 participants and 500 in attendance over the weekend.
Negotiations have concluded and staff recommends approval of the proposed agreement beginning
September 24, 2021 and expiring June 11, 2023 (Attachment 1).
General Plan Consistency:
This report and associated recommendation have been evaluated for their consistency with the City’s
City of Hermosa Beach Printed on 6/3/2021Page 1 of 3
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Staff Report
REPORT 21-0326
General Plan. Relevant Policies are listed below:
Governance Element
Goal 1. A high degree of transparency and integrity in the decision-making process.
Policies:
·1.6 Long-term considerations.Prioritize decisions that provide long-term community benefit
and discourage decisions that provide short-term community benefit but reduce long-term
opportunities.
Parks and Open Space Element
Goal 3. Community parks and facilities encourage social activity and interaction.
Policies:
·3.1 Community-friendly events.Encourage, permit, and support
community group,nonprofit,or business organized events on City property that support
physical activity, beach culture, and family-friendly social interactions.
·3.2 Social and cultural events.Design and program parks and open
space to accommodate unique social and cultural events to foster connectedness and
interaction.
·3.3 Commercial use of facilities.Regulate and enforce commercial use of City parks
and open spaces to ensure activities do not impact general use and enjoyment.
Goal 8.Special events at the beach are balanced to support community recreation and
economic development without restricting coastal access or impacting the community.
Policies:
·8.3 Community-focused events.Prioritize the approval of special events that enhance
the sense of community, improve economic vitality, and foster
·8.4 Family-focused events.Prioritize events that appeal to a wide segment of
community members.
Fiscal Impact:
Table 1 includes all applicable special event fees associated with the Fine Arts Festival event.Those
fees highlighted in yellow would remain the responsibility of the Arts Group of Hermosa Beach;others
would be waived,as proposed in the LTA.The proposed fee-waivers include:the non-profit
application fee of $589;the event set-up fee of $266 for one day of set-up;and the Category II daily
fee of $2,811 for two event days for a total of approximately $6,477 annually.The total fees waived
over the three-year agreement term would be approximately $19,431.
City of Hermosa Beach Printed on 6/3/2021Page 2 of 3
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Staff Report
REPORT 21-0326
Table 1: Fine Arts Festival Event Fees
Attachments:
1.Agreement between the City of Hermosa Beach and Arts Group of Hermosa Beach to Provide
the Fine Arts Festival
Respectfully Submitted by: Lisa Nichols, Senior Recreation Supervisor
Concur: John Jones, Interim Community Resources Manager
Noted for Fiscal Impact: Viki Copeland, Finance Director
Legal Review: Mike Jenkins, City Attorney
Approved: Suja Lowenthal, City Manager
City of Hermosa Beach Printed on 6/3/2021Page 3 of 3
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Arts Group of Hermosa Beach Fine Arts Festival Agreement 2021 - 2023 1
AGREEMENT BETWEEN THE CITY OF HERMOSA BEACH
AND THE ARTS GROUP OF HERMOSA BEACH TO
PROVIDE THE FINE ARTS FESTIVAL
THIS AGREEMENT is made this ________ day of _________________, 2021, by and
between the City of Hermosa Beach (hereinafter called “CITY”), and The Arts Group of
Hermosa Beach (hereinafter called “ARTS GROUP”).
RECITALS
A. ARTS GROUP desires to organize, coordinate, produce and oversee the Fine Arts
Festival (“Event”) in the City on City-owned property for the term of this
Agreement.
B. The CITY is willing to make its property available for the Event due to the benefit
it provides to the community.
NOW, THEREFORE, the parties agree as follows:
Section 1. Term of Agreement. The term of this Agreement shall commence on September 24,
2021 and expire on June 11, 2023, unless earlier terminated as provided herein.
Section 2. ARTS GROUP’s Duties:
a. Event. ARTS GROUP may organize, coordinate, produce and oversee the Event
on the Community Center north and east lawn. The event must be open to the
public. Event days included as part of this Agreement shall be:
• September 24, 2021 – September 26, 2021
• June 10, 2022 – June 12, 2022
• June 9, 2023 – June 11, 2023
b. Annual Event Confirmation. ARTS GROUP must annually inform the CITY of
its intent to produce the Event, including confirmation of event dates and event
times, no later than three (3) months prior to the event dates. Should ARTS
GROUP desire to reschedule an event date(s) from the dates outlined in this
Agreement, it must do so in writing no later than three (3) months prior to the
requested event date(s). CITY will review the request against other activities and
events booked within the City. While approval of a date change will not be
unreasonably withheld, already scheduled activities or events will have priority.
Use of additional location(s) in proximity of the Community Center may be
approved as mutually agreed upon between the CITY and ARTS GROUP
provided ARTS GROUP informs the CITY of this request at least three (3)
months prior to the Event. The CITY or ARTS GROUP may cancel an Event
within 30 days written notice prior to each Event without penalty due to COVID-
19 precautionary measures or other pandemic-related health orders that would
deem the event unsafe or temporarily prohibited. CITY reserves the right in its
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Arts Group of Hermosa Beach Fine Arts Festival Agreement 2021 - 2023 2
sole discretion at any time or times to close and suspend the use of each Event
Location subject to this Agreement for any duration in order to protect public
health and safety. Any such closure will not constitute a breach or a default of this
Agreement. CITY shall have no liability whatever to ARTS GROUP for the effect
of such suspension and closure on any Event, nor shall CITY have any
responsibility to provide ARTS GROUP with substitute Event locations. ARTS
GROUP’s rights under this Agreement are subject and subordinate to CITY’s
police and emergency powers in addition to CITY’s rights to manage its
municipal facilities including outdoor public spaces and its contractual rights as
described in this Agreement.
c. Event Permits and Agreements. ARTS GROUP shall obtain permits from CITY
for each Event and shall enter into and comply with all agreements for such
permits as required by CITY, including but not limited to the provision of
adequate insurance and indemnification of CITY, its officers, agents, volunteers,
employees, and attorneys as outlined in the Special Event Permit. Exhibit A
includes a sample Special Event Permit.
i. ARTS GROUP shall additionally procure any required permits from
the Los Angeles County Health Department and any other government
agency should food service or other activity that requires additional
permits is provided at an Event.
d. Insurance. ARTS GROUP shall provide comprehensive general liability insurance
with a combined single limit of not less than $2,000,000.00 per occurrence. Such
insurance shall (a) name the City, its appointed and elected officials, officers,
employees and agents as insured’s; and (b) be primary with respect to any
insurance or self-insurance programs maintained by the City; and (c) contain
standard cross-liability provisions. ARTS GROUP shall furnish properly executed
certificates of insurance to City, which certificates shall clearly evidence all
coverage required above and provide that such insurance shall not be materially
changed, terminated or allowed to expire except on thirty (30) days prior written
notice to City; and further, shall provide that if ARTS GROUP fails to pay any
required deductible or self-insured retention, City may do so at ARTS GROUP’s
expense.
e. Fee to CITY. ARTS GROUP shall pay CITY all direct costs associated with each
Event within 30 days after each event. Such costs shall include but not be limited
to the provision of CITY Staff time dedicated to the Event, Amplified Sound
Permit, and parking fees. Indirect costs shall be waived including the annual
special event application fee, category fee, set-up/tear-down fee, and co-sponsor
fees.
f. Annual Review. Within 60 days prior to and after each Event, ARTS GROUP
shall provide an annual overview to the Parks, Recreation and Community
Resources Advisory Commission in the form of an agendized presentation. The
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Arts Group of Hermosa Beach Fine Arts Festival Agreement 2021 - 2023 3
pre-event presentation shall highlight: a general event overview including
anticipated number of attendees; an overview of the event footprint and
individualized setup; and anticipated impacts to the community as a result of the
event. The post-event presentation shall include: a general overview including the
actual number of attendees; actual impact(s) to the community as a result of the
event; and any event struggle(s) and success(es).
g. Environmental Sustainable Measures. ARTS GROUP shall implement the
CITY’s environmental sustainability measures, including but not limited to:
i. Electric and Bio-diesel Generators. Generators on the venue shall be
electric or operated with a 50% blend of bio-diesel fuel, or equivalent
or lower emissions sources.
ii. Food Service Containers. ARTS GROUP has read, understands, and
accepts responsibility for ensuring implementation of the City’s food
packaging prohibitions in Section 8.64.030 of the Municipal Code,
which reads as follows: 8.64.030(C). No Person shall use or distribute
Polystyrene Food Service Ware at City sponsored events, City-
managed concessions and City meetings open to the public. This
subsection shall apply to the function organizers, agents of the
organizers, City Contractors, Food Providers and any other Person that
enters into an agreement with one or more of the function sponsors to
sell or distribute Prepared Food or otherwise provide a service related
to the function.
iii. Plastic Bags. Use of plastic bags to deliver, provide, or hand
merchandise or Event-related items is prohibited.
iv. ARTS GROUP shall additionally implement all sustainability
measures in the City’s Green Matrix through its conduct of the Event
and shall ensure vendor compliance.
v. ARTS GROUP shall: (1) Incorporate sustainability requirements into
vendor agreements, and advertise green measures and rules in event
advertising and online; (2) prohibit the use of single-use plastic straws,
stirrers, and utensils beginning July 1, 2020 (per HBMC 8.64); limit
single-use paper, packaging, and décor items; use appropriately sized
plates, containers and cups; and limit use of handouts, flyers and
giveaways; (4) enact a no-idling requirement for vehicles associated
with the loading and unloading of event-related equipment; and (5)
provide onsite personnel to ensure that litter and trash are minimized,
and recycling is maximized.
vi. ARTS GROUP shall participate in pre-event and post-event reviews of
compliance with sustainability measures.
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Arts Group of Hermosa Beach Fine Arts Festival Agreement 2021 - 2023 4
h. Private Security Standards. ARTS GREOUP shall work in concert with the
Hermosa Beach Police Department to determine private security standards that
are appropriate for the Event. ARTS GROUP shall seek to employ CITY’s
preferred private security firm provided its costs are competitive. The private
security standards will be in addition to the minimum police services, which will
be determined by the Hermosa Beach Police Department.
i. Event-Related Equipment. ARTS GROUP shall provide all chairs, tables,
canopies, audio system and any other Event-related equipment needed for each
Event, including all staffing necessary for the transportation, set-up and break-
down of equipment.
j. Amplified Sound. ARTS GROUP may request an Amplified Sound Permit for
event related entertainment. The CITY will consider approval based on the overall
impacts to the Community Center.
k. Event Barricades. ARTS GROUP shall provide temporary water-barricades along
the perimeter of the north and east lawn of the Community Center during the
duration of each event day to the City’s satisfaction as shown in Exhibit B.
l. Maintenance of the North and East Lawn. ARTS GROUP shall at its sole expense
maintain the north and east lawn area in good condition and appearance, in
accordance with all ordinances, and shall not allow a nuisance condition to exist
thereon.
k. Parking Spaces. ARTS GROUP may request dedicated use of public parking
spaces as needed for the parking of Event-related vehicles; storage of essential
Event-related equipment and supplies; and other Event-related structures for each
Event. Use of these spaces must be mutually agreed upon between the CITY and
ARTS GROUP following submittal of a site plan by ARTS GROUP outlining the
use of the parking space(s) at least ten (10) working days prior to each Event.
While approval of parking request(s) will not be unreasonably withheld, already
scheduled activities or events will have priority. The CITY will consider approval
based on the location, seasonal needs for parking, and the overall impacts to the
loss of parking spaces to the area. ARTS GROUP shall ensure the spaces are
clean from debris, and other materials that were collected as a result of event-
related activities.
l. Logistical Meetings. ARTS GROUP is required to participate in logistical and
planning meetings with relevant CITY departments as requested by the City.
m. Sponsorships. ARTS GROUP may sell sponsorships for the Event. ARTS
GROUP agrees that Event sponsors will not be from any person or entity
promoting alcohol, gambling, political, or religious viewpoints. Donating persons
or entities must be consistent with the core values, mission, and vision of the City
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Section 3. CITY’s Duties.
a. Event Permits. CITY shall provide event permits to ARTS GROUP for each
Event unless CITY determines in its sole discretion that it would not be in the
public interest or that it would be averse to the public health, safety, or welfare.
b. Event Fee Invoicing. CITY shall provide ARTS GROUP with initial estimates
for indirect CITY costs associated with each Event 90 days in advance of each
event. Such costs shall be those noted in section 1(d). These amounts are
intended as estimations, as final costs billed to ARTS GROUP may change due to
various factors.
c. No Parking Signs. The CITY shall post no parking signs in the Community
Center parking lot at least 72 hours prior to the start of event setup.
d. Community Center Access. The CITY shall provide access to the Community
Center for usage of restroom facilities the day of each event. Hourly fees
associated with the scheduling of Staff past the regularly scheduled closure of the
facility will be borne by the ARTS GROUP as outlined in section 1(d).
Section 4. Assignment. This agreement may not be assigned in whole or in part by either party,
without the prior written consent of the other party.
Section 5. Independent Contractor. ARTS GROUP will act hereunder as an independent
contractor. This Agreement shall not and is not intended to constitute ARTS GROUP as an
agent, servant, or employee of CITY and shall not and is not intended to create the relationship
of partnership, joint venture or association between CITY and ARTS GROUP.
Section 6. Termination. CITY may terminate this Agreement upon 30 days written notice to
ARTS GROUP if CITY determines in its sole discretion that continuation of this Agreement
would not be in the public interest, that it would be adverse to the public health, safety, or
welfare, or that a substantial portion of CITY’s property is unavailable due to construction
activity. Prior to termination on the ground that a substantial portion of CITY’s property is
unavailable due to construction activity, CITY shall provide ARTS GROUP an opportunity to
propose adjustments to the venue or an alternative location for the event. ARTS GROUP’s
proposed adjustments or alternative shall be provided within 30 days of written notice from
CITY and is subject to approval of the City Council, in its sole discretion, in a public meeting.
Upon termination of the Agreement, any events subsequent to the termination will no longer be
the responsibility of ARTS GROUP.
Section 7. Notice. Any notice required to be given shall be deemed duly and properly given
upon delivery, if sent postage prepaid or if personally delivered as follows:
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Arts Group of Hermosa Beach Fine Arts Festival Agreement 2021 - 2023 6
For ARTS GROUP: Arts Group of Hermosa Beach
1506 Golden Avenue
Hermosa Beach, CA 90254
(310) 372-7269
Attention: Sam Perrotti, Arts Group of Hermosa Beach Representative
For CITY: City of Hermosa Beach
1315 Valley Drive
Hermosa Beach, California 90254
(310) 318-0216
Attention: Suja Lowenthal, City Manager
Section 8. Entire Agreement. This Agreement represents the entire integrated agreement
between CITY and ARTS GROUP, and supersedes all prior negotiations, representations or
agreements, either written or oral. This Agreement may be amended only by a written
instrument signed by both parties. The parties anticipate that, in addition to this Agreement, they
will enter into an event agreement for each Beach Day setting forth precise terms and conditions
applicable to that Beach Day.
EXECUTED the day and year first above stated.
ARTS GROUP FOUNDATION
By: ____________________________________
Sam Perrotti, Arts Group of Hermosa Beach Representative
CITY OF HERMOSA BEACH
By: ___________________________________
Justin Massey, Mayor
APPROVED AS TO FORM ATTEST
By: _________________________________ By:_________________________________
Michael Jenkins, City Attorney City Clerk
EXHIBIT A – Special Event Permit
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Arts Group of Hermosa Beach Fine Arts Festival Agreement 2021 - 2023 7
CITY OF HERMOSA BEACH
SPECIAL EVENT PERMIT
I. Permit
CITY OF HERMOSA BEACH (“City”) hereby grants approval to the
______________ EVENT PLANNER”) for use of the ____________ (the
“SITE”) as the location for the _________________ (the “EVENT”).
The permission granted herein for conduct of the EVENT on the SITE, shall
commence from ________ and terminate at __________, including set up
and tear down, on _________________________.
This Permit is revocable at any time for violation of conditions of approval, the
Hermosa Beach Municipal Code or any applicable regulation or law.
II. Event Planner’s Obligations (checked boxes denote applicable obligations)
1. Not more than 60 days and not less than 30 days in advance of the
EVENT, EVENT PLANNER shall:
☐ a) Damage deposit: Post a bond, cashier's check or letter of credit, in
the amount of $_______________ as compensation for any damage that
may occur to physical property or other costs arising from EVENT
PLANNER’S use of the SITE. The bond or other surety shall provide that
in the event the EVENT PLANNER fails or refuses to clean up and restore
the SITE to its original condition or fails or refuses to compensate City for
other physical damage, City may, at its option, make demand upon the
surety for such cash payment as is required to perform such work.
☐ b) Insurance: Provide to City a policy of comprehensive general
liability insurance with a combined single limit of not less than
$2,000,000.00 per occurrence. Such insurance shall (a) name the City, its
appointed and elected officials, officers, employees and agents as
insured’s; and (b) be primary with respect to any insurance or self -
insurance programs maintained by the City; and (c) contain standard
cross-liability provisions. EVENT PLANNER shall furnish properly
executed certificates of insurance to City, which certificates shall clearly
evidence all coverage required above and provide that such insurance
shall not be materially changed, terminated or allowed to expire except on
thirty (30) days prior written notice to City; and further, shall provide that if
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Arts Group of Hermosa Beach Fine Arts Festival Agreement 2021 - 2023 8
the EVENT PLANNER fails to pay any required deductible or self -insured
retention, City may do so at EVENT PLANNER’s expense.
☐ c) Event fees: EVENT PLANNER shall tender any outstanding fees
associated with the City’s Special Event Application process a minimum of
30 days prior to the EVENT unless non-profit, per participant fees apply
for payment immediately following the event.
☒ d) Permits and approvals: EVENT PLANNER shall obtain all
necessary permits and approvals for the EVENT as set forth in the
completed Special Event Application or otherwise required by the City
(e.g., business license, street banner approval, light pole banner requests,
etc.).
☐ e) Provide City with the name and event day telephone number of its
designated representative for the event, and/or the names of designated
representatives who will be physically on the property for the entire
duration of the EVENT if different from that stated on the Special Event
Permit Application;
☐ f) Notify all residents and businesses within a 300 foot radius of the
SITE. The notice shall be in writing and shall include the date and time of
the EVENT, and the telephone number of the designated representative.
Said written notice shall be provided to the City through electronic copy
not less than 1 week prior to distribution for review and approval;
2. Commencing with the date and time this permit authorizes the use by the
EVENT PLANNER for the EVENT, EVENT PLANNER shall:
☐ a) Fence the entire EVENT area;
☐ b) Provide adequate portable restroom facilities for the EVENT
according to standards as outlined by City for Special Events;
☐ c) Provide adequate first aid facilities and staff;
☐ d) Secure its own telephones and telephone lines for the EVENT;
☐ e) Install a protective barrier around the perimeter of the EVENT not
later than _______________. EVENT PLANNER shall be responsible for
removal of the barrier upon completion of the EVENT. Said barrier(s)
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Arts Group of Hermosa Beach Fine Arts Festival Agreement 2021 - 2023 9
shall structurally and aesthetically fulfill the City’s requirements for said
barrier(s);
☐ f) Ensure that the EVENT includes adequate access and seating to
reasonably accommodate the needs of the disabled;
☐ g) Provide its staff and designated City representatives with proper
credentials and identification for access to the EVENT and SITE area;
☐ h) Clean, restore, resurface and make operational the SITE to the
satisfaction of the City (notwithstanding the clean-up activities described in
Section III.7) upon completion of the EVENT and no later than the post-
event walk-through (if applicable) described in Section III.9.;
☐ i) Maintain six (6) posted volleyball courts on the north side of the Pier for
recreational use;
☐ j) Install and maintain six (6) posted, temporary volleyball courts on the
south side of the Pier for recreational use.
☐ k) Pay to City the total sum of costs for all personnel, materials,
equipment, and disposal fees incurred by City in connection with SITE
preparation and clean-up activities and associated repairs described in
Section III.7., including overhead and indirect costs. Payment shall be
made within 60 days of receipt of invoice from City;
☐ h) DO NOT EXTEND PAST NOBLE PARK WITH ANY EVENT
RELATED
EQUIPMENT, SUPPLIES, OR SET UP.
3. Conduct the EVENT in accordance with all materials included in the complete
Special Event Application for the EVENT approved by the City, including but
not limited to the EVENT Site Plan, Parking Plan, Safety/Security Plan, Green
Matrix, and Accessibility Plan. If information on any Special Event Application
materials has changed from that which was approved by the City, EVENT
PLANNER shall notify the City within 24 hours of any such change.
4. EVENT PLANNER’s obligations shall be completed in the time periods set
forth above and notice of items not completed to City’s satisfaction shall be
given to EVENT PLANNER in writing. EVENT PLANNER shall have seven
days from receipt of notice to complete the obligation, except in the event of
an emergency. Any obligations not completed within the dates set forth
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Arts Group of Hermosa Beach Fine Arts Festival Agreement 2021 - 2023 10
above may be completed by City and EVENT PLANNER shall reimburse City
on a time and materials basis.
III. Services to be Provided by City
☐ 1. Representatives of the City, including any required police and fire
officials necessary to complete required inspections, and EVENT
PLANNER shall perform a walk-through of the SITE on
_______________, at which time the condition of the SITE shall be duly
noted in writing by said representatives, and shall specifically identify
any existing damage or other abnormalities and City shall repair
anything identified as a potential hazard or liability prior to EVENT
PLANNER taking possession of the SITE.
☐ 2. Facilitate closing of streets impacted by the SITE, including
_______________, during the hours of _______________.
☐ 3. Approve text of notices as required by Section II. f. above.
☐ 4. Provide, at no additional cost, the following:
a) _____ collection containers with a storage capacity of not less than
twenty-five (25) gallons each;
b) Collection vehicle and crew to empty the cans on the SITE;
c) Street sweepers.
☐ 5. Ensure that, to the best of the City’s knowledge, all other organized
activities will be excluded from the SITE during the EVENT.
☐ 6. Provide a 24-hour contact person who shall be available in the event of
emergency during the time EVENT PLANNER maintains possession of
the SITE.
☐ 7. Perform clean-up at cost to EVENT PLANNER as established in the
Special Event Permit Application for the EVENT, or in accordance with
actual cost if the amount of clean-up exceeds the EVENT fees, which
shall include but is not limited to:
☐ a. Removal and disposal from public property all no-parking signs, litter
and debris located at the SITE at cost to EVENT PLANNER;
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Arts Group of Hermosa Beach Fine Arts Festival Agreement 2021 - 2023 11
☐ b. Steam cleaning of sidewalks, garages and hardscape surfaces as
required at the SITE at cost to EVENT PLANNER;
☐ c. Repair of any irrigation damage to landscaped medians, planter
beds, lawn areas and the SITE grounds;
☐ d. Renovation of all turf and shrubs on landscaped medians, planter
beds, lawn areas on the SITE;
☐ e. Removal and disposal of trash receptacles placed on public areas of
the SITE;
☐ f. Restoration of all public areas impacted by the EVENT, including
public streets, to the same conditions prior to the EVENT.
8. The City shall submit itemized invoices to EVENT PLANNER for all work
described above within 90 days of the EVENT. Said invoices shall include an
itemized breakdown of costs associated with the cleanup of SITE. In
addition, the City will provide an itemized invoice listing all time and materials
used in the repair of City facilities.
9. Subsequent to the EVENT, and after EVENT PLANNER completed its
cleanup process of the premises, a post-event walk-through shall be
conducted by the representatives of the City and EVENT PLANNER, at which
time any damages or other abnormalities which may have arisen as a result
of the use of the premises by EVENT PLANNER shall be duly noted in writing
by said representatives, it being understood that the City (1) shall undertake
to repair and/or replace any damaged property; and (2) shall bill EVENT
PLANNER for the cost thereof. The foregoing notwithstanding, EVENT
PLANNER shall remain responsible for any later-discovered damage that was
not reasonably visible during the walk-through. Walk thru to be held no later
than _______________.
IV. Notices
All notices and communications shall be sent to the parties at the following
addresses:
The City of Hermosa Beach
1315 Valley Drive
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Arts Group of Hermosa Beach Fine Arts Festival Agreement 2021 - 2023 12
Hermosa Beach, CA 90254
V. Indemnification
EVENT PLANNER shall hold harmless, defend and indemnify the City and
County of Los Angeles, its officers, employees and volunteer from and against
any and all liability, loss, damage expense, and costs (including without limitation
costs and fees of litigation), of every nature arising out of or in connection with
production and performance of the EVENT or its failure to comply with any of its
obligations contained in this Permit except such loss or damage which was
caused by the sole negligence or willful misconduct of the City.
EVENT PLANNER shall pay promptly any judgment rendered against City and
County of Los Angeles, their respective officers, agents or employees, for any
such claims, damages, penalties, obligations and/or liabilities.
VI. Authority
The person executing this Permit for EVENT PLANNER certifies that s/he has full
authority to sign on behalf of EVENT PLANNER and to bind EVENT PLANNER
to the foregoing conditions.
VII. Revocation
EVENT PLANNER hereby accepts all of the foregoing conditions and
understands and acknowledges that City may revoke this permit at any time
upon finding that any of the foregoing conditions have not been satisfied.
EVENT PLANNER further acknowledges that this permit ma y be revoked and the
EVENT ordered concluded at any time during the course of the EVENT by the
highest ranking City police officer or fire personnel on duty at the time upon
determination that the EVENT is causing a violation of State law or upon a
determination that the EVENT has become a threat to public safety.
VIII. Miscellaneous Provisions
This permit is personal to the EVENT PLANNER and may not be transferred,
assigned or otherwise conveyed without the consent of the City.
Neither party will use the other party’s name, logos, trademarks or service marks
in any manner without the other party’s prior written approval.
This permit grants permission solely for the EVENT described above on the
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Arts Group of Hermosa Beach Fine Arts Festival Agreement 2021 - 2023 13
day(s) and time(s) indicated on the SITE.
Nothing in this permit shall be construed as creating a partnership, joint
enterprise or other contractual arrangement between City and EVENT
PLANNER. The EVENT is a privately sponsored event; it is not a City event and
is not sponsored by the City.
APPROVED BY:
City:
Signature
Date
Address: ____
Telephone No.
Applicant:
Signature
Event Representative
Print Name
Address
Telephone No
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Arts Group of Hermosa Beach Fine Arts Festival Agreement 2021 - 2023 14
EXHIBIT B – Event Barricades for Community Center North and East Lawn
94
City of Hermosa Beach
Staff Report
City Hall
1315 Valley Drive
Hermosa Beach, CA 90254
Staff Report
REPORT 21-0341
Honorable Mayor and Members of the Hermosa Beach City Council
Regular Meeting of June 8, 2021
APPROVAL OF THE PARKS, RECREATION AND COMMUNITY
RESOURCES ADVISORY COMMISSION’S RECOMMENDATION
TO APPROVE THE FIRST AMENDMENT TO AGREEMENT FOR USE OF THE HERMOSA BEACH
COMMUNITY CENTER GYMNASIUM BETWEEN THE CITY OF HERMOSA BEACH AND THE
HERMOSA BEACH YOUTH BASKETBALL LEAGUE
(Recreation Coordinator Nick Shattuck)
Recommended Action:
Staff recommends City Council:
1.Approve the Parks,Recreation and Community Resources Advisory Commission
recommendation to approve the first amendment to an Agreement for Use of the Hermosa
Beach Community Center Gymnasium between the City of Hermosa Beach and the Hermosa
Beach Youth Basketball League to allow temporary use of the Kelly Basketball Courts for
games during the 2021 Summer Season; and
2.Authorize the City Manager to execute and the City Clerk to attest the attached first
amendment subject to approval by the City Attorney (Attachment 3).
Background:
For over 30 years,the Hermosa Beach Youth Basketball League (HBYB)has managed and operated
a coed basketball league each winter,and select summers,for South Bay youth in grades
kindergarten through eighth.This league holds its games primarily at the Community Center
Gymnasium,with some practices held on outdoor basketball courts.The Valley School Gymnasium
and outdoor courts are also occasionally utilized for games and practices.Each season,the HBYB
league provides organized play for approximately 750 children.Most participants are Hermosa Beach
residents, with some residing in neighboring cities.
At its regular meeting on September 8,2020,the City Council approved a three-year agreement with
HBYB for use of the Community Center Gymnasium;classrooms in the Community Center;and
outdoor basketball courts for practices (Attachment 1).
Due to the COVID-19 Pandemic and the Los Angeles County Public Health restrictions on indoor
youth sports activities,HBYB cancelled its 2020-2021 Winter Season.Per the agreement,HBYB can
request use of facilities for a summer season.Details of the current agreement limits the league to
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Staff Report
REPORT 21-0341
request use of facilities for a summer season.Details of the current agreement limits the league to
use of the indoor Community Center Gymnasium for games and outdoor basketball courts for
practices.
Discussion:
On April 7,2021,staff received a proposal from HBYB to hold a Summer 2021 Season to utilize two
of the Kelly Basketball Courts for the purpose of games (Attachment 2).As the HBYB Agreement
does not allow for the use of the outdoor basketball courts for gameplay,staff initiated the first
amendment to the HBYB Agreement and submitted to the Parks,Recreation and Community
Resources Advisory Commission for approval.
At its May 4,2021 meeting,the Commission recommended for approval the first amendment to the
HBYB Agreement (Attachment 3)and recommended that it be forwarded to the City Council for final
approval.The proposed amendment would allow HBYB temporary use of the Kelly Basketball Courts
for gameplay during its Summer 2021 Season.Image 1 shows the location of the Kelly Basketball
Courts requested for gameplay.
Image 1: Kelly Basketball Courts
Staff recommends City Council approval of the proposed amendment for temporary use of the Kelly
Basketball Courts for games during the 2021 Summer Season.
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REPORT 21-0341
General Plan Consistency:
This report and associated recommendation have been evaluated for its consistency with the City’s
General Plan. Relevant policies are listed below:
Parks & Open Space Element
Goal 2. Abundant parks, open space, and recreational facilities to serve the community.
Policies:
·2.1 Diverse programs and facilities.Offer diverse recreational programs and facilities
to meet the needs of all residents.
Goal 3. Community parks and facilities encourage social activity and interaction.
Policies:
·3.5 Health and physical activity.Increase the availability of space and variety of
activities that promote community health and physical activity such as community gardens,
fitness stations/ equipment, and fields/courts.
Fiscal Impact:
The total revenue from the summer season cannot be estimated at this time.Per the Agreement,the
indoor hourly rental fees of $28 would be charged for the use of the Gymnasium,Kelly Basketball
Courts,and Classrooms at the Community Center.While unknown at this time,there would likely be
in-kind or monetary donations made at the conclusion of each season donated by HBYB for facility
enhancements or projects throughout the City that would benefit Hermosa Beach residents.
Attachments:
1.HBYB Agreement
2.HBYB Summer Season Proposal
3.First Amendment to HBYB Agreement
Respectfully Submitted by: Nick Shattuck, Recreation Coordinator
Noted for Fiscal Impact: Viki Copeland, Finance Director
Legal Review: Mike Jenkins, City Attorney
Approved: Suja Lowenthal, City Manager
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Agreement with HBYBL 2020 – 2023 1
AGREEMENT FOR USE OF THE HERMOSA BEACH COMMUNITY CENTER GYMNASIUM BETWEEN THE
CITY OF HERMOSA BEACH AND THE
HERMOSA BEACH YOUTH BASKETBALL LEAGUE
This Agreement for Use of the Hermosa Beach Community Center Gymnasium (hereinafter called ”Agreement”) is
made the _____ day of ____________, 2020 by and between the City of Hermosa Beach, a municipal corporation
(hereinafter called “City”) and Hermosa Beach Youth Basketball League, a California nonprofit public benefit
corporation (hereinafter called “HBYB”).
RECITALS
A. CITY is willing to make the Community Center Gymnasium; classrooms in the Community Center; and
outdoor basketball facilities available to HBYB for its annual youth basketball program pursuant to the terms
and conditions of this Agreement.
B. HBYB desires a commitment from CITY to secure the Community Center Gymnasium and outdoor
basketball facilities for practices and games in addition to classrooms in the Community Center, associated
with its youth basketball program.
NOW, THEREFORE, in consideration of the foregoing and the promises contained herein, the parties agree
as follows:
I. TERM AND PAYMENT.
a. ) The facilities described in Recital A are closed as of the execution date of this Agreement
due to the COVID-19 pandemic. The Term of this Agreement shall commence on a mutually agreed
upon date after CITY notifies HBYB in writing that the facilities described in Recital A are re-opened
for use (“Commencement Date”) and HBYB has been provided sufficient time to commence league
activities. The Term of this Agreement shall continue until the completion of the third summer league
held following the Commencement Date. HBYB is authorized use of the enumerated facilities for
both its winter (October – March) and summer (July) seasons during the term. HBYB may request
alternate season dates that extend beyond the traditional schedule not later than thirty (30) days
prior. Additional time is not guaranteed and will be based on availability. This Agreement may be
extended upon request by HBYB for two additional one-year terms in the exclusive discretion of the
City. CITY shall act on such extension requests not later than ninety (90) days following receipt of
HBYB’s Form 990 for the immediately preceding fiscal year, as provided in Section II(i) below. During
the term of this Agreement, CITY authorizes HBYB to use the Community Center Gymnasium,
designated outdoor basketball facilities and designated classrooms within the Community Center for
activities associated with regular league play as further set forth herein.
b. ) HBYB agrees to pay CITY at the rental amount of $28 per hour for use of the indoor facilities.
All rental payments shall be made to the CITY, at the agreed upon date.
II. HBYB RESPONSIBILITIES.
a. ) The HBYB League shall maintain its status as a non-profit organization.
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Agreement with HBYBL 2020 – 2023 2
b. ) HBYB will provide, at its expense, all League equipment. HBYB will set up/tear down within
the allocated rental times on a daily basis. HBYB shall have sole access to the storage room on the
west-side of the gymnasium, accessed from the interior of the gymnasium. Additionally, HBYB shall
set up said equipment in a cooperative and timely fashion, and at the daily close of League activities,
take down, remove and/or store its equipment. A designated HBYB representative must remain on-
site during the entire set-up and tear-down process and during all league activities. The parties agree
that, based on reasonable expectations, HBYB will rectify any outstanding “clean-up” deficiency.
c. ) HBYB shall provide all necessary funds, staff, equipment, and materials necessary to
adequately promote and seek sponsorship for the League at no expense to CITY. League banners,
flyers, promotional materials and other league related items may be installed on interior walls of the
gymnasium no earlier than two weeks prior to the start of each season. HBYB shall remove all
banners, flyers, promotional materials, and items relating to its league no more than two weeks
following the end of the season. Any banners or other sponsor items displayed on interior walls of
the gymnasium must be installed so as not to damage or permanently leave lasting marks on the
infrastructure of the building. If damage does occur during installation or removal, HBYB shall restore
the area to the reasonable satisfaction of the CITY.
d. ) HBYB shall provide a designated representative to consult as necessary with the Community
Resources Manager or CITY designee regarding all facets of League activities on city property. Final
decisions will be made by CITY regarding compliance with the agreement as well as any issues that
directly and/or adversely impact the community.
e.) HBYB, at its expense, shall provide for adequate trash removal. HBYB is required to clean
the Gymnasium, classrooms and outdoor basketball facilities on a daily basis when utilized by HBYB,
removing all trash associated with league activities. This includes, but is not limited to, sweeping
and mopping of the gymnasium floor, trash removal throughout the courtyard and personal item
removal from the gymnasium left behind from participants. HBYB shall store any collected personal
items in its storage room.
f.) HBYB shall provide a full schedule of all requested dates and times to the CITY no less than
thirty (30) days prior to the start of league activities.
g.) The CITY will allow HBYB usage of additional classrooms located at the Community Center
for League-related activities requested after the initial schedule of requested dates and times are
submitted. Additional rooms are not guaranteed and will be based on availabi lity. HBYB shall be
responsible to comply with payment of fees at $25 per hour associated with usage of additional
classrooms by the agreed upon due date.
h.) HBYB shall continue to enforce and implement the following requirements:
a. Maintain an expanded board that includes representatives from several community
organizations and community members directly associated with the league;
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Agreement with HBYBL 2020 – 2023 3
b. Maintain or enhance the current process for parent/guardian responses to issues or
concerns, including but not limited to providing signs, subject to CITY’s approval, with
conduct information visible in the gymnasium;
c. Pay a $750 refundable deposit at the start of the season for any damage or additional staff
time spent on behalf of the CITY as a result of league activities. In the event of damage or
CITY services that are in excess of the deposit, HBYB will be required to pay the difference
and replenish the deposit for the remainder of each season ;
d. Ensure the implementation of a mandatory coaches training program. Further, all new
coaches will be required to attend an on -site seminar, organized by HBYB each season.
Returning coaches may elect to take part in an online course, if available and provided by
the coaches training program, in lieu of attending the on-site seminar;
e. Continue to be proactive about civic and school district outreach for potential
assistance/donations;
f. Present league overview to the Parks, Recreation and Community Resources Advisory
Commission immediately following each season to provide updates and general financials
of the season.
g. Continue to manage the league purely on a volunteer basis (no stipends or salaries for Board
members or others) and contribute league revenues to the community or for the betterment
of the program.
h. HBYB shall ensure its bylaws are consistent with and include the following:
i. Sections that reference compensation to Board Members to further clarify that the
league is managed strictly on volunteerism;
ii. Term lengths of Board Members; and
iii. Loans to Officers.
i. HBYB shall provide CITY with its Form 990 for each fiscal year during the term of this
Agreement, or any extended term, commencing with the Form 990 for 2020, as soon as it is
available.
III. CITY RESPONSIBILITIES.
a. ) CITY shall permit HBYB to conduct the Hermosa Beach Youth Basketball League(s) in the
Community Center Gymnasium located at the Community Center, 710 Pier Avenue, Hermosa
Beach; designated outdoor basketball court for practices only; and designated classroom(s) in the
Community Center.
b. ) CITY shall provide a designated staff person as the assigned contact regarding the total
operation of League activities, especially in all matters pertaining to League liability and public safety.
All decisions of the CITY designee shall be final with respect to any issues that involve compliance
with this Agreement as well as any issues that directly and/or adversely impact the community. Said
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Agreement with HBYBL 2020 – 2023 4
CITY designee shall consult with a designated representative of HBYB and it shall be the goal of the
parties to reach mutual agreement on matters of League operation.
c. ) CITY shall provide to HBYB any CITY services required for the League such as police, fire,
building inspection, etc. as deemed necessary by the respective Chief or Department Head. Cost of
CITY personnel shall be assumed by HBYB.
d.) CITY shall manage the raising and lowering of the nets and will follow the schedule given to
staff at the start of each season. Changes to this schedule must be made in writing at least 48 hours
in advance.
IV. CARE AND MAINTENANCE OF PREMISES.
a.) HBYB acknowledges that, to the best of its knowledge, the premises are in good order and
repair as applicable to HBYB’s intended use of the premises. HBYB shall maintain the condition of
premises in good and safe conditions and shall surrender the same at termination
hereof, in as good condition as received, with normal wear and tear excepted.
b.) The CITY shall be responsible for the building maintenance and associated mechanical
repairs that are necessary to maintain the current condition of the p roperty. Should maintenance
be deemed necessary, it is the responsibility of the HBYB to contact the CITY immediately to report
the issue. The CITY acknowledges that the premises are in good order and repair with no known
risk to health or safety. The CITY is responsible for ADA compliance of the building.
c.) All City properties are smoke free facilities. With the exception of certified service animals,
no pets are allowed in the building.
d.) HBYB shall not, without first obtaining the written consent from the CITY, make any
alterations, additions, or improvements, in, to or about the premises. HBYB shall not be
responsible for any capital improvements which need to be made to the premises during the
course of this Agreement.
V. INSURANCE.
a. ) At least ten (10) days prior to the start of league activities at the Community Center, HBYB
shall provide CITY a Certificate of Insurance providing personal injury and property damage liability
insurance naming CITY, and County of Los Angeles, their officers, employees and agents as
additional insured with a minimum coverage of $2 million combined single limit coverage.
Insurance is to be placed with insurers with a current AM Best’s rating of no less than A:VII. Said
insurance shall not be canceled or altered without thirty (30) days’ notice in writing to CITY.
b. ) HBYB insurers shall be primarily responsible for any and all liability resulting from or arising
out of the performance of the contract and CITY and their insurers shall not be required to co ntribute.
c. ) For insurance purposes, the League area shall be defined to include any and all areas
occupied or affected by the League.
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Agreement with HBYBL 2020 – 2023 5
VI. INDEMNITY AND ASSUMPTION OF RISK.
a.) HBYB shall hold harmless, defend and indemnify the CITY, its officers, employees and
volunteers from and against any and all liability, loss, damage expense, and costs (including without
limitation costs and fees of litigation), of every nature arising out of or in connection with HBYB’s
League and performance of the League hereunder or its failure to comply with any of its obligations
contained in this Agreement except such loss or damage which was caused by the sole negligence
or willful misconduct of the CITY. The CITY shall indemnify HBYB from and against any and all
liability, loss, damage, expense, and costs (including without limitation costs and fees of litigation),
of every nature arising out of or in connection with the sole negligence or willful misconduct of the
CITY.
b.) By signing this agreement, HBYB acknowledges the contagious nature of COVID-19 and
voluntarily assume the risk that league participants and their families, league administrators, league
officials, and contractors of the league (“program participants”) may be exposed to or infected by
COVID-19 by using the facilities described in Recital A, and that such exposure or infection may
result in personal injury, illness, permanent disability, and death. HBYB understand that the risk of
becoming exposed to or infected by COVID-19 at the facilities described in Recital A may result from
the actions, omissions, or negligence of program participants and others, including, but not limited
to, City of Hermosa Beach employees, officials and agents.
c.) HBYB assumes all risks of damages and injury to program participants and others arising
out of or attributable to its use of the facilities described in Recital A during the COVID-19 pandemic.
HBYB hereby releases and discharges the City of Hermosa Beach and its officers, employees and
agents, from any and all claims for losses, injuries, damages or liabilities, including personal injury
and injury to personal property arising out of or attributable to its use of the facilities described in
Recital A during the COVID-19 pandemic, and HBYB expressly releases the City of Hermosa Beach
and its officers, employees and agents from and against any and all claims or liability arising from
their negligence. HBYB voluntarily agrees to assume all of the foregoing risks and accepts sole
responsibility for any injury to program participants including, but not limited to, personal injury,
disability, and death, illness, damage, loss, claim, liability, or expense, of any kind, that may be
experienced or incurred in connection with use of the facilities described in Recital A. HBYB hereby
releases, covenants not to sue, discharges, and holds harmless the City of Hermosa Beach, its
employees, officers, and agents, of and from all liabilities, claims, actions, damages, costs or
expenses of any kind arising out of or relating thereto. HBYB understands and agrees that this
release includes any claims based on the actions, omissions, or negligence of the City of Hermosa
Beach, its employees, officers and agents, whether a COVID-19 infection occurs before, during, or
after use of the facilities described in Recital A.
VII. ADVERTISING.
a. ) All sponsor signs, props, product facsimiles, etc. deemed necessary by HBYB to identify the
League, shall be approved as to location and content by CITY.
b.) As stated in section 2c, these items must be removed at the conclusion of each season.
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Agreement with HBYBL 2020 – 2023 6
VIII. CONCESSIONS.
a. ) HBYB is not permitted to sell, serve, or distribute food or drink items (excluding water) in the
gymnasium. HBYB agrees to make every effort to ensure League participants do not bring food or
drink items into the Gymnasium for League activities.
VIII. INDEPENDENT CONTRACTOR.
CITY and HBYB shall each be and act as independent contractors and under no circumstances shall
this agreement be construed as one of agency or partnership between CITY and HBYB. Each party
acknowledges and agrees that it neither has nor will give the appearance or imp ression of having
any legal authority to bind or commit the other party in any way other than as authorized by this
Agreement. Nothing in this Agreement shall be construed to create a joint venture between the
parties hereto or to obligate either party fo r debts or obligations incurred by the other party in the
performance of this Agreement.
IX. COMPLIANCE WITH THE LAW.
Should it be determined that this Agreement or any provision hereof violates any federal, state, or
local law or regulation, then the parties shall promptly modify this Agreement to the extent necessary
to bring about compliance with such law and/or regulation; provided, however, that if such
modification would cause this Agreement to fail in its essential purpose or purposes, it shall be
deemed cancelled by mutual agreement of the parties and neither party shall have any further
obligations or liabilities with respect to this Agreement.
X. RESERVATION OF RIGHTS BY CITY.
CITY reserves the right in its sole discretion at any time or times to close and suspend the use of the
facilities subject to this Agreement for any duration in order to protect public health and safety. Any
such closure will not constitute a breach or a default of this Agreement. CITY shall have no liability
whatever to HBYB for the effect of such suspension and closure on its program, nor shall CITY have
any responsibility to provide HBYB with substitute facilities. HBYB’s rights under this Agreement a re
subject and subordinate to CITY’s police and emergency powers in addition to CITY’s rights to
manage its municipal facilities and its contractual rights as described in this Agreement.
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Agreement with HBYBL 2020 – 2023 7
XI. ENTIRE AGREEMENT.
This Agreement constitutes the entire understanding between the parties with respect to the subject
matter hereof and supersedes any and all prior understandings or agreements in regard hereto. This
Agreement cannot be altered or modified except by an agreement in writing signed by both parties.
CITY OF HERMOSA BEACH
Mayor, Mary Campbell City Manager, Suja Lowenthal
ATTEST APPROVED AS TO FORM
City Clerk, Eduardo Sarmiento City Attorney, Michael Jenkins
HBYB
________________________________
HBYB Representative (name) HBYB Representative (signature)
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Brian Pettigrew
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Summer Season
Planning
2021
105
Goal
HBYB was not able to hold a Winter or Spring season for 2021, so we are looking
to create a Summer season.
There is high demand and interest from the community and parents want their kids
to get back to playing basketball again as soon as it is safe and allowable.
HBYB wants to be in the position to help our parents by being there for their kids
this summer.
2106
Type of Season
With Covid-19 numbers dropping and vaccinations increasing daily, we believe we
will be able to run a season with games this summer. That’s our goal. Whether
those games are outside, inside, or both we are planning to play with Covid-19
precautions such as masks, hand sanitizing stations, etc. as appropriate.
We are 100% aware that the Covid-19 situation could change for the worse
between now and then, but we remain positive that the future holds good news.
3107
Season Schedule
Open Registration: May 10th
Close Registration: June 21st
Season Start: July 6th
Season End Date: August 15th
4108
Courts Requested
There are two possibilities in terms of what courts we would be requesting
depending on whether we can play indoors, or are relegated to outdoors only.
Indoor Allowed:
Community Center Court
Clark Courts (at least 1)
(Valley School courts, indoor and outdoor will also be requested from school board)
Outdoor Only:
Clark Courts (both)
Edith Rodaway Courts (both)
(We would request outdoor courts at Valley School as well)
5109
Game Play Time Slots
Days of the Week:
7 days a week
Times:
Weekdays - 4pm start, 9pm finish
Weekends - 9am start, 8pm finish
We would not need the courts for all of those times, and would schedule
accordingly based on registration and the number of teams we have.
6110
Community Interest
In a survey we ran in the Fall of 2020 we had over 400 kids who were interested in
a Summer season if we were not able to do a Winter/Spring season. Since then
our pre-registration that we ran last fall and continue to leave open continues to
grow and is beyond 600 participants. While we don’t expect all of those
pre-registered to participate in Summer, it shows an incredible desire and interest
to get back out on the courts.
In order to help us meet the demand and interest of the parents we hope that the
City of Hermosa Beach will work with HBYB to create a fantastic summer season
that kids will get kids back on the courts playing the sport they love.
7111
THANK YOU!
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HBYB Agreement – First Amendment - page 1
FIRST AMENDMENT TO AGREEMENT FOR USE OF THE HERMOSA BEACH
COMMUNITY CENTER GYMNASIUM BETWEEN THE CITY OF HERMOSA
BEACH AND THE HERMOSA BEACH YOUTH BASKETBALL LEAGUE
This First Amendment to Agreement for Use of the Hermosa Beach Community Center
Gymnasium Between the City of Hermosa Beach and the Hermosa Beach Youth Basketball
League (“First Amendment”) is entered into by and between the City of Hermosa Beach, a
municipal corporation (“City”) and the Hermosa Beach Youth Basketball League (“HBYB”) as
of May 5 _____, 2021.
RECITALS
A. CITY and HBYB are parties to the three-year agreement, made the 8th day of September,
2020, between City of Hermosa Beach and Hermosa Beach Youth Basketball League
which allows HBYB the use of the Community Center Gymnasium; classrooms in the
Community Center; and outdoor basketball facilities for practice.
B. The parties desire to amend the agreement to allow HBYB the temporary use of Kelly
Basketball Courts for gameplay during their Summer 2021 Season.
NOW, THEREFORE, in consideration of the foregoing, the agreement is amended as
follows:
1. Section 3(a) is amended to read as follows:
CITY shall permit HBYB to conduct the Hermosa Beach Youth
Basketball League(s) in the Community Center Gymnasium located at the
Community Center, 710 Pier Avenue, Hermosa Beach; designated outdoor
basketball court for practices only; and designated classroom(s) in the
Community Center. This specific amendment provides allowances for
HBYB the temporary use of the two (2) outdoor Kelly courts for games,
during the Summer of 2021 season only at the same hourly fee identified
within the existing agreement.
Except as above modified, in all other respects the agreement is hereby reaffirmed in full
force and effect.
[Signatures on the following page.]
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HBYB Agreement – First Amendment - page 2
HERMOSA BEACH YOUTH BASKETBALL
LEAGUE
HBYB, President
CITY OF HERMOSA BEACH
By
CITY MANAGER, Suja Lowenthal
ATTEST:
CITY CLERK, Eduardo Sarmiento
114
City of Hermosa Beach
Staff Report
City Hall
1315 Valley Drive
Hermosa Beach, CA 90254
Staff Report
REPORT 21-0340
Honorable Mayor and Members of the Hermosa Beach City Council
Regular Meeting of June 8, 2021
HERMOSA BEACH LANDSCAPING AND STREET LIGHTING
DISTRICT 2021-2022 ADOPTION OF RESOLUTIONS REGARDING
THE ENGINEER’S REPORT AND SETTING JULY 13, 2021
FOR A PUBLIC HEARING
(Interim Public Works Director Angela Crespi)
Recommended Action:
Staff recommends City Council:
1.Adopt the attached Resolution approving the Engineer's Report in connection with Hermosa
Beach Landscaping and Street Lighting District 2021-2022 (District)made pursuant to the
requirements of Resolution No. 21-7278; and
2.Adopt the attached Resolution declaring the City’s intention to order certain improvements and
to levy and collect assessments within the Hermosa Beach Landscaping and Street Lighting
District 2021-2022 for the Fiscal Year beginning July 1,2021 through June 30,2022,and
appointing July 13,2021,at the hour of 6:30 p.m.in the Civic Center Council Chambers as the
time and place for a public hearing in relation thereto.
Executive Summary:
The Hermosa Beach Landscaping and Street Lighting District partially funds the maintenance and
operation of the citywide street lighting program and landscaping within street medians and
parkways.The Landscaping and Street Lighting District must be renewed annually by following a
three-step process. Staff recommends continuation of the process for Fiscal Year 2021-2022.
Background:
The Hermosa Beach Landscaping and Street Lighting District (District)was created in Fiscal Year
1989-1990,according to the Landscaping and Lighting Act of 1972 and pursuant to Street and
Highway Code Sections 22500-22679.The District assessment provides funding to maintain and
operate streetlights,traffic signals,and landscaping located within parkways and medians citywide.
The assessment rate has not increased since the passage of Proposition 218 in 1996 and is set at
$41.45 per dwelling unit.
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The anticipated assessment to be collected for Fiscal Year 2020-2021 is $453,000;an additional
$291,002 is needed to subsidize the Landscaping and Street Lighting District Fund to maintain the
citywide Landscaping and Street Lighting District for Fiscal Year 2020-2021.Typically,the difference
between what is collected through the assessment and what is need in a fiscal year is subsidized by
the General Fund.
The District must be renewed annually by following a three-step process.First,Council authorizes
the Director of Public Works to prepare an Engineer’s Report containing the estimated cost of
maintaining the District,the list of parcels within the District,and the method of apportionment of the
assessment.Second,the Engineer’s Report is presented to Council for approval and to set a date for
a Public Hearing declaring the City Council’s intention to order certain improvements and to levy and
collect assessments within the District for the new fiscal year.The third and final step is to hold a
Public Hearing to accept public input on the matter of the proposed assessment and,if approved,to
levy the assessment for the new fiscal year.
Analysis:
Based on the advice of the City Attorney,the City is in compliance with Proposition 218 and can
continue to levy assessments to pay for the maintenance and operation of streetlights,street
medians,and parkway landscaping without balloting requirements so long as the assessments are
not increased.The assessment rate per dwelling unit has not increased since the passage of
Proposition 218 in 1996.
By approving the first attached Resolution (Attachment 1),City Council approves the Engineer’s
Report,prepared by the Deputy City Engineer acting as the Assessment Engineer.This report
contains maps,methodology,costs,and estimated assessments for the District and is on file in the
office of the City Clerk.Adoption of the proposed Resolution confirms that the report has been
prepared prior to the Public Hearing.
By approving the second attached Resolution (Attachment 2),City Council sets July 13,2021,at the
hour of 6:30 p.m.in the Civic Center Council Chambers as the time and place for a Public Hearing in
order to accept input on the report.
In order to levy and collect assessments within the Hermosa Beach Landscaping and Street Lighting
District 2021-2022, the City Council must also:
1.Hold a Public Hearing and adopt a Resolution confirming the map and assessment for the
District for Fiscal Year 2021-2022 and levy the set assessment per-unit rate for the fiscal year
commencing July 1, 2021 and ending June 30, 2022; and
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2. Adopt the Fiscal Year 2021-2022 estimated revenue for secured collections for the District.
Past Council Actions
Meeting Date Description
April 13, 2021
City Council adopted Resolution 21-7278 authorizing the preparation of a
report for the annual levy of assessments within the Hermosa Beach
Landscaping and Street Lighting District during Fiscal Year 2021-2022
General Plan Consistency:
This report and associated recommendation have been evaluated for their consistency with the City’s
General Plan. Relevant Policies are listed below:
Mobility Element
Goal 2.A public realm that is safe,comfortable,and convenient for travel via foot,bicycle,public
transit,and automobile and creates vibrant,people oriented public spaces that encourage active
living.
Policies:
·2.1 Prioritize public right-of-ways.Prioritize improvements of public right-of-ways that provide
heightened levels of safe,comfortable and attractive public spaces for all non-motorized
travelers while balancing the needs of efficient vehicular circulation.
·2.4 Sustainable landscape.Use consistent and sustainable landscape and streetscape
designs that reflect the city’s community identity;showcase local assets and the community’s
unique and vibrant culture.
Parks + Open Space Element
Goal 10. Abundant landscaping, trees, and green space provided throughout the community.
Policies:
·10.3 Green space co-benefits.Recognize the many positive qualities provided by
landscaping,trees,and green space including reduced heat gain,controlled stormwater
runoff,absorbed noise,reduced soil erosion,improved aesthetic character,and absorption of
air pollution.
Infrastructure Element
Goal 1. Infrastructure systems are functional, safe, and well maintained.
Policies:
·1.1 Infrastructure systems plan.Establish and adopt an integrated,holistic systems approach
to guide infrastructure development, improvement, maintenance, and resilience.
·1.4 Fair share assessments.Require new development and redevelopment projects to pay
their fair share of the cost of infrastructure improvements needed to serve the project and
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ensure that needed infrastructure is available prior to or at the time of project completion.
Fiscal Impact:
The anticipated assessment to be collected for Fiscal Year 2021-2022 is $454,285.Staff
recommends in the FY2021-2022 Budget that an additional $229,790 be transferred from the RTI
Undersea Cable Fund (rather than the General Fund)to the Landscaping and Street Lighting District
Fund to maintain the citywide Landscaping and Street Lighting District for Fiscal Year 2021-2022.
Attachments:
1.Resolution approving the Engineer's Report in connection with Hermosa Beach Landscaping
and Street Lighting District 2021-2022
2.Resolution declaring the City’s intention to order certain improvements and to levy and collect
assessments within the Hermosa Beach Landscaping and Street Lighting District 2021-2022
for the Fiscal Year beginning July 1, 2021 through June 30, 2022, and appointing a time and
place for a Public Hearing in Relation Thereto
Respectfully Submitted by: Andrew Nguyen, Assistant Engineer
Concur: Lucho Rodriguez, Deputy City Engineer
Concur: Angela Crespi, Interim Public Works Director
Noted for Fiscal Impact: Viki Copeland, Finance Director
Legal Review: Mike Jenkins, City Attorney
Approved: Suja Lowenthal, City Manager
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Page 1 of 2 20-XXXX
1
RESOLUTION NO. 20-XXXX 2
3
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF HERMOSA BEACH, 4
CALIFORNIA, APPROVING THE ENGINEER’S REPORT IN CONNECTION WITH 5
HERMOSA BEACH LANDSCAPING AND STREET LIGHTING DISTRICT 2021-2022 6
7
HERMOSA BEACH LANDSCAPING AND STREET LIGHTING DISTRICT 2021-2022 8
WHEREAS, the City Council of the City of Hermosa Beach, California, by its Resolution 9
No. 20-7278, adopted April 13, 2021, ordered the Director of Public Works to prepare and file a 10
report in accordance with Article 4 of Chapter 1 of the Landscaping and Lighting Act of 1972, Part 11
2 of Division 15 (Section 22500, et seq.) of the Streets and Highways Code of the State of California, 12
in connection with the proposed maintenance and operation of streets and sidewalks within an 13
existing assessment district to be designated as the “Hermosa Beach Landscaping and Street 14
Lighting District 2021-2022”, including the operation, maintenance and servicing of landscaping, 15
lighting and appurtenant facilities located in and along such streets and sidewalks for the fiscal year 16
commencing July 1, 2021 and ending June 30, 2022; and 17
WHEREAS, under the direction of the Director of Public Works, the Deputy City Engineer, 18
acting as the Assessment Engineer, prepared and filed in the office of the City Clerk a written report 19
in accordance with Article 4 of Chapter 1 of the Landscaping and Lighting Act of 1972; and 20
WHEREAS, the City Clerk presented the report of the Deputy City Engineer to the City 21
Council, and the City Council carefully examined, inspected and considered the report and is 22
satisfied with the report and with each and all of the items set forth therein. 23
24
NOW THEREFORE, THE CITY COUNCIL OF THE CITY OF HERMOSA 25
BEACH, CALIFORNIA, DOES HEREBY RESOLVE AS FOLLOWS: 26
SECTION 1. The report of the Deputy City Engineer entitled “Engineer’s Report, Hermosa 27
Beach Landscaping and Street Lighting District 2021-2022,” which was prepared and filed pursuant 28
to the provisions of the Landscaping and Lighting Act of 1972, Part 2 of Division 15 (Section 22500, 29
et seq.) of the Streets and Highways Code of the State of California, is hereby approved as filed. 30
119
Page 2 of 2 20-XXXX
SECTION 2. This Resolution shall take effect immediately. The City Clerk shall certify to 31
the passage and adoption of this Resolution, shall cause the original of the same to be entered among 32
the original resolutions of the City Council, and shall make a minute of the passage and adoption 33
thereof in the minutes of the City Council meeting at which the same is passed and adopted. 34
35
36
PASSED, APPROVED AND ADOPTED this 8th day of June, 2021. 37
38
________________________________________________________________________ 39
PRESIDENT of the City Council and MAYOR of the City of Hermosa Beach, California 40
41
42
43
ATTEST: APPROVED AS TO FORM: 44
45
46
__________________________ __________________________ 47
City Clerk City Attorney 48
49
50
120
ATTACHMENT 1
ENGINEER’S REPORT
CITY OF HERMOSA BEACH
LANDSCAPING AND
STREET LIGHTING DISTRICT
2021-2022
121
ENGINEER'S REPORT
CITY OF HERMOSA BEACH
LANDSCAPING AND
STREET LIGHTING DISTRICT
2021-2022
Prepared By:
Andrew Nguyen
Assistant Engineer
Lucho Rodriguez, P.E.
Deputy City Engineer
May 27, 2021
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ENGINEER'S REPORT
CITY OF HERMOSA BEACH
LANDSCAPING AND STREET LIGHTING DISTRICT 2021-2022
TABLE OF CONTENTS
Certificate .................................................................................................. 1
Report ........................................................................................................ 2
Part A - Plans and Specifications ................................................... 4
Part B - Estimate of Cost ................................................................ 5
Part C - Assessment Roll ............................................................... 6
Part D - Method of Apportionment of Assessment .......................... 7
Part E - Property Owner List ........................................................... 9
Part F - Assessment District Boundary ........................................... 10
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FISCAL YEAR 2021-2022
CITY OF HERMOSA BEACH
ENGINEER'S REPORT PREPARED PURSUANT TO THE PROVISIONS OF THE
LANDSCAPING AND LIGHTING ACT OF 1972, SECTION 22500 THROUGH
22679, OF THE CALIFORNIA STREETS AND HIGHWAYS CODE
Pursuant to Part 2 of Division 15 of the Streets and Highways Code of the State of California,
and in accordance with the Resolution of Initiation adopted by the Council of the City of
Hermosa Beach, State of California, in connection with the proceedings for:
HERMOSA BEACH
LANDSCAPING AND STREET LIGHTING DISTRICT 2021-2022
Hereinafter referred to as the "Assessment District" or "District", Lucho Rodriguez, Deputy City
Engineer, the duly appointed ENGINEER OF WORK, submit herewith the "Report" consisting of
six (6) parts as follows:
PART A
Plans and specifications for the improvements showing and describing the general nature,
location and extent of the improvements.
PART B
An estimate of the cost of the proposed improvements for FY 2021-2022, including incidental
costs and expenses in connection therewith.
PART C
An assessment of the estimated cost of the improvements on each benefited lot or parcel of
land within the Assessment District.
PART D
The method of apportionment of assessments, indicating the proposed assessment of the total
amount of the costs and expenses of the improvements upon the several lots and parcels of
land within the Assessment District, in proportion to the estimated benefits to be received by
such lots and parcels.
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PART E
A list of the names and addresses of the owners of real property within the Assessment District,
as shown on the last equalized roll of the Assessor of the County of Los Angeles.
PART F
The Diagram of the Assessment District Boundaries showing the exterior boundaries of the
Assessment District, the boundaries of any zones within the Assessment District and the lines
and dimensions of each lot or parcel of land within the Assessment District.
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PART A
PLANS AND SPECIFICATIONS
The facilities, which have been constructed within the City of Hermosa Beach, and those which
may be subsequently constructed, will be operated, serviced and maintained as generally
described as follows:
DESCRIPTION OF IMPROVEMENTS
FOR THE HERMOSA BEACH
LANDSCAPING AND STREET LIGHTING DISTRICT 2021-2022
The proposed improvements for FY 2021-2022 may be generally described as the continued
maintenance and operation of streets and sidewalks within the District, including the operation,
servicing and maintenance of landscaping, lighting and appurtenant facilities that are located in
and along such streets and sidewalks, including but not limited to, personnel, electrical energy,
utilities such as water, materials, contracting services, and other items necessary for the
satisfactory operation of these services described as follows:
Street Landscaping and Appurtenant Facilities
Landscaping, planting, shrubbery, trees and appurtenant facilities, including irrigation systems,
hardscapes and fixtures in public street and sidewalk rights-of-way, including parkways and
medians, within the boundaries of the Assessment District.
Street Lighting and Appurtenant Facilities
Poles, fixtures, bulbs, conduits, equipment including guys, anchors, posts and pedestals,
metering devices and appurtenant facilities as required to provide street lighting and traffic
signals in public street and sidewalk rights-of-way, including parkways and medians, within the
boundaries of the Assessment District.
Maintenance means the furnishing of services and materials for the ordinary and usual
maintenance, operation and servicing of the landscaping, lighting facilities and appurtenant
facilities, including repair, removal or replacement of all or part of any of the landscaping,
lighting facilities or appurtenant facilities; providing for the life, growth, health and beauty of the
landscaping, including cultivation, irrigation, trimming, spraying, fertilizing and treating for
disease or injury; the removal of trimmings, rubbish, debris and other solid waste; and the
cleaning, sandblasting, and painting of walls and other improvements to remove or cover graffiti.
Servicing means the furnishing of water for the irrigation of the landscaping and the
maintenance of any of the lighting facilities or appurtenant facilities and the furnishing of electric
current or energy, gas or other illuminating agent for the lighting facilities, or for the lighting or
operation of the landscaping or appurtenant facilities.
The plans and specifications for the improvements, showing and describing the general nature,
location, and the extent of the improvements, are on file in the office of the City Clerk and are
incorporated herein by reference.
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PART B
ESTIMATE OF COSTS
LANDSCAPING AND STREET LIGHTING DISTRICT
Proposed Budget - Fiscal Year 2021-2022
The estimated cost of the operation, servicing and maintenance of the street and sidewalk
improvements for fiscal year 2021-2022, as described in Part A, are summarized herein and described
below.
Lighting and Landscaping Maintenance and Servicing
•Median & Pkwy Landscaping Maintenance and Servicing
•Lighting Maintenance and Servicing
•Tree Trimming $536,140
Administration Costs $11,054
Insurance $152,480
L.A. County Tax Collection Costs $2,000
Equipment Replacement $52,712
Proposed Capital Improvements $0
Expenditures Subtotal: $754,386
Appropriation from Fund balance $70,120
Amount transferred from Tyco Fund $229,790
Miscellaneous Revenues $191
Total Assessment: $454,285
Fund Balance 6/30/22 $0
Total amount of $291,002 was transferred from the General Fund in FY 20-21. An
additional amount of $229,790 will be transferred from the RTI Fund to maintain the
District for FY 21-22.
The 1972 Act requires that a special fund be set up for the revenues and expenditures of the
District. Funds raised by assessment shall be used only for the purpose as stated herein. A
contribution to the District by the City may be made to reduce assessments, as the City Council
deems appropriate. Any balance or deficit remaining on July 1 must be carried over to the next
fiscal year.
Note: Total cost of the operation, servicing and maintenance of the Landscaping and Street
Lighting District 2021-2022 is estimated to be $754,386.
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PART C
ASSESSMENT ROLL
The total proposed assessment for Fiscal Year 2021-2022 and the amount of the total proposed
assessment apportioned to each lot or parcel within the District, as shown on the latest
assessment roll at the Los Angeles County Assessor's Office, are contained in the Assessment
Roll on file in the office of the City Clerk of the City of Hermosa Beach, which is incorporated
herein by reference.
The description of each lot or parcel is part of the Los Angeles County assessment roll and this
roll is, by reference, made part of this Report.
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PART D
METHOD OF APPORTIONMENT OF ASSESSMENT
GENERAL
Part 2, of Division 15, of the Streets and Highways Code, the Landscaping and Lighting Act of
1972, permits the establishment of assessment districts by cities for the purpose of providing
certain public improvements which include operation, maintenance and servicing of street lights,
traffic signals and landscaping.
The 1972 Act requires that maintenance assessments be levied according to benefit rather than
according to assessed value. Section 22573 provides that:
“The net amount to be assessed upon lands within an assessment district
may be apportioned by any formula or method which fairly distributes the
net amount among all assessable lots or parcels in proportion to the
estimated benefits to be received by each such lot or parcel from the
improvements.”
The Act permits the designation of zones of benefit within any individual assessment district if
"by reason of variations in the nature, location, and extent of the improvements, the various
areas will receive different degrees of benefit from the improvements" (Sec. 22574) Thus, the
1972 Act requires the levy of a true "benefit assessment" rather than a "special tax."
Exempted from the assessment would be the areas of all publicly owned property in use in the
performance of a public function. Railroad and utility rights-of-way are also exempt from
assessment.
BENEFIT ANALYSIS
• Street Lighting and Traffic Signals - The proper functioning of street lighting and traffic
signals is imperative for the welfare and safety of the public and property throughout the
City. Proper operation, maintenance and servicing of the street lighting system benefits
properties within the District by providing proper illumination for ingress and egress and safe
traveling at night. Properties within the District also benefit from the proper functioning of
the District's traffic signal system. Proper operation of the streetlight and traffic signal
systems is imperative to public convenience, orderly traffic flow, enhanced congestion
management and safety. Improved security, fuel conservation, protection of property from
crime and vandalism, and reduction of traffic accidents, are special and direct benefits to all
properties within the City; lighting benefits are directly related to public safety and property
protection and therefore increase property values.
• Median and Parkway Landscaping and Tree Trimming - Trees, landscaping, hardscaping
and appurtenant facilities, if well maintained, provide beautification, shade and
enhancement of the desirability of the surroundings, and therefore increase property value.
The City maintains trees and miscellaneous shrubbery and landscaping throughout the City.
The trees, shrubbery and landscaping are located within the public street and sidewalk rights-of-
way, including parkways and medians. These trees, shrubbery and landscaping provide an
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aesthetically pleasing environment, shade, beautification, and, according to some authorities, air
purification and sound attenuation. These positive attributes increase the value of all properties
throughout the City.
Therefore, all property within the District receive an overall specific and direct benefit from the
maintenance and servicing of the street median and parkway landscaping and street tree
trimming programs.
Special benefits which are received by all parcels in the City are considered to be City-wide
Benefits, and the associated costs of these special benefits are spread equally, based on
Equivalent Dwelling Units, to all parcels within the District. All properties in the District benefit
from the operation, maintenance and servicing of the street lighting, traffic signals, street
median and parkway landscaping and street tree trimming.
The degree of benefit to each parcel of land varies depending on its land use and the size of the
parcel. If assessments were spread on an individual parcel basis, not considering land use or
parcel size, it would not be an equitable method of spread because a single family parcel would
pay the same assessment as a 50-unit apartment parcel or a large commercial parcel.
Therefore, the method for spreading the improvement costs, which must be based on special
and direct benefit, is on an Equivalent Dwelling Unit (EDU) basis. The EDU method uses the
residential dwelling unit as the basic unit and compares other uses to it, as follows:
• Residential parcels are assessed based on the number of dwelling units on each parcel,
where each residential dwelling unit equals one EDU
• Non-residential parcels have been converted into EDU'S, based on engineering judgment
taking into consideration the size of the parcel and the amount of frontage along the street.
Every parcel is assessed a minimum of one (1) EDU.
There are a total of 11,045 EDU's within the Assessment District.
ASSESSMENT RATE CALCULATION
Based on a budget of $457,285 as shown in Part B of this report, the preliminary assessment
rate for FY 2021-2022 is calculated as follows:
$457,285÷11,032 EDU's = $41.45 per EDU
The assessment for FY 2020-2021 was $41.45 per EDU.
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PART E
PROPERTY OWNER LIST
A list of names and addresses of the owners of all parcels within this District is shown on the
last equalized Property Tax Roll of the Assessor of the County of Los Angeles, which by
reference is hereby made a part of this report. This list is keyed to the Assessor's Parcel
Numbers as shown on the Assessment Roll on file in the office of the City Clerk of the City of
Hermosa Beach.
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PART F
ASSESSMENT DISTRICT BOUNDARY
The boundaries of the District are coterminous with the boundaries of the City of Hermosa
Beach. A diagram showing the exterior boundaries of the District, the boundaries of any zones
within the District, and the lines and dimensions of each lot or parcel of land within the District is
on file in the office of the City Clerk of the City of Hermosa Beach, and is incorporated herein by
reference. The lines and dimensions of each lot or parcel within the District are those lines and
dimensions shown on the maps of the Assessor of the County of Los Angeles for fiscal year
2020-2021. The Assessor's maps and records are incorporated by reference herein and made
part of this report.
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2021-2022
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Page 1 of 3 20-XXXX
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RESOLUTION NO. 20-XXXX 2
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A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF HERMOSA BEACH, 4
CALIFORNIA, DECLARING ITS INTENTION TO ORDER CERTAIN IMPROVEMENTS 5
AND TO LEVY AND COLLECT ASSESSMENTS WITHIN THE HERMOSA BEACH 6
LANDSCAPING AND STREET LIGHTING DISTRICT 2021-2022 FOR THE FISCAL 7
YEAR BEGINNING JULY 1, 2021 AND ENDING JUNE 30, 2022, AND APPOINTING A 8
TIME AND PLACE FOR A PUBLIC HEARING IN RELATION THERETO 9
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NOW THEREFORE, THE CITY COUNCIL OF THE CITY OF HERMOSA 11
BEACH, CALIFORNIA, DOES HEREBY RESOLVE AS FOLLOWS: 12
SECTION 1. The public interest and convenience require, and it is the intention of the City 13
Council of the City of Hermosa Beach, California, to order certain improvements within an existing 14
citywide assessment district for the fiscal year beginning July 1, 2021 and ending June 30, 2022, 15
and to levy and collect assessments against properties within the assessment district for that fiscal 16
year. 17
SECTION 2. The proposed improvements are the continued maintenance and operation of 18
the streets and sidewalks within the assessment district including the operation, servicing and 19
maintenance of landscaping, lighting and appurtenant facilities that are located in and along such 20
streets and sidewalks. 21
SECTION 3. The assessment district is designated as the “Hermosa Beach Landscaping 22
and Street Lighting District 2021-2022.” The assessment district is comprised of all of the City of 23
Hermosa Beach, as shown in the Engineer’s Report and on the “MAP OF LANDSCAPING AND 24
STREET LIGHTING DISTRICT 2021-2022” on file in the Office of the City Clerk. 25
SECTION 4. The assessments to be levied and collected against the assessable lots and 26
parcels of land within the assessment district for fiscal year 2021-2022 are not proposed to increase 27
from those levied and collected in fiscal year 2020-2021. 28
SECTION 5. Reference is hereby made to the report prepared by the Deputy City Engineer, 29
entitled “Engineer’s Report, for Hermosa Beach Landscaping and Street Lighting District 2021-30
2022,” on file in the Office of the City Clerk, for a full and detailed description of the improvements, 31
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Page 2 of 3 20-XXXX
the boundaries of the assessment district and any zones therein, and the proposed assessments upon 32
assessable lots and parcels of land within the assessment district. 33
SECTION 6. The improvements shall be provided pursuant to the provisions of the 34
Landscaping and Lighting Act of 1972, Part 2 of Division 15 (Section 22500, et seq.) of the Street 35
and Highways Code of the State of California, and in accordance with plans and specifications on 36
file in the office of the City Clerk. 37
SECTION 7. The assessment shall be levied and collected at the same time and in the same 38
manner and with the same interest and penalties as general taxes of the City, which are collected for 39
the City by the Los Angeles County Tax Collector. 40
SECTION 8. Public property owned by any public agency and in use in the performance 41
of a public function, which is included within the boundaries of the assessment district shall be 42
omitted and exempt from the assessment to be made to cover the costs and expenses of the 43
improvements. 44
SECTION 9. To expedite the making of the improvements, the City Council may transfer 45
into the “Hermosa Beach Landscaping and Street Lighting District 2021-2022 Fund,” out of any 46
money in the General Fund, any sums as it shall deem necessary, and the sums so transferred shall 47
be deemed a loan to such fund and shall be repaid in accordance with the Landscaping and Lighting 48
Act of 1972. 49
SECTION 10. NOTICE IS HEREBY GIVEN that Tuesday, July 13, 2021, at the hour of 50
6:30 PM in Civic Center Council Chambers, 1315 Valley Drive, Hermosa Beach, California, is 51
appointed as the date, time and place for hearing protests to the question of approving and 52
confirming the levy of the proposed assessment. 53
SECTION 11. The City Clerk is hereby authorized, designated and directed to give notice 54
of the public hearing in the time, form and manner required by law. 55
SECTION 12. The EASY READER, a weekly newspaper of general circulation circulated 56
within the City, is hereby designated as the newspaper in which said notice shall be published. 57
SECTION 13. This Resolution shall take effect immediately. The City Clerk shall certify 58
to the passage and adoption of this Resolution, shall cause the original of the same to be entered 59
among the original resolutions of the City Council and shall make a minute of the passage and 60
adoption thereof in the minutes of the City Council meeting at which the same is passed and adopted. 61
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Page 3 of 3 20-XXXX
PASSED, APPROVED AND ADOPTED this 8th day of June, 2021. 63
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PRESIDENT of the City Council and MAYOR of the City of Hermosa Beach, California 66
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ATTEST: APPROVED AS TO FORM: 70
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__________________________ __________________________ 73
City Clerk City Attorney 74
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City of Hermosa Beach
Staff Report
City Hall
1315 Valley Drive
Hermosa Beach, CA 90254
Staff Report
REPORT 21-0342
Honorable Mayor and Members of the Hermosa Beach City Council
Regular Meeting of June 8, 2021
APPROVAL OF THE SUPPLEMENTAL LAW ENFORCEMENT SERVICES AGREEMENT BY AND
BETWEEN COUNTY OF LOS ANGELES AND CITY OF HERMOSA BEACH
(Police Chief Paul LeBaron)
Recommended Action:
Staff recommends City Council
1.Approve the Supplemental Law Enforcement Services Agreement by and between County of
Los Angeles and City of Hermosa Beach; and
2.Authorize the City Manager to execute and the City Clerk to attest the attached agreement
subject to approval by the City Attorney (Attachment 1).
Executive Summary:
The City of Hermosa Beach maintains an agreement with the County of Los Angeles to provide
supplemental law enforcement services for significant events.The current agreement expires on
June 30,2021.The recommended action would renew the agreement for a period of five years,
allowing continued seamless public safety support during significant events.
Background:
The City of Hermosa Beach has maintained an agreement with the County of Los Angeles for
supplemental law enforcement services from the Los Angeles County Sheriff’s Department for many
years.During significant events such as the Independence Day Holiday,the public safety demands
exceed the maximum deployment of the Hermosa Beach Police Department.To provide adequate
public safety to the community during significant events,the Los Angeles County Sheriff’s
Department provides additional personnel and resources.The Hermosa Beach Police Department
and the Los Angeles County Sheriff’s Department have established a strong working relationship to
seamlessly provide the necessary public safety during significant events.
Discussion:
The current agreement for supplemental law enforcement services will expire on June 30,2021.Staff
recommends establishing a new agreement between the County of Los Angeles and the City of
Hermosa Beach for supplemental law enforcement services from the Los Angeles County Sheriff’s
Department.The agreement term would be for a period of five years beginning on July 1,2021 and
City of Hermosa Beach Printed on 6/3/2021Page 1 of 3
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Staff Report
REPORT 21-0342
Department.The agreement term would be for a period of five years beginning on July 1,2021 and
expiring on June 30,2026.The Fiscal Year 2021-22 billing rates for supplemental law enforcement
are included in the agreement as Attachment A.The billing rates would be readjusted by the County
Auditor-Controller on an annual basis with an effective date of July 1 of each year.
General Plan Consistency:
This report and associated recommendation have been evaluated for their consistency with the City’s
General Plan. Relevant Policies are listed below:
Governance Element
Goal 4. A leader and partner in the region.
·Policy 4.3 Collaboration with adjacent jurisdictions.Maintain strong collaborative
relationships with adjacent jurisdictions and work together on projects of mutual interest and
concern.
Public Safety Element
Goal 5. High quality police and fire protection services provided to residents and visitors.
·Policy 5.2 High level of response.Achieve optimal utilization of allocated public safety
resources and provide desired levels of response, staffing, and protection within the
community.
·Policy 5.7 Collaborate with neighboring jurisdictions.Cooperate and collaborate with
neighboring jurisdictions and social services to maximize public safety and emergency
services.
Fiscal Impact:
The fiscal impact for supplemental law enforcement services would vary year to year depending on
the rates and the personnel and resources needed.On years where significant events,such as the
Independence Day Holiday,fall on a weekday,fewer personnel and resources are needed.On years
where significant events fall on a weekend,additional personnel and resources are needed.The
police department budgets for supplemental law enforcement services as part of the annual budget
process.The FY 2021-22 Preliminary Budget includes an appropriation of $45,000 in the Police
Department’s Contract Services-Government account (001-2101-4251)for this year’s special
events.
Attachment:
1.Supplemental Law Enforcement Services Agreement by and between County of Los Angeles and
City of Hermosa Beach.
Respectfully Submitted by: Paul LeBaron, Police Chief
City of Hermosa Beach Printed on 6/3/2021Page 2 of 3
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Staff Report
REPORT 21-0342
Noted for Fiscal Impact: Viki Copeland, Finance Director
Legal Review: Mike Jenkins, City Attorney
Approved: Suja Lowenthal, City Manager
City of Hermosa Beach Printed on 6/3/2021Page 3 of 3
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1
SUPPLEMENTAL LAW ENFORCEMENT SERVICES AGREEMENT
BY AND BETWEEN
COUNTY OF LOS ANGELES
AND
CITY OF HERMOSA BEACH
TABLE OF CONTENTS
PARAGRAPH TITLE PAGE
RECITALS.............................................................................................................................. 2
1.0 SCOPE OF SERVICES…………............................................................ 2
2.0 ADMINISTRATION OF PERSONNEL................................................. 4
3.0 INDEMNIFICATION............................................................................... 5
4.0 TERM OF AGREEMENT........................................................................ 5
5.0 RIGHT OF TERMINATION................................................................... 5
6.0 BILLING RATES...................................................................................... 6
7.0 PAYMENT PROCEDURES.................................................................... 6
8.0 AMENDMENTS…………….................................................................... 7
9.0 ASSIGNMENT, DELEGATION, AND SUBCONTRACTING….….. 7
10.0 AUTHORIZATION WARRANTY.......................................................... 7
11.0 GOVERNING LAW, JURISDICTION, AND VENUE ........................ 7
12.0 NOTICES…………………………………………………........................ 8
13.0 VALIDITY……………………………………………….......................... 8
14.0 WAIVER.…………………………………………………........................ 8
15.0 ENTIRE AGREEMENT………………………………………………... 9
SIGNATURES………………………………………………………….…........................... 10
EXHIBIT A - SUPPLEMENTAL LAW ENFORCEMENT SERVICES RATES
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SUPPLEMENTAL LAW ENFORCEMENT SERVICES AGREEMENT
BY AND BETWEEN
COUNTY OF LOS ANGELES
AND
CITY OF HERMOSA BEACH
This Supplemental Law Enforcement Services Agreement ("Agreement") is entered into this ____
day of _____________, 2021, by and between the County of Los Angeles ("County") and City of
Hermosa Beach ("Public Entity.")
RECITALS
(a) Whereas, the Public Entity is desirous of contracting with the County for the performance
of the supplemental law enforcement functions described herein by the Los Angeles
County Sheriff’s Department ("Sheriff's Department"); and
(b) Whereas, the County is agreeable to rendering such supplemental law enforcement services
within the County on the terms and conditions set forth in this Agreement; and
(c) Whereas, this Agreement is authorized by the provisions of Section 56-1/2 and/or 56-3/4
of the Charter of the County of Los Angeles and/or Section 51301 of the California
Government Code and/or Section 10405 of the California Corporations Code; and
(d) Whereas, the County is agreeable to rendering such supplemental law enforcement
services, as available, on the terms and conditions set forth in this Agreement.
NOW THEREFORE, in consideration of the mutual covenants contained herein, and for good and
valuable consideration, the parties mutually agree as follows:
1.0 SCOPE OF SERVICES
1.1 The County agrees, as available, through the Sheriff's Department, to provide
supplemental law enforcement services to the Public Entity. The classification and
approximate numbers of personnel provided by the County shall be determined and
mutually agreed upon by the Sheriff's Department and the Public Entity prior to the
provision of supplemental law enforcement services, and set forth in an operations
plan which shall be attached hereto as an Amendment to this Agreement and
incorporated herein by this reference. The hours of duty performed by County
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employees will be established and agreed upon in accordance with the requested
supplemental law enforcement services.
1.2 The request for supplemental law enforcement services shall be a written request
on official Public Entity letterhead. The request shall contain specific dates of
service, hours of operation, number of personnel requested, classification of
personnel requested, and duties and responsibilities associated with the type of
service requested.
1.3 The request shall be signed by a representative of the Public Entity who is duly
authorized to enter into such agreements for supplemental law enforcement
services. The request shall be submitted to the Los Angeles County Sheriff’s
Department’s Contract Law Enforcement Bureau located at 211 W. Temple Street,
7th Floor, Los Angeles, California 90012.
1.4 For the purpose of performing said services, County shall furnish and supply, as
available, all necessary labor, supervision, personnel, helicopters, equipment,
communications, fuel, and supplies necessary to provide the supplemental law
enforcement services to be rendered hereunder. Notwithstanding the foregoing, the
Public Entity may provide additional resources for the County to utilize in the
performance of the supplemental law enforcement services.
1.5 If applicable, the Public Entity hereby grants to the County, the Sheriff’s
Department, and its personnel responding to requests for supplemental law
enforcement services herein the right to transmit and broadcast communications to
the Public Entity's police department's units via the primary dispatch frequency
and/or any other law enforcement frequency for which the Public Entity is licensed
by FCC.
1.6 Except as otherwise specifically set forth in this Agreement, supplemental law
enforcement services shall encompass duties and functions within the jurisdiction
of and customarily rendered by the Sheriff's Department under the Charter of the
County and the statutes of the State of California.
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2.0 ADMINISTRATION OF PERSONNEL
2.1 In the event of a dispute between the parties to this Agreement as to the extent of
the duties and functions to be rendered hereunder, or the minimum level or manner
of performance of such service, the Public Entity shall be consulted and a mutual
determination thereof shall be made by both the Sheriff's Department and the Public
Entity
2.2 The rendition of the services performed by the Sheriff's Department, the discipline
of officers, and other matters incident to the performance of such services and the
control of personnel so employed shall remain with the County.
2.3 With regard to Paragraphs 2.1 and 2.2 above, in the event of an unresolved dispute
over the minimum level of performance of services, the County shall have final and
conclusive determination as between the parties hereto.
2.4 All Public Entity employees who work in conjunction with the Sheriff’s
Department pursuant to this Agreement shall remain employees of the Public Entity
and shall not have any claim or right to employment, civil service protection, salary,
or benefits or claims of any kind from the County based on this Agreement. No
Public Entity employees shall become employees of the County.
2.5 The Public Entity shall not be called upon to assume any liability for the direct
payment of any Sheriff's Department salaries, wages, or other compensation to any
County personnel performing services hereunder for said Public Entity. Except as
herein otherwise specified, the Public Entity shall not be liable for compensation or
indemnity to any County employee or agent of the County for injury or sickness
arising out of his/her employment as a contract employee of the Public Entity.
2.6 As part of its compliance with all applicable laws and regulations relating to
employee hiring, the County agrees that the County Civil Service Rules to which it
is subject and which prohibit discrimination on the basis of non-merit factors, shall
for purposes of this Agreement be read and understood to prohibit discrimination
on the basis of sexual orientation.
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3.0 INDEMNIFICATION
3.1 Public Entity shall indemnify, defend, and hold harmless the County, its Special
Districts, elected and appointed officers, employees, and agents from and against
any and all liability, including but not limited to demands, claims, actions, fees,
costs, and expenses (including attorney and expert witness fees), arising from or
connected with the Public Entity’s acts and/or omissions arising from and/or
relating to this Agreement.
3.2 County shall indemnify, defend, and hold harmless the Public Entity, its Special
Districts, elected and appointed officers, employees, and agents from and against
any and all liability, including but not limited to demands, claims, actions, fees,
costs, and expenses (including attorney and expert witness fees), arising from or
connected with the County’s acts and/or omissions arising from and/or relating to
this Agreement.
4.0 TERM OF AGREEMENT
The term of this Agreement shall commence July 1, 2021 or upon execution by the Sheriff,
whichever is later, and shall terminate June 30, 2026, unless sooner terminated or extended
in whole or in part as provided for herein.
5.0 RIGHT OF TERMINATION
5.1 Either party may terminate this Agreement with or without cause by giving not less
than sixty (60) calendar days advance written notice to the other party.
5.2 Notwithstanding the foregoing, the Sheriff may cancel the provision of services
with only ten (10) calendar days advance notice, or less in the event of exigent
circumstances, if the Sheriff concludes that there are insufficient personnel to
provide the agreed upon services and still perform other Sheriff’s duties as required
by law.
5.3 In the event of a termination, each party shall fully discharge all obligations owed
to the other party accruing prior to the date of such termination, and, except as
otherwise provided herein, each party shall be released from all obligations, which
would otherwise accrue subsequent to the date of termination.
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6.0 BILLING RATES
6.1 For and in consideration of the rendition of the supplemental law enforcement
services to be performed by the County for the Public Entity under this Agreement,
the Public Entity shall pay County for said services provided by County under the
terms of this Agreement at the appropriate and prevailing billing rates set forth on
Exhibit A, Supplemental Law Enforcement Services Rates, as established by the
County Auditor-Controller.
6.2 The billing rates set forth on Attachment A, Supplemental Law Enforcement
Services Rates, of this Agreement shall be readjusted by the County Auditor-
Controller annually effective July 1 of each year, published by the County, and
attached hereto as an Amendment to this Agreement, to reflect the cost of such
service in accordance with the policies and procedures for the determination of such
rates as adopted by the County Board of Supervisors.
6.3 The billing rates published, Supplemental Law Enforcement Services Rates, are
developed and deemed appropriate by the County Auditor-Controller to reflect the
County’s actual costs in the compensation of employees at premium overtime rates
(except Deputy Sheriff - Reserves), the administration of workers’ compensation
benefits, and the overhead of the County attributable to the provision of services
pursuant to this Agreement. The foregoing rates are adjusted annually pursuant to
the policies and practices adopted by the Los Angeles County Board of Supervisors
governing the determination of such actual costs.
7.0 PAYMENT PROCEDURES
7.1 The County, through the Sheriff's Department, shall render to the Public Entity a
summarized invoice which covers all services performed during said month, and
the Public Entity shall pay County for all undisputed amounts within sixty (60)
calendar days after date of said invoice.
7.2 If such payment is not delivered to the County office, which is described on said
invoice, within sixty (60) calendar days after the date of the invoice, the County is
entitled to recover interest thereon. For all disputed amounts, the Public Entity shall
provide the County with written notice of the dispute including the invoice date,
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amount, and reasons for dispute within ten (10) calendar days after receipt of the
invoice. The parties shall memorialize the resolution of the dispute in writing. For
any disputed amounts, interest shall accrue if payment is not received within sixty
(60) calendar days after the dispute resolution is memorialized.
7.3 Said interest shall be at a rate of ten percent (10%) per annum or any portion thereof,
calculated from the date payment was due pursuant to Paragraphs 7.1 and 7.2
above.
8.0 AMENDMENTS
With the exception of Amendments made pursuant to Paragraph 6.0 which do not require
the signature of either party, all other changes, modifications, or amendments to this
Agreement must be in the form of a written Amendment duly executed by authorized
personnel of the County and the Public Entity.
9.0 ASSIGNMENT, DELEGATION, AND SUBCONTRACTING
A party shall not assign its rights and/or subcontract, or otherwise delegate, its duties under
this Agreement, either in whole or in part, without the prior written consent of the other
party, and any attempted assignment or delegation without such consent shall be null and
void.
10.0 AUTHORIZATION WARRANTY
The Public Entity represents and warrants that the person executing this Agreement for the
Public Entity is an authorized agent who has actual authority to bind the Public Entity to
each and every term, condition, and obligation of this Agreement and that all requirements
of the Public Entity have been fulfilled to provide such actual authority.
11.0 GOVERNING LAW, JURISDICTION, AND VENUE
This Agreement shall be governed by, and construed in accordance with, the laws of the
State of California. The parties agree and consent to the exclusive jurisdiction of the courts
of the State of California for all purposes regarding this Agreement and further agree and
consent that venue of any action brought hereunder shall be exclusively in the County of
Los Angeles.
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12.0 NOTICES
Unless otherwise specified herein, all notices or demands required or permitted to be given
or made under this Agreement shall be in writing and shall be hand delivered with signed
receipt or mailed by first class registered or certified mail, postage prepaid, addressed to
the parties at the following addresses and to the attention of the person named. Addresses
and persons to be notified may be changed by either party by giving ten (10) calendar days
prior written notice thereof to the other party.
Notices to the County shall be addressed as follows:
Los Angeles County Sheriff's Department
Contract Law Enforcement Bureau
Attn: Sergio V. Escobedo, Captain
211 W. Temple Street, 7th Floor
Los Angeles, California 90012
Notices to the Public Entity shall be addressed as follows:
City of Hermosa Beach Police Department
Attn: Paul LeBaron, Chief
540 Pier Avenue
Hermosa Beach, California 90254
13.0 VALIDITY
If any provision of this Agreement or the application thereof to any person or circumstance
is held invalid, the remainder of this Agreement and the application of such provision to
other persons or circumstances shall not be affected thereby.
14.0 WAIVER
No waiver by the parties of any breach of any provision of this Agreement shall constitute
a waiver of any other breach or of such provision. Failure of the parties to enforce at any
time, or from time to time, any provision of this Agreement shall not be construed as a
waiver thereof.
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15.0 ENTIRE AGREEMENT
This Agreement, including Exhibit A, Supplemental Law Enforcement Services Rates, and
any executed Amendments hereto or thereto, constitute the complete and exclusive
statement of understanding of the parties which supersedes all previous agreements, written
or oral, and all communications between the parties relating to the subject matter of this
Agreement.
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SUPPLEMENTAL LAW ENFORCEMENT SERVICES AGREEMENT
BY AND BETWEEN
COUNTY OF LOS ANGELES
AND
CITY OF HERMOSA BEACH
IN WITNESS WHEREOF, the Los Angeles County Board of Supervisors has caused this
Agreement to be executed by its Sheriff, and the Public Entity has caused this Agreement to be
executed on its behalf by its authorized officer, on the dates written below.
COUNTY OF LOS ANGELES
By ________________________________
Alex Villanueva, Sheriff
Date _______________________________
CITY OF HERMOSA BEACH
By ________________________________
Suja Lowenthal, City Manager
Date _______________________________
APPROVED AS TO FORM: APPROVED AS TO FORM:
RODRIGO A. CASTRO-SILVA
County Counsel
By _APPROVAL ON FILE__ By ____________________________
Deputy County Counsel Michael Jenkins, City Attorney
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SERVICE UNIT HOURLY*LIABILITY TOTAL
RATE @ 3%COST
Deputy Sheriff, Generalist 86.06$ 2.58$ 88.64$
Deputy Sheriff, Bonus I 94.00$ 2.82$ 96.82$
Deputy Sheriff, Bonus II 113.55$ 3.41$ 116.96$
Deputy Sheriff, Bonus II- SEB/ESD 119.96$ 3.60$ 123.56$
Deputy Sheriff, Bonus II- Pilot 119.96$ 3.60$ 123.56$
Deputy Sheriff, Reserve 43.22$ 1.30$ 44.52$
Sergeant 114.03$ 3.42$ 117.45$
Sergeant- SEB/ESD 120.47$ 3.61$ 124.08$
Sergeant- Pilot 133.12$ 3.99$ 137.11$
Lieutenant 137.02$ 4.11$ 141.13$
Security Officer 43.04$ 1.29$ 44.33$
Security Assistant 27.11$ 0.81$ 27.92$
Custody Assistant 55.89$ 1.68$ 57.57$
Custody Assistant (Patrol)59.05$ 1.77$ 60.82$
Community Services Assistant 32.70$ 0.98$ 33.68$
Parking Control Officer, Supervising 53.47$ 1.60$ 55.07$
Criminalist 73.14$ 2.19$ 75.33$
Criminalist, Senior 98.55$ 2.96$ 101.51$
Criminalistics Laboratory Technician 49.17$ 1.48$ 50.65$
* Hourly Rate does not include the liability cost at 3%.
Attachment A
Rates are effective July 1, 2021 through June 30, 2022
SHERIFF'S DEPARTMENT
C O U N T Y O F L O S A N G E L E S
"A Tradition of Service"
Since 1850
SUPPLEMENTAL LAW ENFORCEMENT SERVICES RATES
FISCAL YEAR 2021-22
AS PUBLISHED BY THE AUDITOR-CONTROLLER
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City of Hermosa Beach
Staff Report
City Hall
1315 Valley Drive
Hermosa Beach, CA 90254
Staff Report
REPORT 21-0339
Honorable Mayor and Members of the Hermosa Beach City Council
Regular Meeting of June 8, 2021
VACANCIES-PARKS, RECREATION AND COMMUNITY RESOURCES ADVISORY COMMISSION
TERM EXPIRATIONS-SCHEDULE APPLICANT INTERVIEWS
(City Clerk Eduardo Sarmiento)
Recommended Action:
Staff recommends City Council schedule interviews for Tuesday,July 13,2021 at 4:00 p.m.,to
interview Parks,Recreation and Community Resources Advisory Commission applicants for the three
terms due to expire June 30, 2021.
Summary:
Three Parks,Recreation and Community Resources Advisory Commissioner terms are due to expire
June 30,2021.Council directed staff to advertise and request applications from interested parties,
which resulted in five applicants.Staff recommends City Council schedule interviews to take place on
Tuesday, July 13, 2021 at 4:00 p.m.
Background:
At its meeting of April 13,2021,City Council directed the City Clerk to advertise and request
applications from interested parties for three Parks,Recreation and Community Resources Advisory
Commission terms due to expire June 30,2021.Following established procedure,notice was posted
at the usual Civic Center locations,placed on the City’s website,and published twice in the Easy
Reader,with an application filing deadline of 6:00 p.m.,Thursday,June 3rd.Five applications
(attached) were received; applicants are alphabetically listed below:
1.Jani Lange
2.Lauren Pizer Mains
3.E. Thomas Moroney
4.Isabel Rodriguez
5.Tara McNamara Stabile
Staff recommends interviews take place at 4:00 p.m.,prior to the regular meeting of Tuesday,July
13,2021,with appointments (four-year terms that will expire June 30,2025)made later that evening
at the Regular City Council meeting.The Parks,Recreation and Community Resources Advisory
Commission’s next meeting is scheduled for Tuesday, July 6, 2021.
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REPORT 21-0339
Past Council Actions
Meeting Date Description
April 13, 2021 (Regular Meeting)Council directed City Clerk to advertise and request applicitons from interested parties
Fiscal Impact:
There are no fiscal impacts associated with this recommendation.
Attachments:
1.Jani Lange Application
2.Lauren Pizer Mains Application
3. E. Thomas Moroney Application
4.Isabel Rodriguez Application
5. Tara McNamara Stabile Application
Respectfully submitted by: Eduardo Sarmiento, City Clerk
Approved: Suja Lowenthal, City Manager
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CITY OF HERMOSA BEACH
BOARDS AND COMMISSIONS
The City of Hermosa Beach appreciates your interest in serving on one of the City’s six boards and
commissions. Board and commission members provide a valuable service and serve in a voluntary
capacity, without compensation. Please submit your completed application to the City Clerk’s office.
All appointments are made by the City Council. With one exception, each board and commission is
composed of five members, serving staggered four-year terms. The composition of all standing boards
and commissions excludes current City elected officials, and no members serve on more than one
board/commission at the same time.
All board and commission members are required by law to file statements of economic interest
(assuming office statement, annual statements, and leaving office statements) for the purpose of
disclosing potential conflicts of interest. The completed statements are filed with the City Clerk, who
will provide all forms and instructions at the appropriate time.
Generally, two absences from regularly scheduled meetings of any member within one calendar quarter
and/or four absences from regular meetings within one calendar year constitutes grounds for removal or
creates an automatic vacancy, with no distinction between excused and unexcused absences. All
members serve at the pleasure of the City Council, with no term limits. Following is a brief description
of qualifications and duties for each of the City’s boards and commissions, and the Hermosa Beach
Municipal Code (HBMC) reference for obtaining more detailed information.
BOARD OF APPEALS
[HBMC 15.04.020] This five-member board provides for reasonable interpretations of the
Building Code. Members must be qualified by training and experience to pass upon matters pertaining
to building construction. There are no specified term limits (members serve at the pleasure of the City
Council), and members are not required to be residents or qualified electors of the city. The Board of
Appeals meets in the City Council Chambers at 7 p.m. on the second Monday of every month, as
necessary. {Staff liaison = Community Development Director Ken Robertson}
CIVIL SERVICE BOARD
[HBMC 2.76] This five-member board functions as the City’s Review Board pertaining to
personnel functions and Civil Service Rules and Regulations in conjunction with Ordinance N.S. 211
(People’s Initiative, passed by voters June 7, 1960). Members must be qualified electors of the City;
no person shall be appointed to this board that holds any salaried public office or employment with the
City; no member of this board shall be eligible for appointment to any office or employment with the
City.
Members are appointed to staggered four-year terms. The Civil Service Board is scheduled to
meet regularly in the City Council Chambers at 5 p.m. on the third Wednesday of each month, as
necessary, with additional meetings called, if needed. {Staff liaison = Human Resources Manager
Vanessa Godinez}
EMERGENCY PREPAREDNESS ADVISORY COMMISSION
[HBMC 2.38] The duties of this seven-member commission include providing to the City
Council advice and recommendations on how the City and its residents can prepare and respond swiftly
and responsibly to emergencies.
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Members must be residents of the City and are appointed to staggered four-year terms. The
Commission meets regularly every other month in the City Council Chambers at 7 p.m. on the first
Monday of odd-numbered months (January, March, May, July, September, November). {Staff liaison
= Emergency Management Coordinator Brandy Villanueva}
PARKS, RECREATION & COMMUNITY RESOURCES ADVISORY COMMISSION
[HBMC 2.28] This five-member commission serves in an advisory capacity to the City Council
in all matters pertaining to the Community Resources Department; cooperates with other governmental
agencies and civic groups on the advancement of sound leisure, cultural, social services and
educational programming; and formulates policies on the services, programs and lease agreements of
the Department, subject to approval of the City Council.
Members must be bona fide residents of the city, and not members of the Hermosa Beach
Community Center Foundation Board. Members are appointed to staggered four-year terms. The
Commission meets regularly in the Council Chambers at 7 p.m. on the first Tuesday of each month, or
as scheduled by the Commission. {Staff liaison = Community Resources Manager Kelly Orta}
PLANNING COMMISSION
[HBMC 2.32] This five-member commission is governed in all respects and performs duties as
prescribed by applicable state and local laws. The primary purpose of the Commission is to maintain
and enhance the environment of the community, which entails advance or long-range planning
(updating of the General Plan and specific elements), current planning (short-range projects), and land
use controls (administering to the code and review of all subdivisions and zoning petitions). The
Commission serves as an advisory board to the City Council on all matters pertaining to zoning,
conditional use permit process, etc.
Members must be qualified electors of the City. Members are appointed to staggered four-year
terms. The Commission meets regularly in the Council Chambers at 7 p.m. on the third Tuesday of
each month. {Staff liaison = Community Development Director Ken Robertson}
PUBLIC WORKS COMMISSION
[HBMC 2.80] The duties of this five-member commission are to review and make
recommendations to the City Council on all capital improvement projects, assist with developing and
updating design guidelines for public improvements, and other matters referred to the Commission by
the City Council.
Members must be qualified electors of the City. Members are appointed to staggered four-year
terms. The Commission is scheduled to meet regularly every other month in the City Council
Chambers at 7 p.m. on the third Wednesday of odd-numbered months (January, March, May, July,
September, November). {Staff liaison = Public Works Director Andrew Brozyna}
City Clerk's Office
Phone: (310) 318-0204
1315 Valley Drive, Hermosa Beach, CA 90254
FAX: (310) 372-6186
Email: edoerfling@hermosabch.org
(09-29-16)
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CITY OF HERMOSA BEACH
BOARD/COMMISSION APPLICATION
NAME OF COMMISSION
Name Home Phone
Address Cell Phone
Email Bus. Phone
Occupation/Profession:
Employer Name & Address
REFERENCES:
Local:
Professional:
Other:
COMMUNITY PARTICIPATION AND SERVICE (past and present):
Why do you wish to become a Commission member?
What do you feel are the duties and responsibilities of a Commission member?
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Do you have any current obligations or responsibilities, which could be construed as a conflict of interest with
your being a board/commission member? ____Yes ____No (If yes, please explain)
Please provide below and/or attach a resume of your education, employment, memberships, past activities and
other experience that you feel would qualify you as a Board/Commission member.
This Board/Commission meets on at p.m. Do you foresee any scheduling
problems that might cause you to miss meetings? ____Yes ____No
How long have you lived in Hermosa Beach?
Additional Comments:
Signed:
Date:
(07-03-18)
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City of Hermosa Beach
Staff Report
City Hall
1315 Valley Drive
Hermosa Beach, CA 90254
Staff Report
REPORT 21-0345
Honorable Mayor and Members of the Hermosa Beach City Council
Regular Meeting of June 8, 2021
APPROVAL OF THE REVISED ENHANCED WATERSHED
MANAGEMENT PROGRAM AND REASONABLE ASSURANCE
ANALYSIS FOR THE BEACH CITIES WATERSHED
MANAGEMENT GROUP
(Environmental Programs Manager Douglas Krauss)
Recommended Action:
Staff recommends City Council approve the Revised Enhanced Watershed Management Program
(EWMP)and Reasonable Assurance Analysis (RAA)for the Beach Cities Watershed Management
Group.
Executive Summary:
The current National Pollutant Discharge Elimination System (NPDES)Municipal Separate Storm
Sewer System Permit (MS4 Permit)requires permittees to submit an updated Enhanced Watershed
Management Plan (EWMP)with an amended Reasonable Assurance Analysis (RAA)by June 30,
2021.Hermosa Beach and the Beach Cities Watershed Management Group partners (Beach Cities
Group)have been working on an update,which includes both analysis of water quality data and
control measure performance data,as well as an update of potential regional projects identified to
help meet pollution reduction mandates.Staff recommends City Council review and approve the draft
revised document (Attachment 3).If approved,staff would submit the updated EWMP to the
Regional Water Quality Control Board.
Background:
The cities of Hermosa Beach,Torrance,Redondo Beach,Manhattan Beach,and the Los Angeles
County Flood Control District formed the Beach Cities Group to develop an EWMP to comply with the
Los Angeles Regional Water Quality Control Board's (Regional Board)2012 MS4 Permit.The Beach
Cities Group entered into an MOU to cost share the development of the EWMP and a Coordinated
Integrated Monitoring Plan (CIMP)in 2013 (Attachment 1).The Beach Cities EWMP was submitted
to the Regional Board and was approved by the Executive Officer of the Regional Board via a letter
dated April 18,2016 (Attachment 2).The Beach Cities Group was directed by the Executive Officer
of the Regional Board to begin implementation of the EWMP immediately,including construction of
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identified capital projects.
At its October 27,2020 meeting,City Council approved a Memorandum of Understanding (MOU)
between the Beach Cities Watershed group to update the EWMP,for which the City of Redondo
Beach is serving as lead.The MOU included the City’s cost of $107,963.33 towards its share of the
EWMP update,as well as the City’s contribution of $160,000 approved at its July 28,2020 meeting to
help fund feasibility studies after the cancellation of the Greenbelt Infiltration project.
In addition to its many other components,the EWMP update identifies regional stormwater projects
to ensure the group meets the pollutant reduction goals outlined in the existing EWMP.The City of
Hermosa Beach and its Beach Cities Group partners are actively seeking alternate projects to
achieve stormwater diversion and pollution reductions equivalent to what would have been achieved
by the cancelled Hermosa Greenbelt Infiltration Project.The search for alternative projects involves
reanalyzing existing concepts and researching new projects throughout the area with the goal of
combining multiple smaller projects to achieve compliance goals.Additionally,the Regional Board
recently approved a three-year extension of the group’s primary pollution reduction deadline (Santa
Monica Bay Bacteria TMDL),which allows the group until July 2024 to identify and construct projects.
A formal request for a time extension on pollutant reduction goals will be considered as that deadline
nears.
Analysis:
In addition to adapting the EWMP every two years as described in the MS4 Permit,the current MS4
Permit requires Permittees submit an updated EWMP with an updated Reasonable Assurance
Analysis (RAA)by June 30,2021.The RAA is the computer model,which predicts the pollutant load
reductions needed to meet the MS4 Permit’s numeric water quality limits.The updated EWMP and
RAA must incorporate water quality data and control measure performance data,as well as any other
information informing the adaptive management process gathered through December 31,2020.The
document also reflects new information or lessons learned from the group’s implementation thus far
of the EWMP.A working proposal of the next MS4 Permit,which will supersede the current permit,
has been released by the Regional Board and will also require an updated EWMP and RAA every
five years, consistent with the current requirement.
The updated Beach Cities Group EWMP (Attachment 3)builds upon and improves the original
Beach Cities EWMP.Since the Beach Cities EWMP was approved in 2016,significant advancements
have been made in stormwater project planning and RAA modeling.Additionally,the group has
gained invaluable experience and insight with respect to implementation of the EWMP,understanding
more about both the opportunities and challenges they face in successfully implementing effective
stormwater projects.
In particular, the updated Beach Cities EWMP has been revised in the following critical ways:
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·Incorporation of newly available,EWMP-specific data.The Beach Cities Group has been
successfully implementing its Coordinated Integrated Monitoring Program (CIMP)since 2015,
resulting in five years of outfall and receiving water monitoring data from the EWMP area.
Coupled with other regional studies and data,this has resulted in a more-definitive
determination of whether MS4 outfalls are causing or contributing to receiving water
exceedances.
·Utilization of the recently updated,Countywide RAA modeling tool.The revised RAA
uses the newly released WMMS 2 modeling platform to maintain consistency with the majority
of RAAs across Los Angeles County.In addition to its incorporation of remote sensing,water
quality,and hydrology data,a key advantage of using the WMMS 2 model is the extensive
regional calibration effort that has gone into the recent model update.This model was further
calibrated and validated using Beach Cities CIMP monitoring data collected through June 30,
2020 to best reflect the baseline hydrology and water quality conditions within the Beach
Cities EWMP Area.
·A focus on multi-benefit regional projects.Although distributed Best Management
Practices (BMPs)are necessary and beneficial for watershed planning,regional projects are
generally preferable,as they provide multiple benefits,are more cost-effective,and have a
higher likelihood of receiving outside funding.The Beach Cities Group is committed to
emphasizing regional,multi-benefit projects,including regional green streets,that seek to
maximize community benefits and amplify other environmental objectives.
Incorporating these changes,the updated Beach Cities Group EWMP more accurately reflects the
actual water quality and flow conditions in the EWMP area,provides updated,measurable milestones
that can be tracked over time,and identifies implementable and cost-effective solutions to achieve
compliance.
An important component of the EWMP update process is community engagement on the document’s
development and the identification of regional projects.The public relations consultant working on the
project developed a website for the EWMP update that serves all the Beach Cities Group
communities.They also hosted a virtual community meeting on May 19,2021,where a high-level
overview of the process was presented,and feedback was received on the proposed projects
identified for each city.More information on the project and a link to the presentation are found on the
project page of the City’s website.
For Hermosa Beach,the EWMP and RAA update consultant team has identified the installation of dry
wells that,in combination with the projects proposed in the other cities “upstream”,should help
Hermosa Beach meet its required storm water run-off volume reduction goals.A dry well is a bored,
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Hermosa Beach meet its required storm water run-off volume reduction goals.A dry well is a bored,
drilled,or driven shaft whose depth is greater than its width.These dry wells would most likely be
prefabricated storage chambers or pipe segments.Dry wells are similar to a tube in the ground.No
bigger than a few feet in diameter and marked at the surface by a maintenance access hole and inlet,
they serve to temporarily store and subsequently infiltrate stormwater runoff.
Dry wells are more cost effective and logistically manageable than a large regional infiltration project
and allow much greater flexibility for siting.For comparison,the capital projects identified in the City’s
original EMWP had a total estimated cost range of $12.5-$27 million (Greenbelt Infiltration Project
and distributed green streets),while the EWMP update estimates $6.5-$8 million in capital project
costs (for the proposed dry wells and Hermosa Avenue Green Streets projects).Dry wells proposed
for the vicinity of Pacific Coast Highway and the neighborhood to the east could potentially provide
the stormwater capture necessary (in conjunction with projects in our partner cities)to meet the
mandates of the MS4 permit.These proposed dry wells will help satisfy the requirement of the
EWMP update to identify potential projects,but final quantity and locations will be determined via
further investigation and community engagement.Additionally,as other regional projects are studied
and constructed,Hermosa Beach’s required projects could be adjusted to incorporate revised
treatment volumes and other types of pollution control measures.
Past Council Actions
Meeting Date Description
November 12, 2013 Authorized an MOU with the Beach Cities Group to develop an EMWP
and CIMP
June 23, 2015 Authorized submission of the draft EWMP to the Regional Water Quality
Control Board and Adopt Los Angeles County Program Environmental
Impact Report
February 9, 2016 Approved an MOU to develop and implement a CIMP with the Beach
Cities WMG
July 28, 2020 Approved Dissolution of the MOU for the Greenbelt Infiltration Project and
Reappropriated $160,000 from CIP 542 to fund the feasibility studies
September 8, 2020 Council sent the draft MOU back to staff to revise
October 27, 2020 Council approved MOU for EWMP Update
General Plan Consistency:
This report and associated recommendations have been evaluated for their consistency with the
City’s General Plan. Relevant Policies are listed below:
Infrastructure
Goal 5. The stormwater management system is safe, sanitary, and environmentally and
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fiscally sustainable.
Policies:
·5.1 Integration of stormwater best practices.Integrate stormwater infiltration best practices
when initiating streetscape redevelopment or public facility improvement projects.
·5.8 Low impact development. Require new development and redevelopment projects to
incorporate low impact development (LID) techniques in project designs, including but not
limited to on-site drainage improvements using native vegetation to capture and clean
stormwater runoff and minimize impervious surfaces.
Fiscal Implications:
Per the EWMP Update MOU,the City of Hermosa will pay its share of $267,963.33 in Fiscal Year
2020-21,which includes $107,963.33 from CIP 401 EWMP Update/Feasibility Study for its share of
the EWMP update and $160,000 from CIP 542 Stormwater Urban Run-off Diversion Project
committed by the City to fund feasibility studies as part of the dissolution of the Greenbelt Infiltration
Project MOU.Should the feasibility studies final cost total less than $160,000,the City will be
reimbursed by the City of Redondo Beach for the difference.These costs are being tracked
specifically for this purpose.
The cost of the capital projects identified in the plan (proposed dry wells and Hermosa Avenue Green
Street)is estimated to be $6.5-$8 million.The City of Torrance has received a grant to fund the
design and engineering of the Hermosa Avenue Green Street Project and is seeking additional grants
for construction.The Fiscal Year 2021-22 Preliminary Budget includes funding of $159,500 for CIP
164 Hermosa Avenue Green Street.Staff will continue to seek grant funding opportunities for the
proposed projects and will seek future budget appropriations as project cost estimates are further
developed.
Attachments:
1.2013 MOU for Development of EWMP and CIMP
2.Current EWMP
3.Draft Updated EWMP
Respectfully Submitted by: Douglas Krauss, Environmental Program Manager
Noted for Fiscal Impact: Viki Copeland, Finance Director
Legal Review: Mike Jenkins, City Attorney
Approved: Suja Lowenthal, City Manager
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ENHANCED WATERSHED
MANAGEMENT PROGRAM
(EWMP)
for the Beach Cities Watershed Management
Area (Santa Monica Bay and Dominguez
Channel Watersheds)
Submitted to:
Los Angeles Regional Water Quality Control Board
Submitted by:
Beach Cities EWMP Group
March 2018
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TABLE OF CONTENTS Executive Summary ....................................................................................................................................................... ES-1 Purpose and Objectives ........................................................................................................................................... ES-1 Santa Monica Bay Watershed ............................................................................................................................... ES-4 Dominguez Channel Watershed ....................................................................................................................... ES-17 Compliance Schedule ............................................................................................................................................ ES-29 Planning Level Cost Opinion .............................................................................................................................. ES-34 Financing Discussion ............................................................................................................................................. ES-36 1 Introduction .............................................................................................................................................................. 1-1 1.1 Purpose and Regulatory Framework .................................................................................................... 1-1 1.2 Applicability of EWMP ................................................................................................................................ 1-4 1.3 EWMP Development Process ................................................................................................................... 1-7 1.4 Report Organization .................................................................................................................................. 1-10 1.5 Terms of Reference.................................................................................................................................... 1-10 2 Santa Monica Bay Watershed ............................................................................................................................ 2-1 2.1 Background ...................................................................................................................................................... 2-1 2.2 Identification of Water Quality Priorities............................................................................................ 2-4 2.3 Selection of Appropriate Best Management Practices ................................................................ 2-18 2.4 Reasonable Assurance Analysis Approach ...................................................................................... 2-23 2.5 Baseline Loads and Target Load Reductions .................................................................................. 2-34 2.6 Best Management Practices ................................................................................................................... 2-39 2.7 Reasonable Assurance Analysis Results ........................................................................................... 2-68 2.8 Multiple Benefits ........................................................................................................................................ 2-71 2.9 Parallel Compliance Efforts .................................................................................................................... 2-73 3 Dominguez Channel Watershed ....................................................................................................................... 3-1 3.1 Background ...................................................................................................................................................... 3-1 3.2 Identification of Water Quality Priorities............................................................................................ 3-4 3.3 Selection of Appropriate Best Management Practices ................................................................ 3-20 3.4 Reasonable Assurance Analysis Approach ...................................................................................... 3-21 3.5 Baseline Loads and Target Load Reductions .................................................................................. 3-32 3.6 Best Management Practices ................................................................................................................... 3-35 3.7 Reasonable Assurance Analysis Results ........................................................................................... 3-48
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3.8 Multiple Benefits ........................................................................................................................................ 3-52 3.9 Parallel Compliance Efforts .................................................................................................................... 3-52 4 Implementation Schedule.................................................................................................................................... 4-1 4.1 Compliance Schedule ................................................................................................................................... 4-1 4.2 Project Sequencing ....................................................................................................................................... 4-7 5 Assessment and Adaptive Management Framework ............................................................................... 5-1 6 Financial Analysis ................................................................................................................................................... 6-4 6.1 BMP Cost Methodology and Assumptions .......................................................................................... 6-4 6.2 Proposed Structural BMPs ........................................................................................................................ 6-7 7 Potential Funding Sources and Financial Strategy ................................................................................... 7-1 7.1 Grant Opportunities ..................................................................................................................................... 7-2 7.2 Project-Specific Interagency Partnerships ......................................................................................... 7-7 7.3 Local Bond Issuance ..................................................................................................................................... 7-7 7.4 State Revolving Funds ................................................................................................................................. 7-8 7.5 Local Public Funding Opportunities and Approval Procedures ................................................ 7-9 7.6 Public Private Partnerships ................................................................................................................... 7-12 7.7 Financial Strategy ....................................................................................................................................... 7-13 7.8 Watershed Management Program Budgets .................................................................................... 7-15 8 Legal Authority ........................................................................................................................................................ 8-1 9 References .................................................................................................................................................................. 9-2
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LIST OF FIGURES Figure ES-1. Beach Cities EWMP Area ........................................................................................................ ES-5 Figure ES-2. Analysis Regions and Compliance Monitoring Locations within the SMB Watershed portion of the Beach Cities EWMP Area ............................................................................. ES-8 Figure ES-3. Proposed Project Sequencing in the Santa Monica Bay Watershed .................. ES-17 Figure ES-4. Analysis Regions within the Dominguez Channel Watershed portion of the Beach Cities EWMP Area ............................................................................................................................................. ES-21 Figure ES-5. Project Sequencing in the Dominguez Channel Watershed .................................. ES-28 Figure 1-1. Beach Cities EWMP Area ............................................................................................................. 1-5 Figure 2-1. Beach Cities WMG MS4 Infrastructure within the Santa Monica Bay Watershed . 2-2 Figure 2-2. Beach Cities WMG Land Uses within the Santa Monica Bay Watershed ................ 2-3 Figure 2-3. Process for Categorizing Water Body-Pollutant Combinations ................................2-10 Figure 2-4. Non-Stormwater Outfall Screening Program ...................................................................2-22 Figure 2-5. Analysis Regions and Monitoring Locations within the SMB Watershed portion of the Beach Cities EWMP Area ...........................................................................................................................2-25 Figure 2-6. SBPAT Model Data Flow ............................................................................................................2-27 Figure 2-7. SBPAT Monte Carlo Method Components .........................................................................2-28 Figure 2-8. SBPAT Rain and Stream Gauges .............................................................................................2-29 Figure 2-9. Annual Runoff Volumes for Topanga Creek Subwatershed: Modeled vs. Observed. .....................................................................................................................................................................................2-32 Figure 2-10. Annual Runoff Volumes for Topanga Creek Subwatershed: Modeled vs. Observed (Flow Duration Curve Format). .....................................................................................................................2-33 Figure 2-11. Correlation between Modeled Fecal Coliform Loads and Observed Exceedance Days (each point represents one TMDL year, 2005-2013) ................................................................2-34 Figure 2-12. IGP and Caltrans Area within the Santa Monica Bay portion of the Beach Cities EWMP Area ............................................................................................................................................................2-53 Figure 2-13. Existing and Proposed Regional BMPs within EWMP Area .....................................2-54 Figure 2-14. Existing and Proposed Distributed BMP Locations within the EWMP Area. ...2-55 Figure 2-15. Proposed Regional Projects, Analysis Region SMB-5-02 ..........................................2-62 Figure 2-16. Proposed Regional Projects, Analysis Region SMB-6-01 ..........................................2-64 Figure 3-1. Beach Cities WMG MS4 Infrastructure within the Dominguez Channel Watershed ....................................................................................................................................................................................... 3-2 Figure 3-2. Beach Cities WMG Land Uses within the Dominguez Channel Watershed ........... 3-3 Figure 3-3. Analysis Regions within the Dominguez Channel Watershed portion of the Beach Cities EWMP Area ................................................................................................................................................3-23 Figure 3-4. Annual Runoff Volumes Predicted by LSPC and SBPAT ...............................................3-28
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Figure 3-5. Annual Runoff Volumes Predicted by LSPC and SBPAT..............................................3-29 Figure 3-6. Comparison of Fecal Coliform High Density Residential EMC Values between SCCWRP Measurements (n=7) and Multi-Family Residential EMC distribution in SBPAT ..3-30 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 SBPAT .....................................................................................................................................................................................3-31 Figure 3-8. IGP and Caltrans Area within the Dominguez Channel portion of the Beach Cities EWMP Area ............................................................................................................................................................3-40 Figure 3-9. Proposed Distributed BMPs within the Dominguez Channel Watershed ............3-41 Figure 3-10. Proposed Regional BMPs within the Dominguez Channel Watershed ...............3-42 Figure 3-11. Proposed Regional BMPs, DC-RB/MB Analysis Region .............................................3-45 Figure 4-1. Proposed Project Sequencing ................................................................................................... 4-8 Figure 5-1. Adaptive Management Approach ............................................................................................ 5-3
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LIST OF TABLES Table ES-1. Beach Cities WMG Area Distribution by Participating Agency ................................. ES-3 Table ES-2. Water Body-Pollutant Combination Prioritization for the Santa Monica Bay Watershed .............................................................................................................................................................. ES-6 Table ES-3. Water Quality Targets for Modeled Pollutants in the Santa Monica Bay Watershed ..................................................................................................................................................................................... ES-7 Table ES-4. TLRs for Fecal Coliform in the Santa Monica Bay Watershed ................................ ES-10 Table ES-5. Proposed Structural BMPs in the Santa Monica Bay Watershed .......................... ES-13 Table ES-6. Santa Monica Bay Watershed – Fecal Coliform Reasonable Assurance Analysis Results – Interim and Final Compliance ................................................................................................. ES-16 Table ES-7. Water Body-Pollutant Prioritization for the Dominguez Channel Watershed ... ES-18 Table ES-8. Water Quality Targets for the Dominguez Channel Watershed ............................ ES-19 Table ES-9. TLRs and Baseline Conditions for Pollutants in the Dominguez Channel Watershed .................................................................................................................................................................................. ES-23 Table ES-10. Proposed Structural BMPs in the Dominguez Channel Watershed .................. ES-24 Table ES-11. Dominguez Channel Watershed – Reasonable Assurance Analysis Results – Interim and Final Compliance ..................................................................................................................... ES-27 Table ES-12. Compliance Schedule for the Santa Monica Bay and Dominguez Channel Watersheds ......................................................................................................................................................... ES-30 Table ES-13. Cost Opinion for Proposed Structural BMPs in Santa Monica Bay and Dominguez Channel Watersheds ....................................................................................................................................... ES-35 Table 2-1. Beach Cities WMG EWMP Area Distribution by Participating Agency ...................... 2-1 Table 2-2. Beach Cities EWMP Area - Santa Monica Bay Watershed Water Bodies and Beneficial Uses ........................................................................................................................................................ 2-6 Table 2-3. Water Body-Pollutant Combination Prioritization and Pollutant Interim and Final Compliance Targets for Santa Monica Bay Watershed Portion of the Beach Cities EWMP Area .....................................................................................................................................................................................2-11 Table 2-4. Bacteria RLWs for Beach Cities WMG Shoreline Monitoring Stations ....................2-12 Table 2-5. Rainfall Summary at Manhattan Beach Precipitation Gauge (Station ID 1070) ..2-30 Table 2-6. BMPS and Constituents Modeled in SBPAT1 .......................................................................2-31 Table 2-7. Target Load Reductions for Fecal Coliform for each Modeled Analysis Region in Santa Monica Bay Watershed - TMDL Year 1995 ..................................................................................2-38 Table 2-8. MCM Modifications and Agency-Specific Enhancements for Beach Cities EWMP Area ...........................................................................................................................................................................2-42 Table 2-9. Estimated Annual Redevelopment Rates ............................................................................2-48 Table 2-10. Redevelopment and Public Retrofit Incentives Model Assumptions ...................2-51
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Table 2-11. Non-MS4 Parcels – Modeled as Treated by Treatment Plants (i.e., BMPs that will treat stormwater to the Water Quality Objectives)...............................................................................2-52 Table 2-12. Parameters and Performance for Existing Regional BMPs Modeled as Infiltration Basins .......................................................................................................................................................................2-59 Table 2-13. Parameters and Performance for Existing Regional BMPs Modeled as Wet Ponds with Extended Detention..................................................................................................................................2-60 Table 2-14. Parameters and Performance for Proposed Regional BMPs Modeled as Infiltration Basins .......................................................................................................................................................................2-65 Table 2-15. Existing and Proposed Distributed BMPs .........................................................................2-67 Table 2-16. Existing and Proposed Distributed BMP Performance ................................................2-68 Table 2-17. Santa Monica Bay Watershed – Fecal Coliform RAA Results – Interim and Final Compliance .............................................................................................................................................................2-69 Table 2-18. Dry Weather RAA Evaluation of Santa Monica Bay Watershed CMLs .................2-71 Table 3-1. Beach Cities WMG Area Distribution by Participating Agency ..................................... 3-1 Table 3-2. Beach Cities EWMP Area – Dominguez Channel Watershed Water Bodies and Beneficial Uses ........................................................................................................................................................ 3-4 Table 3-3. LACDPW Monitoring Results Summary ................................................................................. 3-8 Table 3-4. Water Body-Pollutant Combination Prioritization and Pollutant Interim and Final Compliance Targets for Dominguez Channel Watershed ...................................................................3-11 Table 3-5. RAA Models Used in the Dominguez Channel Watershed ............................................3-24 Table 3-6. Wet Weather Permit Limits (Final Compliance Limits for Modeled Pollutants).3-25 Table 3-7. Mean Annual Volume Predicted by SBPAT and LSPC and Measured at the S28 Stream Gauge ........................................................................................................................................................3-28 Table 3-8. Baseline Runoff, Concentration, and Load for Pollutants in the Dominguez Channel Watershed for the Critical Condition ..........................................................................................................3-32 Table 3-9. Target Load Reductions and Baseline Conditions for Pollutants in the Dominguez Channel Watershed for the Critical Condition .........................................................................................3-35 Table 3-10. Estimated Annual Redevelopment Rates .........................................................................3-37 Table 3-11. Parameters and Performance for Proposed Regional BMPs Modeled as Media Filters ........................................................................................................................................................................3-46 Table 3-12. Dominguez Channel Watershed – RAA Results – Interim and Final Compliance .. 3-51 Table 4-1. Compliance Deadlines associated with Santa Monica Bay Watershed WBPCs ...... 4-1 Table 4-2. Implementation Actions and Dates associated with Dominguez Channel Watershed WBPCs ........................................................................................................................................................................ 4-4 Table 6-1. Range of Soft Costs for Proposed Structural BMP Projects as a Percent of Capital . 6-6 Table 6-2. Proposed BMP Design Assumptions for Conceptual Cost Opinions ........................... 6-8
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Table 6-3. Estimated Construction and O&M Costs for Structural BMPs in Analysis Region SMB-5-02, Alternative 1 ....................................................................................................................................6-11 Table 6-4. Estimated Construction and O&M Costs for Structural BMPs in Analysis Region SMB-5-02, Alternative 2 ....................................................................................................................................6-12 Table 6-5. Estimated Construction and O&M Costs for Structural BMPs in Analysis Region SMB-6-01 ................................................................................................................................................................6-14 Table 6-6. Estimated Construction and O&M Costs for Structural BMPs in Analysis Region DC-RB/MB1 ....................................................................................................................................................................6-16 Table 6-7. Estimated Construction and O&M Costs for Structural BMPs in Analysis Region DC-Torrance ..................................................................................................................................................................6-17 Table 6-8. Estimated Construction and O&M Costs for Catch Basin Retrofits ...........................6-18 Table 6-9. Capital, O&M, and 20-year Life-Cycle Cost Opinion for Proposed Structural BMPs by Analysis Region ....................................................................................................................................................6-22 Table 7-1. Relevant Grant Opportunities .................................................................................................... 7-4 Table 7-2. Added Benefits of Interagency Partnership for Stormwater Management ............. 7-7 Table 7-3. Local Funding Opportunities ....................................................................................................7-10 Table 7-4. Local Funding Approval Mechanisms....................................................................................7-11 Table 7-5. Selected Cities that provide Financial Subsidies to encourage the Development of Stormwater Infrastructure in Private Properties ..................................................................................7-13 Table 7-6. Funding Approach Summary ....................................................................................................7-14 Table 7-7. Watershed Management Program Budgets for the Beach Cities WMG ..................7-15
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LIST OF APPENDICES A. Notice of Intent B. Reasonable Assurance Analysis for Dominguez Channel Watershed within the City of Torrance C. City of Redondo Beach Area Located within Machado Lake Watershed D. City of Redondo Beach Tributary to Machado Lake E. City of Redondo Beach Request for Withdrawal and/or Exemption from Machado Lake Trash TMDL—Region 4 F. Machado Lake Trash TMDL – Redondo Beach Watershed Contribution G. Background Information on the LACFCD H. Approach to Addressing Receiving Water Exceedances I. Land Use-Based Wet Weather Pollutant EMCs J. BMP Effluent Concentrations K. Sample RAA Calculations L. MCM Customization Summary M. LID Ordinances N. Green Streets Policies O. Structural BMP Unit Cost Tables P. Documentation of Legal Authority Q. Selection of Critical Condition R. Ammonia Monitoring Data from Sites S28 and TS19
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LIST OF ACRONYMS AED Allowable Exceedance Days ASBS Area of Special Biological Significance ASCE American Society of Civil Engineers BMP Best Management Practice Caltrans California Department of Transportation CERCLA Comprehensive Environmental Response, Compensation, & Liability Act CFCC California Financing Coordinating Committee cfs Cubic feet per second CIMP Coordinated Integrated Monitoring Program CML Compliance Monitoring Location CNT Center for Neighborhood Technology COMM Commercial and Sport Fishing Conc. Concentration CSMP Coordinated Shoreline Monitoring Plan CTR California Toxic Rules cu-ft Cubic feet CWA Clean Water Act CWSRF Clean Water State Revolving Fund DC Dominguez Channel DCu Dissolved Copper DDT Dichloro-diphenyl-trichloroethane DP Dissolved Phosphorus as P DZn Dissolved Zinc EIFD Enhanced Infrastructure Financing Districts EMC Event Mean Concentration EWMP Enhanced Watershed Management Program FAA Federal Aviation Administration FC Fecal coliform FIB Fecal Indicator Bacteria ft Foot GIS Geographic Information System GM Geometric Mean GO General Obligation gpm Gallons per minute HFS High Flow Suspension HSPF Hydrological Simulation Program - Fortran IBD International BMP Database IC/ID Illicit Connection/Illicit Discharge IDDE Illicit Discharge Detection and Elimination IGP Industrial General Permit in inch IND Industrial Service Supply in/hr Inches per hour
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IPM Integrated Pest Management J5&6 Jurisdictional Groups 5 and 6 JPA Joint Powers Authority LACFCD Los Angeles County Flood Control District LADWP Los Angeles Department of Water and Power LARWQCB Los Angeles Regional Water Quality Control Board lb Pound LID Low Impact Development LSPC Loading Simulation Program C++ MAR Marine Habitat MB Manhattan Beach MCM Minimum Control Measure MEP Maximum Extent Practical MIGR Migration of Aquatic Organisms min Minute MPN Most Probable Number MS4 Municipal Separate Storm Sewer System MUN Municipal and Domestic Supply NAV Navigation NH3 Ammonia as N NO3 Nitrate as N NOI Notice of Intent NPDES National Pollutant Discharge Elimination System O&M Operations and Maintenance OM&R Operations, Maintenance, and Replacement PCB Polychlorinated Biphenyl PIPP Public Information and Participation Program RAA Reasonable Assurance Analysis RARE Rare, Threatened, or Endangered Species RB Redondo Beach REC-1 Water Contact Recreation REC-2 Non-Contact Water Recreation RWL Receiving Water Limitation SBPAT Structural BMP Prioritization and Analysis Tool SCCWRP Southern California Coastal Watershed Research Project SCPWA Southern California Public Water Authority SFPUC San Francisco Public Utilities Commission SHELL Shellfish Harvesting SMB Santa Monica Bay SMBBB Santa Monica Bay Beaches Bacteria SPWN Spawning, Reproduction, and/or Early Development SUSMP Standard Urban Stormwater Management Program SWMM Storm Water Management Model, originally developed by USEPA SWQDv Storm Water Quality Design Volume SWQPA State Water Quality Protection Area
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SWRCB State Water Resources Control Board TAC Technical Advisory Committee TCu Total Copper TKN Total Kjeldahl Nitrogen as N TP Total Phosphorus TPb Total Lead TIE Toxicity Identification Evaluation TLR Total Load Reduction TMDL Total Maximum Daily Load TSS Total Suspended Solids TZn Total Zinc USEPA United States Environmental Protection Agency WARM Warm Freshwater Habitat WBPC Water Body-Pollutant Combination WDR Waste Discharge Requirement WER Water Effects Ratio WERF Water Environment Research Foundation WET Wetland Habitat WHAT Web-Based Hydrograph Analysis Tool WILD Wildlife Habitat WLA Waste Load Allocation WMA Watershed Management Area WMG Watershed Management Group WMMS Watershed Management Modeling System WMP Watershed Management Program WQBEL Water Quality-Based Effluent Limitation yr Year
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EXECUTIVE SUMMARY PURPOSE AND OBJECTIVES Following adoption of the 2012 Los Angeles Municipal Separate Storm Sewer System (MS4) National Pollutant Discharge Elimination System (NPDES) Permit1 (Permit), the Cities of Hermosa Beach, Manhattan Beach, Redondo Beach and Torrance, together with the Los Angeles County Flood Control District (LACFCD), collectively referred to as the Beach Cities Watershed Management Group (Beach Cities WMG) agreed to collaborate on the development of an Enhanced Watershed Management Program (EWMP) for the Santa Monica Bay (SMB) and Dominguez Channel Watershed areas within their jurisdictions (referred to herein as the Beach Cities EWMP Area). The Machado Lake Watershed is being addressed separately by the City of Torrance, and is not addressed in this EWMP. This EWMP is intended to facilitate effective, watershed-specific Permit implementation strategies in accordance with Permit Part VI.C. Watershed Management Program. This EWMP:
• Summarizes watershed-specific water quality priorities identified by the Beach Cities WMG;
• Outlines the program plan, including specific strategies, control measures and best management practices (BMPs)2 , necessary to achieve water quality targets (Water Quality-Based Effluent Limitations [WQBELs] and Receiving Water Limitations [RWLs]); and
• Describes the quantitative analyses completed to support target achievement and Permit compliance. In compliance with Section VI.C.4.b of the Permit, the Beach Cities WMG submitted to the Los Angeles Regional Water Quality Control Board (LARWQCB) a Notice of Intent (NOI) (Appendix A) to develop an EWMP on June 28, 2013, with a revised NOI submitted December 17, 2013 in response to comments received from LARWQCB staff. On March 27, 2014, the Beach Cities WMG received a letter from the Executive Officer of the LARWQCB approving the revised NOI submittal. In compliance with Section VI.C.4.c.iv of the Permit, the Beach Cities WMG then submitted a draft EWMP Work Plan to the LARWQCB on June 26, 2014. LARWQCB comments were not received on the EWMP Work Plan; therefore work proceeded on EWMP development consistent with the approach outlined in the EWMP Work Plan. The Beach Cities WMG was required by Section VI.C.4.c.iv of the Permit to submit a draft EWMP no later than June 30, 2015. This document has been developed to serve as the Beach Cities Draft EWMP and is consistent with the Work Plan previously submitted to the LARWQCB. Watershed Management Programs (WMPs) are a voluntary opportunity afforded by Section VI.C.1 of the Permit for Permittees to collaboratively or individually develop comprehensive watershed- 1 Order No. R4-2012-0175 NPDES Permit No. CAS004001 Waste Discharge Requirements for Municipal Separate Storm Sewer System (MS4) Discharges within the Coastal Watersheds of Los Angeles County, except those Discharges Originating from the City of Long Beach MS4. 2 For simplification, the term “BMP” will be used to collectively refer to strategies, control measures, and/or best management practices. The Permit also refers to these measures as Watershed Control Measures.
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specific control plans and are intended to facilitate Permit compliance and water quality target achievement. Enhanced WMPs (EWMPS) are WMPs which comprehensively evaluate opportunities for collaboration on multi-benefit regional projects that retain all non-stormwater runoff and runoff from the 85th percentile, 24 hour storm event while also achieving benefits associated with issues such as flood control and water supply. Where it is not feasible for regional projects to retain the 85th percentile 24 hour storm, the EWMP must demonstrate through a Reasonable Assurance Analysis, that applicable water quality targets should be achieved. Permittees within the Beach Cities Watershed Management Area (WMA) have elected to prepare an EWMP. The EWMP allows Permittees to collaboratively or individually develop comprehensive watershed-specific control plans which a) prioritize water quality issues, b) identify and implement focused strategies, control measures and BMPs, c) execute an integrated monitoring and assessment program, and d) allow for modification over time. In general, WMPs and EWMPs are intended to facilitate Permit compliance and water quality target achievement and goals that: 1) discharges from covered MS4s achieve applicable WQBELs and RWLs and do not include prohibited non-stormwater discharges; and 2) control measures are implemented to reduce the discharge of pollutants to the maximum extent practicable (MEP). Per Permit Section VI.C.1.e, WMPs and EWMPs are to be developed based on the LARWQCB’s WMAs or subwatersheds thereof. Consistent with Permit requirements, this EWMP is written to: 1. Be consistent with Permit provisions for EWMPs in Part VI.C.1.a.-f and Part VI.C.5-C.8; 2. Incorporate applicable State agency input on priority setting and other key implementation issues; 3. Provide for meeting water quality standards and other Clean Water Act obligations; 4. Include multi-benefit regional projects which retain stormwater from the 85th percentile 24 hour storm where feasible; 5. Include watershed control measures which achieve compliance with all interim and final WQBELs in drainage areas where retention of the 85th percentile 24 hour storm is infeasible with reasonable assurance; 6. Maximize the effectiveness of funding; 7. Incorporate effective innovative technologies; 8. Ensure existing requirements to comply with technology based effluent limitations and core requirements are not delayed; and 9. Ensure a financial strategy is in place. This EWMP is applicable to the Beach Cities WMG EWMP Area, which consists of all of the incorporated MS4 areas of the cities of Redondo Beach, Manhattan Beach, Hermosa Beach and Torrance (excluding the Machado Lake Watershed) and includes the infrastructure of the LACFCD within those jurisdictions (Figure ES-1). This area includes portions of two distinct HUC-12
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watersheds 3, Santa Monica Bay Watershed and Dominguez Channel Watershed, as summarized in
Table ES-1. The Wylie Sump, Bishop Montgomery Basin, and Ocean Basin are all retention basins with no outlet. Therefore, their drainage areas have been excluded from the EWMP Reasonable Assurance Analysis (RAA). The Del Amo Retention Basin also has no outlet, and is sized to capture runoff from at least the 85th percentile, 24 hour storm event. Because the Del Amo Retention Basin is within the Machado Lake Watershed, this drainage area is excluded from the EWMP.
• The western portion of the Beach Cities EWMP Area consists of approximately 7,840 acres of land that drains to Santa Monica Bay (SMB). This accounts for 52% of the total Beach Cities WMG area, and includes portions of the cities of Manhattan Beach, Redondo Beach, and Torrance, and the entirety of the City of Hermosa Beach. This portion of the study area is hereinafter referred to as the “SMB Watershed”.
• The northeastern portion of the Beach Cities EWMP Area is tributary to Dominguez Channel (including Torrance Carson Channel) and is comprised of approximately 7,380 acres of land. 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”.
Table ES-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%) The EWMP approach, including model selection, data inputs, critical condition selection, calibration performance criteria, and output types is consistent with the LARWQCB Reasonable Assurance Analysis Guidance Document (LARWQCB, 2014) and also leverages previous efforts where relevant models have already been developed. The individual water quality targets, BMPs, Reasonable Assurance Analyses, schedules, and costs for each of the watersheds are summarized in watershed-specific sections that follow. 3 A HUC-12 watershed is defined by a 12-digit hydrologic unit code (HUC) delineation, which identifies the watershed area based on six levels of classification: regional, sub-region, hydrologic basin, hydrologic sub-basin, watershed, and subwatershed.
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SANTA MONICA BAY WATERSHED Receiving waters for stormwater runoff from the Beach Cities EWMP Area were screened for water quality priorities by reviewing Total Maximum Daily Loads (TMDLs), the State’s 303(d) list, and additional water quality data. Each identified water quality priority for a given receiving water body was categorized as a water body-pollutant combination. Water body-pollutant combinations were classified into one of three categories, in accordance with Section VI.C.5(a).ii of the Permit. Table
ES-2 presents the prioritized water body-pollutant combinations within the SMB Watershed portion of the Beach Cities EWMP Area. Water body-pollutant combinations categorized below are subject to change based on future data collected as part of the Coordinated Integrated Monitoring Program (CIMP) or other monitoring program.
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Figure ES-1. Beach Cities EWMP Area
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Table ES-2. Water Body-Pollutant Combination Prioritization for the Santa Monica Bay
Watershed
Category Water Body Pollutant Reason for Categorization
1: Highest Priority
Santa Monica Bay Beaches Dry Weather Bacteria SMB Beaches Dry Weather Bacteria TMDL
Wet Weather Bacteria SMB Beaches Wet Weather Bacteria TMDL
Santa Monica Bay Trash/Debris SMB Debris TMDL DDTs SMB PCBs and DDT TMDL PCBs SMB PCBs and DDT TMDL 2: High Priority N/A None No other 303(d) listings exist for the Beach Cities portion of SMB
3: Medium Priority N/A None Outfall and receiving water monitoring data are not available for the Beach Cities portion of SMB The Reasonable Assurance Analysis was performed on bacteria in each of the defined analysis regions (Figure ES-2), as it was the controlling pollutant within the SMB Watershed. Bacteria targets are summarized in Table ES-3. Trash was not modeled as part of the Reasonable Assurance Analysis; instead, the Reasonable Assurance Analysis describes how the Beach Cities WMG Agencies will comply with the TMDL through their Trash Monitoring and Reporting Programs which are aimed at meeting the zero trash discharge definition in the TMDL (see Section 2.2.2 herein). The MS4 compliance targets for dichloro-diphenyl-trichloroethanes (DDTs) and polychlorinated biphenyls (PCBs) established in the Santa Monica Bay DDT & PCB TMDL were based on the assumption that the existing stormwater pollutant loads for DDT and PCBs were equal to or lower than what was needed to protect the Santa Monica Bay from these legacy pollutants (i.e., based on data used in the TMDL, no MS4 pollutant load reduction is expected to be required to demonstrate compliance with the TMDL). Therefore, it is assumed that no reductions in DDT and PCB loading from the Beach Cities WMG MS4s are required to meet the TMDL and reasonable assurance of compliance is assumed to be demonstrated without modeling. Monitoring of these pollutants will occur under the Beach Cities CIMP. Once three years of water quality data are collected, further source assessment will be considered and the categorization and prioritization of PCBs and DDT as MS4-related pollutants of concern will be reevaluated. If the CIMP monitoring data show that Beach Cities discharges are not in compliance with the TMDL, an RAA will be conducted for these pollutants and the EWMP will be revised accordingly.
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Table ES-3. Water Quality Targets for Modeled Pollutants in the Santa Monica Bay
Watershed
Water
Body Pollutant
RWL/WQBEL from
the Permit Note on Modeling Assumptions
Santa Monica Bay Beaches
Fecal Coliform (modeled as surrogate for all three fecal indicator bacteria in the Santa Monica Bay Beaches Bacteria [SMBBB] TMDL)
Allowable Exceedance Days per season per year (varies by beach Compliance Monitoring Location)
Used 90th percentile rain year (based on wet days) as the critical condition. Accounted for site-specific exceedance rates and the number of discharge days modeled for each Compliance Monitoring Location.
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Figure ES-2. Analysis Regions and Compliance Monitoring Locations within the SMB
Watershed portion of the Beach Cities EWMP Area
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Targets – Santa Monica Bay Target load reductions (TLRs) represent a numerical expression of the Permit compliance metrics that can be modeled and can serve as a basis for confirming, with reasonable assurance, that implementation of the proposed BMPs will result in attainment of the applicable TMDL-based WQBELs and RWLs in the Permit for Category 1 pollutants, or the Water Quality Objectives for Category 2 and Category 3 pollutants. For bacteria, the target load reductions are expressed as Allowable Exceedance Days (AEDs) per year. TLRs for both interim and final compliance deadlines are presented for all analysis regions including both open beach and point zero compliance monitoring locations (CMLs) (Table ES-4).
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Table ES-4. TLRs for Fecal Coliform in the Santa Monica Bay Watershed
Analysis
Region
Baseline Condition for the Critical
Year Allowed Condition for the Critical Year Target Load Reduction for the Critical Year6
Annual
Runoff
Average
Pollutant
Conc.5
Annual
Pollutant
Load
Annual
Runoff
Average
Pollutant
Conc.5
Annual
Pollutant
Load
Interim Target Load
Reduction
Final Target Load
Reduction
(ac-ft)
(MPN/
100mL) (1012 MPN) (ac-ft)
(MPN/
100mL) (1012 MPN)
Absolute
Load
% of
Baseline
Annual
Load
Absolute
Load
% of
Baseline
Annual
Load
(1012
MPN)
(1012
MPN) SMB-5-011 39 15,400 7.4 39 15,400 7.4
Interim target load reduction assessed on a watershed-wide basis
0 0% SMB-O-06 90 20,700 23.0 90 20,700 23.0 0 0% SMB-5-02 1516 28,600 534.8 1516 15,400 287.2 247.6 46.3% SMB-5-02/ SMB-5-032 123 23,000 34.9 123 23,000 34.9 0 0% SMB-5-031 65 36,200 29.0 65 36,200 29.0 0 0% SMB-5-03/ SMB-5-042 251 28,800 89.3 251 28,800 89.3 0 0% SMB-5-041 51 27,200 17.1 51 27,200 17.1 0 0% SMB-5-04/ SMB-5-052 37 17,800 8.2 37 17,800 8.2 0 0% SMB-5-051 472 31,400 182.8 472 31,400 182.8 0 0% SMB-5-05/ SMB-6-012 36 15,100 6.7 36 15,100 6.7 0 0% SMB-6-013 2118 27,100 706.6 2118 15,100 394.3 312.1 44.2% BCSump3 1191 25,800 379.4 1191 13,700 201.4 178 46.9% SMB-6-01/ SMB-6-022 621 21,200 162.5 621 21,200 162.5 0 0% SMB-6-021,4 358 22,600 99.6 358 22,600 99.6 0 0% SMB-6-03 206 24,500 62.2 206 24,500 62.2 0 0% SMB-6-04 621 27,400 209.9 621 27,400 209.9 0 0% SMB-6-051 230 32,000 90.9 230 32,000 90.9 0 0% SMB-O-08 425 26,500 138.9 425 26,500 138.9 0 0% SMB-6-061 19 28,000 6.7 19 28,000 6.7 0 0%
SMB
Watershed 8468 26,700 2789.9 8468 19,600 2052.1 368.9 13% 737.7 26%
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1 Anti-degradation site. 2 For the unmonitored tributary areas located in-between the CML tributary areas, TLRs were assigned from the geographically smaller of the two adjacent CML analysis regions. 3 “BCSump” was defined as a separate analysis region for modeling purposes. The baseline load for “BCSump” analysis region was combined with the baseline load of the “SMB-6-01” analysis region to equal the total baseline load contributing to the SMB-6-01 CML (“SMB-6-01+BCSump”). 4 The drainage area to Outfall SMB-O-07 is encompassed by analysis region SMB-6-02; therefore SMB-O-07 was analyzed as part of analysis region SMB-6-02. 5 The average pollutant concentration is estimated as the total pollutant load divided by total runoff volume. 6 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.
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Nine CMLs were assigned zero TLRs to reflect their historic good water quality (consistent with anti-degradation-based wet weather allowable exceedance days). Although the SMBBB TMDL requires only the maintaining of beach water quality at anti-degradation compliance locations, the Beach Cities EWMP will seek to implement nonstructural and Low Impact Development (LID)-based BMPs within the SMB portion of their EWMP area; this will further protect and potentially improve water quality at these beaches and is consistent with the Jurisdictional Group 5 and 6 (J5&6) Implementation Plan (Geosyntec Consultants, 2011).
BMPs – Santa Monica Bay EWMPs offer Permittees the opportunity to identify and implement focused strategies, control measures and BMPs to achieve applicable water quality targets (WQBELs and RWLs) and to reduce the discharge of pollutants to the maximum extent practicable. In order to demonstrate reasonable assurance, BMPs were identified and prioritized. 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 specific pollutants of concern were prioritized); and implementation feasibility as determined by the Beach Cities agencies. In general, nonstructural (e.g., programmatic) BMPs were prioritized over structural BMPs due to their lower relative cost. The following is an overview of the types of BMPs contemplated in this EWMP within the Santa Monica Bay Watershed. 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 including implementation of each agency’s Sanitary Sewer Management Plan consistent with Statewide Waste Discharge Requirements [WDRs], 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. 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 disconnection programs that redirect roof runoff to vegetated or otherwise pervious areas. Redevelopment: Beginning in 2001, redevelopment projects were required by the Permit (via the Standard Urban Stormwater Management Program [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 2003 (the point at which the Bacteria TMDL was implemented) and 2015 for the SMB EWMP area. Additionally, 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. These were taken into account as well. Non-MS4 Permitted Parcels or Areas: In general, this BMP assumes that regulated parcels/areas would be in compliance with the NPDES Statewide Storm Water Permit Waste Discharge
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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). Structural BMPs: Both existing and proposed regional and distributed structural BMPs are included in this EWMP to address water quality targets in the SMB Watershed. Because bacteria were identified as the controlling pollutant of concern, infiltration BMPs were prioritized as they are most effective for addressing bacteria. General design criteria for proposed structural BMPs are summarized in Table ES-5.
Table ES-5. Proposed Structural BMPs in the Santa Monica Bay Watershed
Analysis
Region Project Name1 Description
Design
Storage
Volume
(cu-ft)
Tributary
Area
(acres)
SMB-5-02 Manhattan Beach Infiltration Trench3
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 Distributed Green Streets
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-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 in Hermosa Beach, 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 sub-surface 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
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
1 All projects listed in this table 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 2 This includes upstream BMPs and associated tributary drainage areas 3 Alternative project locations have also been identified
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Distributed green streets BMPs are proposed and were modeled as part of the Reasonable Assurance Analysis within select analysis regions, at analysis region-specific implementation levels (e.g., runoff from 14% of single family residential, multi-family residential, and commercial land uses would be treated by green streets BMPs). It should be noted that if at any time in the future, 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 subwatershed and within the same timeline, to meet an equivalent subwatershed load reduction. In addition, if monitoring data indicate that more easily implementable, alternative BMPs can provide equivalent (or superior) load reductions, these alternative BMPs may be implemented at the discretion of the WMG Agencies. The Beach Cities WMG will provide timely notification and project details to the Regional Board in the case of any project substitutions.
Demonstration of Compliance – Santa Monica Bay To demonstrate wet weather compliance, a Reasonable Assurance Analysis was conducted in which the following steps were taken: 1. For each analysis region, develop TLRs for 90th percentile year based on Permit requirements and LARWQCB guidance; 2. Identify structural and non-structural BMPs that were either implemented after applicable TMDL effective dates or are planned for implementation in the future: a. Assume a load reduction for non-modeled non-structural (or programmatic) BMPs (five percent of baseline pollutant load); b. Calculate load reductions for public incentives for retrofits on private property (e.g., downspout disconnects) and redevelopment (e.g., low impact development requirements); c. Calculate load reductions attributable to anticipated new permit compliance activities of non-MS4 Permittees (e.g., Industrial General Permit holders and California Department of Transportation [Caltrans]); and d. Calculate load reductions for proposed regional BMPs that were identified in existing plans; 3. Compare total estimated load reduction for each analysis region with the TLRs; and 4. Meet the TLRs by backfilling the remaining load reduction with new regional or distributed green streets BMPs, and with green streets that address a certain percentage of specific developed land uses. Results of the Reasonable Assurance Analysis for each analysis region in the SMB watershed are presented in Table ES-6 below. The values provided correspond to the load reductions attributable to the BMP types following the applicable final and interim compliance deadlines. As shown, the final TLR is met in all SMB watershed analysis regions with varying applications of non-structural and regional BMPs. The interim 50% TLR is met through a combination of nonstructural and existing regional BMPs.
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For dry weather bacteria compliance, a qualitative analysis was conducted to show compliance at each of the CMLs. Many CMLs have an effective diversion such that they are consistently operational, well maintained, and sized to effectively eliminate discharges to the surf zone during year-round dry weather days. For the remaining smaller outfalls a systematic screening conducted in 2002 demonstrated that there was no discharge to the wave wash during summer dry weather from these storm drains. Rescreening of outfalls will be conducted as part of the Non-Stormwater Screening and Monitoring in the Coordinated Integrated Monitoring Program and will include both summer dry weather and winter dry weather screening. For the CMLs in the SMB Watershed that have anti-degradation based allowed exceedance days for both winter-dry and summer-dry weather, reasonable assurance is assumed to be demonstrated through the basis that the TMDL established their allowed exceedance days based on historic conditions (i.e., no water quality improvements were necessary).
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Table ES-6. Santa Monica Bay Watershed – Fecal Coliform Reasonable Assurance Analysis Results – Interim and Final
Compliance
Analysis
Region
Implementation Benefits (average load reduction as % of baseline load for critical year)
TLR
Compliance
(TLR Met)?
Non-Structural
BMPs
(Non-Modeled)
Public Retrofit
Incentives +
Redevelopment
Non-
MS4
Regional
BMPs
Distributed
BMPs
Distributed
BMP
Implementation
Level
Estimated
Load
Reduction SMB-5-01 5% 2% 0% 0% 0% N/A 7% 0% Yes SMB-O-06 5% 2% 0% 0% 0% N/A 7% 0% Yes SMB-5-02 5% 4% 2% 36% 3% 5% MFR/COM/SFR 50% 46% Yes SMB-5-02/5-03 5% 3% 0% 0% 0% N/A 8% 0% Yes SMB-5-03 5% 3% 0% 0% 0% N/A 8% 0% Yes SMB-5-03/5-04 5% 4% 0% 5% 0% N/A 15% 0% Yes SMB-5-04 5% 5% 0% 1% 1%2 N/A 12% 0% Yes SMB-5-04/5-05 5% 4% 0% 2% 0% N/A 11% 0% Yes SMB-5-05 5% 4% 5% 3% 0% N/A 18% 0% Yes SMB-5-05/6-01 5% 3% 0% 2% 0% N/A 10% 0% Yes SMB-6-01+ BCSump1 5% 3% 3% 33% 2% 25% MFR/COM/SFR 46% 45% Yes SMB-6-01/6-02 5% 2% 4% 0% 0% N/A 11% 0% Yes SMB-6-02 5% 3% 1% 4% 0% N/A 13% 0% Yes SMB-6-03 5% 3% 5% 10% 0% N/A 23% 0% Yes SMB-6-04 5% 4% 3% 0% 0% N/A 12% 0% Yes SMB-6-05 5% 3% 6% 0% 0% N/A 15% 0% Yes SMB-O-08 5% 2% 0% 0% 0% N/A 7% 0% Yes SMB-6-06 5% 5% 0% 0% 0% N/A 10% 0% Yes
Final
Compliance
Deadline
(2021)
5% 3% 3% 21% 1% N/A 33% 26% Yes
Interim
Compliance
Deadline
(2018)
2.5% 0.8% 1.5% 9.6% 0% N/A 14.4% 13% Yes
1 “BCSump” was defined as a separate analysis region for modeling purposes. The baseline load for “BCSump” analysis region was combined with the baseline load of the “SMB-6-01” analysis region to equal the total baseline load contributing to the SMB-6-01 CML (“SMB-6-01+BCSump”). 2 D istributed green street BMP load reduction in SMB-5-04 is a result of the existing filter/infiltration boxes retrofitted on the east side of Hermosa Avenue in the City of Hermosa Beach.
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Schedule – Santa Monica Bay In order to meet the compliance deadlines for the water body-pollutant combinations discussed above based on load reduction projections in the Reasonable Assurance Analysis, the proposed structural BMPs within the SMB Watershed would be implemented as described in Figure ES-3.
Figure ES-3. Proposed Project Sequencing in the Santa Monica Bay Watershed
COLOR
KEY Funding Phase Design Phase Construction/ Installation Phase
BMP Location/Name
Timeline 2015 2016 2017 2018 2019 2020 2021 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 1 Alternative project locations have also been identified DOMINGUEZ CHANNEL WATERSHED Within the Dominguez Channel Watershed, water body-pollutant combinations were classified into one of three categories, in accordance with Section VI.C.5(a).ii of the Permit. Table ES-7 presents the prioritized water body-pollutant combinations within the Dominguez Channel Watershed portion of the Beach Cities EWMP Area. Water body-pollutant combinations categorized below are subject to change based on future data collected as part of the CIMP or other monitoring program.
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Table ES-7. Water Body-Pollutant Prioritization for the Dominguez Channel Watershed
Category Water Body Pollutant Reason for Categorization
1: Highest Priority
Dominguez Channel (including Torrance Lateral) 1
Toxicity Dominguez Channel Toxics TMDL Total Copper Dominguez Channel Toxics TMDL Total Lead Dominguez Channel Toxics TMDL Total Zinc Dominguez Channel Toxics TMDL
Dominguez Channel Estuary
Total Copper Dominguez Channel Toxics TMDL Total Lead Dominguez Channel Toxics TMDL Total Zinc Dominguez Channel Toxics TMDL Cadmium Dominguez Channel Toxics TMDL DDT Dominguez Channel Toxics TMDL Total PAHs Dominguez Channel Toxics TMDL PCBs Dominguez Channel Toxics TMDL
2: High Priority
Dominguez Channel (including Torrance Lateral) Indicator Bacteria 303(d) List Ammonia 303(d) List Dominguez Channel Estuary Indicator Bacteria 303(d) List Ammonia 303(d) List
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) pH Historic exceedance of the Basin Plan Objective (6.5 – 8.5) Selenium Historic exceedances of the CTR continuous concentration water quality objective (5.0 ug/L) Mercury Historic exceedances of the CTR human health criterion for organisms only (0.051 ug/L) Cadmium Historic exceedances of the CTR continuous concentration water quality objective (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) Chromium Historic exceedances of the ERL proposed sediment quality guidelines from the National Status and Trends database (81 mg/kg sediment) Silver Historic exceedances of the CTR continuous saltwater objective (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)
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 criterion for organisms only (0.051 ug/L) Thallium Historic exceedances of the ERL proposed sediment quality guidelines from the National Status and Trends database (6.3 ug/L sediment)
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For the purposes of the wet weather Reasonable Assurance Analysis, the EWMP area directly 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. For the purposes of the dry weather Reasonable Assurance Analysis for which bacteria are the only water body-pollutant combination, the EWMP area draining to Dominguez Channel was combined into the same single analysis region. The Dominguez Channel watershed analysis regions are shown in
Figure ES-4. The wet weather Reasonable Assurance Analysis was performed on copper, lead, zinc, and bacteria (fecal coliform) within the Dominguez Channel Watershed. Water quality targets were identified for Dominguez Channel Watershed in the same manner as in SMB Watershed. 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. For metals, the waste load allocation (WLA) assigned to MS4 discharges, as shown in Table ES-8, is a mass-based allocation based on the freshwater targets for Dominguez Channel and Torrance Lateral (using ambient hardness at the time of sampling) multiplied by the daily volume and is shared amongst all MS4 Permittees that discharge to the freshwater portion of Dominguez Channel and Torrance Lateral. The water quality targets for prioritized water body-pollutant combinations are summarized in Table ES-8.
Table ES-8. Water Quality Targets for the Dominguez Channel Watershed
Water Body Pollutant
RWL/WQBEL from the Permit
or Assumed Based on Other
Similar Los Angeles Region
TMDLs1 Approach for Applying the Critical
Period
Dominguez Channel Fecal Coliform 19% allowed exceedance of the REC-1 water quality objective, (400 MPN/100mL) on non-high flow suspension days
90th percentile year (based on wet days) was used as the critical condition. Allowable number of wet weather exceedance days for the critical year was set to 19% of non-high flow suspension wet days, rounding down.
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Water Body Pollutant
RWL/WQBEL from the Permit
or Assumed Based on Other
Similar Los Angeles Region
TMDLs1 Approach for Applying the Critical
Period Total Copper WQBEL=9.7 ug/L Waste load allocation (WLA)= Concentration*Daily Volume 90th percentile daily load during wet weather was used as the critical condition. This calendar day was identified for each metal by ranking daily loads for metal wet days between 2003 and 2012. Total Lead WQBEL=42.7 ug/L WLA= Concentration*Daily Volume Total Zinc WQBEL=69.7 ug/L WLA= Concentration*Daily Volume 1 MS4 Permittees may demonstrate compliance with the freshwater metals allocations for Dominguez Channel and Torrance Lateral via any one of three different means: a. Final allocations are met. b. CTR total metals criteria are met instream. c. CTR total metals criteria are met in the discharge. Although toxicity was identified as a Category 1 water body-pollutant combination, it was not modeled for Dominguez Channel and the Torrance Lateral since it is not a wet weather parameter that can be modeled using currently available Reasonable Assurance Analysis tools for the Los Angeles Region. Instead, the Reasonable Assurance Analysis qualitatively describes how the Beach Cities WMG Agencies will comply with the TMDL WQBELs. Toxicity will continue to be monitored under the Beach Cities’ CIMP. Although ammonia was identified as a Category 2 water body-pollutant combination (Table ES-7), monitoring data since 2003 show that all water quality samples at monitoring locations S28 and TS19 meet the freshwater Basin Plan Objective for ammonia, and as a result, ammonia was not modeled as part of the Beach Cities’ Reasonable Assurance Analysis. Similarly, the Category 3 water body-pollutant combinations cyanide, pH, selenium, mercury, and cadmium, all within the Torrance Lateral, were not modeled either due to a lack of demonstrated MS4 linkage or due to data limitations. These 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. 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 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)
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list for Dominguez Channel and therefore is not included as a Category 2 pollutant for Dominguez Channel (including Torrance Lateral).
Figure ES-4. Analysis Regions within the Dominguez Channel Watershed portion
of the Beach Cities EWMP Area
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Targets – Dominguez Channel As discussed previously, TLRs represent a numerical expression of the Permit compliance metrics (e.g., allowed mass per day for metals for wet weather and allowable exceedance days per year for bacteria) that can be modeled and can serve as a basis for confirming, with reasonable assurance, that implementation of the proposed BMPs will result in attainment of the applicable TMDL-based WQBELs and RWLs in the Permit for Category 1 pollutants, or the Water Quality Objectives for Category 2 and Category 3 pollutants. TLRs were developed for the single combined analysis region (Table ES-9).
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Table ES-9. TLRs and Baseline Conditions for Pollutants in the Dominguez Channel Watershed
Pollutant
Compliance
Deadline
Baseline Data for Critical Condition
Allowable Discharge for Critical
Condition
Interim Target Load
Reduction[4]
Final Target Load
Reduction[4]
Runoff
Volume
Pollutant
Conc.[3]
Pollutant
Load
Runoff
Volume
Pollutant
Conc. [3]
Pollutant
Load
Absolute
Load
% of
Baseline
Load
Absolute
Load
% of
Baseline
Load Copper 2032 301 ac-ft/day 25.8 ug/L 21 lb/day 301 ac-ft/day 9.7ug/L 8 lb/day N/A[1]
13 lb/day 62% Lead 2032 275 ac-ft/day 11.6 ug/L 8.7 lb/day 275 ac-ft/day 42.7 ug/L 32 lb/day 0 lb/day 0% Zinc 2032 291 ac-ft/day 290.2 ug/L 230 lb/day 291 ac-ft/day 69.7 ug/L 55 lb/day 175 lb/day 76%
Fecal coliform
2022[2] 6,048 ac-ft/year 20,080 MPN/100 mL 1,498 *1012 MPN/yr 6,048 ac-ft/year 18,413 MPN/100mL 1,373*1012 MPN/yr 124*1012 MPN/yr 8.3% - -
2027[2] 6,048 ac-ft/year 20,080 MPN/100 mL 1,498 *1012 MPN/yr 6,048 ac-ft/year 16,667 MPN/100mL 1,243*1012 MPN/yr 255*1012 MPN/yr 17% - -
2032[2] 6,048 ac-ft/year 20,080 MPN/100 mL 1,498 *1012 MPN/yr 6,048 ac-ft/year 13,454 MPN/100 mL 1,004*1012 MPN/yr - - 493*1012 MPN/yr 33%
1 The interim deadline for Dominguez Channel Toxic TMDL was March 23, 2012. Hence the interim target load reduction is not applicable since this date has passed. 2 Proposed, non-TMDL compliance schedule. 3 Fecal coliform concentrations are 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. 4 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.
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BMPs – Dominguez Channel Both existing and proposed regional and distributed BMPs are included in this EWMP to address water quality targets in the Dominguez Channel Watershed. Distributed green streets BMPs are proposed and were modeled as part of the Reasonable Assurance Analysis 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). General design criteria for proposed structural BMPs are summarized in Table ES-10.
Table ES-10. Proposed Structural BMPs in the Dominguez Channel Watershed
Analysis
Region Project Name1 Description
Design
Storage
Volume
(cu-ft)
Tributary
Area
(acres)
DC – MB/RB Powerline Easement 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
DC- MB/RB Distributed Green Streets BMPs
The distributed green streets (to address runoff from 14% of single family residential, multi-family residential, commercial, and industrial 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. 636,300 200
DC-Torrance Catch Basin Inlet Filters The City of Torrance plans to retrofit 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. *Alternative project location has also been identified It should be noted that if at any time specific distributed green streets or regional/centralized BMPs are found to be infeasible for implementation, or new innovative BMPs are developed, alternative BMPs or operational changes will be planned within the same analysis region and within the same timeline, to meet an equivalent analysis region 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. The
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Beach Cities WMG will provide timely notification and project details to the Regional Board in the case of any project substitutions.
Demonstration of Compliance – Dominguez Channel To demonstrate wet weather compliance, the Reasonable Assurance Analysis was performed according to the following steps: 1. For each analysis region, develop TLRs for the critical condition (90th percentile year for bacteria and 90th percentile load day for metals) based on Permit requirements and LARWQCB guidance; 2. Identify structural and non-structural BMPs that were either implemented after applicable TMDL effective dates or are planned for implementation in the future: a. Assume a load reduction for non-modeled non-structural (or programmatic) BMPs (five percent of baseline pollutant load); b. Calculate load reductions for public incentives for private retrofit (e.g., downspout disconnects) and redevelopment; c. Calculate load reductions attributable to anticipated new permit compliance activities of non-MS4 entities (e.g., Industrial General Permit holders and Caltrans); and d. Calculate load reductions for proposed regional BMPs that were identified in existing plans; 3. Compare total estimated load reduction for each analysis region with the TLRs; and 4. Meet the TLRs 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. Within the DC-Torrance analysis region, an estimated load reduction attributable to distributed catch basin inlet filters was derived from a review of literature/studies on their performance (Appendix B). If the estimated performance is supported by future monitoring data, these filters may be used as alternative BMPs in other portions of the Dominguez Channel Watershed. Results of the wet weather Reasonable Assurance Analysis for each analysis region are presented in Table ES-11 below. The values provided correspond to the load reductions attributable to the BMP types following the applicable compliance deadline. As shown, the TLRs are predicted to be met in the DC-RB/MB analysis region for metals and fecal coliforms with varying applications of non-structural and regional BMPs as described previously. Within the DC-Torrance analysis region, the TLRs will be met through implementation of catch basin inlet filters as needed. Monitoring and subsequent adaptive management will be employed to evaluate the achieved load reductions prior to each of the compliance deadlines, installing additional filters as needed until compliance is achieved for every applicable WQBEL or RWL.
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For dry weather, bacteria is the only applicable pollutant in the Dominguez Channel Watershed, and it is a Category 2 water body-pollutant combination (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 WMG 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.
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Table ES-11. Dominguez Channel Watershed – Reasonable Assurance Analysis 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 Non-
MS4 Regional
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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Schedule – Dominguez Channel In order to meet the compliance deadlines for the water body-pollutant combinations based on load reduction projections in the Reasonable Assurance Analysis, the proposed structural BMPs within the Dominguez Channel Watershed would be implemented per the timeline provided in Figure
ES-5. Project construction is proposed to be complete with project start-up beginning in 2020, at which point load reduction credit begins in the Reasonable Assurance Analysis.
Figure ES-5. Project Sequencing in the Dominguez Channel Watershed
COLOR
KEY Funding Phase Design Phase Construction/ Installation Phase
BMP Location/Name
Timeline 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 Dominguez Channel Watershed Catch basin inlet filters in DC-Torrance 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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COMPLIANCE SCHEDULE
Table ES-12 summarizes the existing and proposed implementation actions and dates within the Santa Monica Bay and Dominguez Channel Watersheds, for each identified water body-pollutant combination. The compliance schedule for Category 1 water body-pollutant combinations is consistent with the associated TMDLs. The compliance schedule for the Category 2 water body-pollutant combinations 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 ES-12, the compliance schedule for the Category 3 water body-pollutant combinations will be dependent on the results of the CIMP.
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Table ES-12. Compliance Schedule for the Santa Monica Bay and Dominguez Channel Watersheds
Category Watershed Pollutant(s)
Wet/Dry
Weather Date Implementation Action 1: Highest Priority Dominguez Channel and Dominguez Channel Estuary
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 Santa Monica Bay Bacteria Dry 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 July 2018 Interim: 50% single sample ED reduction July 2021 Final: Geometric Mean [GM] targets met Final: Single sample AED targets met Trash/Debris N/A March 2016 Interim: 20% load reduction met through implementation of trash excluders March 2017 Interim: 40% load reduction met through implementation of trash excluders August 2018 Interim (Cities of Hermosa Beach and Redondo Beach): Determination of compliance strategy for installing full capture trash systems March 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 August 2019 Interim (City of Manhattan Beach): Determination of compliance strategy for installing full capture trash systems.
March 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. March 2023 Final (City of Manhattan Beach): 100% reduction in trash from baseline through the installation of full capture trash systems serving MS4 drainage area to Santa Monica Bay.
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Category Watershed Pollutant(s)
Wet/Dry
Weather Date Implementation Action DDTs N/A N/A Since the TMDL effectively implements an anti-degradation 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 Reasonable Assurance Analysis), no compliance schedule is proposed. PCBs N/A N/A
2: High Priority Dominguez Channel and Dominguez Channel Estuary
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 minimum control measure (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
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Category Watershed Pollutant(s)
Wet/Dry
Weather Date Implementation Action 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. 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 DC-Torrance 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.
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Category Watershed Pollutant(s)
Wet/Dry
Weather Date Implementation Action 3: Medium Priority9
Dominguez Channel and Dominguez Channel Estuary
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
ES-7. 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 water,10 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.
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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PLANNING LEVEL COST OPINION Planning-level cost opinions associated with implementation of the proposed structural best management practices within the Beach Cities WMG area are provided based on results from the Reasonable Assurance Analysis for the Beach Cities EWMP. 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 water body-pollutant combination. EWMP planning-level cost opinions were developed for the proposed structural BMPs in addition to programmatic costs. Costs approximated for structural BMPs include “hard” costs for tangible assets and “soft” costs, which include considerations such as design and permitting. Table ES-13 summarizes the total 20-year life-cycle costs 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. These cost opinions are provided for information only, and it is recognized that should monitoring information demonstrate that alternative, less-expensive BMPs are equally (or superior) to those described herein, that these alternative BMPs may be implemented at the discretion of the WMG agencies. Not included in these costs are the annual monitoring costs for implementing the CIMP or the costs associated with implementing baseline and enhanced MCMs.
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Table ES-13. Cost Opinion for Proposed Structural BMPs in Santa Monica Bay and Dominguez Channel Watersheds
Watershed/
Analysis Region Location of BMP Project Name
Construction Cost
Range Annual O&M Range
Total 20-Year Life-
Cycle1 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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FINANCING DISCUSSION The availability of funds will be critical for the implementation of the EWMP. Section 7 of this EWMP provides an overview of potentially available funding sources to pay for programs proposed in the EWMP. Examples show that a multi-pronged funding strategy using multiple sources rather than rely on a single storm drain fee may be the most prudent approach. A list of potential fees and charges has been developed, which will be further considered and explored by the Beach Cities WMG in the future:
• Vehicle license and vehicle rental fees
• Solid waste management surcharge
• Water service surcharge (under AB850)
• Property assessment
• Fines (not a stable source, it is an exemption under Proposition 26)
• Financial subsidy to encourage private sector participation to develop local and district projects
• One time capital recovery fee
• Dedicated storm drain fee
• Taxes (e.g. fuel taxes)
• A TMDL fee / tax could be developed based on the pollutant contribution from polluters / activities In addition, Public Private Partnerships and alternative delivery and financing methods may facilitate and streamline implementation, and could result in program cost reductions. From the analysis of potential costs in this section as summarized in Table ES-13, 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 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.
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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.
• 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.
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1 INTRODUCTION Following adoption of the 2012 Los Angeles Municipal Separate Storm Sewer System (MS4) National Pollutant Discharge Elimination System (NPDES) Permit4 (Permit), the Cities of Hermosa Beach, Manhattan Beach, Redondo Beach and Torrance, together with the Los Angeles County Flood Control District (LACFCD), collectively referred to as the Beach Cities Watershed Management Group (Beach Cities WMG) agreed to collaborate on the development of an Enhanced Watershed Management Program (EWMP) for the Santa Monica Bay (SMB) and Dominguez Channel areas within their jurisdictions (referred to herein as the Beach Cities EWMP Area). This EWMP is intended to facilitate effective, watershed-specific Permit implementation strategies in accordance with Permit Part VI.C. and summarizes the SMB and Dominguez Channel-specific water quality priorities identified jointly by the Beach Cities WMG, outlines the program plan, including specific strategies, control measures and best management practices (BMPs)5, necessary to achieve water quality targets (Water Quality-Based Effluent Limitations [WQBELs] and Receiving Water Limitations [RWLs]), and describes the quantitative analyses completed to support target achievement and Permit compliance. In compliance with Section VI.C.4.b of the Permit, the Beach Cities WMG submitted to the Los Angeles Regional Water Quality Control Board (LARWQCB) a Notice of Intent (NOI) to develop an EWMP on June 28, 2013 with a revised NOI submitted December 17, 2013. On March 27, 2014, the Beach Cities WMG received a letter from the Executive Officer of the LARWQCB approving the revised NOI submittal. In compliance with Section VI.C.4.c.iv of the Permit, the Beach Cities WMG then submitted a draft EWMP Work Plan to the LARWQCB on June 26, 2014. Comments were not received. As the next step in EWMP development, the Beach Cities WMG was required by Section VI.C.4.c.iv of the Permit to submit a draft EWMP no later than June 30, 2015. This document has been developed to serve as the Beach Cities Draft EWMP and is consistent with the Work Plan previously submitted to the LARWQCB. 1.1 PURPOSE AND REGULATORY FRAMEWORK Watershed Management Programs (WMPs) are a voluntary opportunity afforded by Section VI.C.1 of the Permit for Permittees to collaboratively or individually develop comprehensive watershed-specific control plans and are intended to facilitate Permit compliance and water quality target achievement. Enhanced WMPs (EWMPS) are WMPs which comprehensively evaluate opportunities for collaboration on multi-benefit regional projects that retain all non-stormwater runoff and runoff from the 85th percentile, 24 hour storm event while also achieving benefits associated with issues such as flood control and water supply. Additional details on the regulatory background for NPDES
4 Order No. R4-2012-0175 NPDES Permit No. CAS004001 Waste Discharge Requirements for Municipal Separate Storm Sewer System (MS4) Discharges within the Coastal Watersheds of Los Angeles County, except those Discharges Originating from the City of Long Beach MS4. 5 For simplification, the term “BMP” will be used to collectively refer to strategies, control measures, and/or best management practices. The Permit also refers to these measures as Watershed Control Measures.
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Permit and Water Quality Standards and the Permit specifics of WMPs and EWMPs are provided below.
1.1.1 NPDES PERMIT The 1972 Clean Water Act (CWA) established the NPDES Program to regulate the discharge of pollutants from point sources to waters of the United States. In 1990, the United States Environmental Protection Agency (USEPA) developed Phase I of the NPDES Stormwater Permitting Program, which established a framework for regulating municipal and industrial discharges of stormwater and non-stormwater that had the greatest potential to negatively impact water quality within waters of the United States. In particular, under Phase I, USEPA required NPDES Permit coverage for discharges from medium and large MS4 servicing populations greater than 100,000 persons. Operators of MS4s regulated under the Phase I NPDES Stormwater Program were required to obtain permit coverage for municipal discharges of stormwater and non-stormwater to waters of the United States. The LARWQCB designated the MS4s owned and/or operated by the incorporated cities and Los Angeles County unincorporated areas within the Coastal Watersheds of Los Angeles County as a large MS4 due to the total population of Los Angeles County. All MS4s within the Coastal Watersheds of Los Angeles County except for the City of Long Beach MS4 are subject to the waste discharge requirements set forth in Order No. R4-2012-0175 Permit No. CAS004001. General permit requirements, which are relevant to and must be ensured by WMPs, include (i) a requirement to effectively prohibit non-stormwater discharges through the MS4, (ii) requirements to implement controls to reduce the discharge of pollutants to the maximum extent practicable, and (iii) other provisions the LARWQCB has determined appropriate for the control of such pollutants.
1.1.2 WATER QUALITY STANDARDS AND TOTAL MAXIMUM DAILY LOADS (TMDLS) The CWA also required that the RWQCB establish water quality standards for each water body in its region. Water quality standards include beneficial uses, water quality objectives and criteria that are established at levels sufficient to protect those beneficial uses, and an anti-degradation policy to prevent degrading waters. The LARWQCB adopted a Water Quality Control Plan - Los Angeles Region (hereinafter Basin Plan) on June 13, 1994 addressing this portion of the CWA which designates beneficial uses, establishes water quality objectives, and contains implementation programs and policies to achieve those objectives for all waters in the Los Angeles Region. Pursuant to California Water Code section 13263(a), the requirements of the Permit implement the Basin Plan. The State Water Resources Control Board (State Water Board) adopted the Water Quality Control Plan for Ocean Waters in California, California Ocean Plan (hereinafter Ocean Plan) in 1972 and adopted the most recent amended Ocean Plan on September 15, 2009. The Ocean Plan also establishes water quality objectives and a program of implementation to protect beneficial uses at all MS4 discharge points within Los Angeles County coastal watersheds with the exception of Long Beach.
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CWA Section 303(d)(1) requires each state to identify the waters within its boundaries that do not meet water quality standards. Water bodies that do not meet water quality standards are considered impaired and are placed on the state’s “CWA Section 303(d) List”. For each listed water body, the state is required to establish a TMDL for each pollutant impairing the water quality standards in that water body. TMDLs establish the allowable pollutant loadings for a water body and provide the basis upon which to establish water quality-based controls (required by NPDES Permits). The 2010 CWA Integrated Report and updated 303(d) list were approved by the State Water Resources Control Board (SWRCB) on August 4, 2010 and by the USEPA on October 11, 2011. Provisions regarding TMDLs are included in NPDES Permits once they have been developed and adopted. Specific TMDLs applicable to the Beach Cities EWMP Area are discussed in more detail in Sections 2 and 3.
1.1.3 WMPS AND ENHANCED WMPS The voluntary WMPs and EWMPs allow Permittees to collaboratively or individually develop comprehensive watershed-specific control plans which a) prioritize water quality issues, b) identify and implement focused strategies, control measures and BMPs, c) execute an integrated monitoring and assessment program, and d) allow for modification over time. In general, WMPs and EWMPs are intended to facilitate Permit compliance and water quality target achievement with the goals that: 1) discharges from covered MS4s achieve applicable WQBELs and RWLs and do not include prohibited non-stormwater discharges; and 2) control measures are implemented to reduce the discharge of pollutants to the maximum extent practicable (MEP). Per Permit Section VI.C.1.e, WMPs and EWMPs are to be developed based on the LARWQCB’s Watershed Management Areas (WMAs) or subwatersheds thereof. Permittees within a WMA may elect to prepare an EWMP, which is defined in the Permit as a WMP that comprehensively evaluates opportunities for collaboration amongst Permittees and other partners on multi-benefit regional projects that, wherever feasible, retain, 1) all non-stormwater runoff, and 2) all stormwater runoff from the 85th percentile 24 hour storm event while also achieving benefits associated with issues such as flood control and water supply. Where regional projects cannot achieve these standards, the EWMP must demonstrate through a Reasonable Assurance Analysis (RAA), that applicable water quality targets are achieved. The Permit specifies that an EWMP shall: 1. Be consistent with Permit provisions in Part VI.C.1.a.-f and Part VI.C.5-C.8, 2. Incorporate applicable State agency input on priorities and key implementation factors, 3. Provide for meeting water quality standards and other CWA obligations, 4. Include multi-benefit6 regional projects which retain stormwater from the 85th percentile 24 hour storm
6 Potential multiple benefits include neighborhood greening, water conservation and/or supply, groundwater
recharge, public education and/or awareness, etc.
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5. Include watershed control measures which achieve compliance with all interim and final WQBELs in drainage areas where retention of the 85th percentile 24 hour storm is infeasible with reasonable assurance, 6. Maximize the effectiveness of funding, 7. Incorporate effective innovative technologies, 8. Ensure existing requirements to comply with technology based effluent limitations and core requirements are not delayed, and 9. Ensure a financial strategy is in place. 1.2 APPLICABILITY OF EWMP The agencies of the Beach Cities WMG have been working together since 2004 to implement the previously developed Jurisdictional Groups 5 and 6 Implementation Plan for the Santa Monica Bay Beaches Bacteria (SMBBB) TMDLs, including a BMP Siting Study (Geosyntec, 2011a) and Dry Weather Source Characterization and Control Study (Geosyntec, 2011b) for two high priority subwatersheds, along with joint implementation of programmatic solutions. Since 2004, the Beach Cities have also been jointly funding receiving water monitoring consistent with the Coordinated Shoreline Monitoring Plan for the SMBBB TMDLs along the shoreline of the Beach Cities WMG EWMP Area. These ongoing efforts by the Beach Cities WMG to comply with the SMBBB TMDLs have been an effective facilitator for the development of the EWMP. This EWMP is applicable to the Beach Cities EWMP Area, which consists of all of the incorporated MS4 areas of the cities of Redondo Beach, Manhattan Beach, Hermosa Beach and Torrance and includes the infrastructure of the LACFCD within those jurisdictions (Figure 1-1), with the exception of the Machado Lake Watershed which is being addressed separately by the City of Torrance, and is not addressed in this EWMP. A small portion of the City of Redondo Beach is located within the Machado Lake Watershed boundary but has requested to be removed from the Machado Lake Implementation Plan and other compliance requirements pertaining to the Machado Lake Watershed. Further details are described in Section 1.2.1. The beach areas within the geographic area of the Beach Cities WMG do not have any storm drain infrastructure that collect and discharges beach runoff directly to the receiving water and are therefore considered non-point sources and not subject to the MS4 Permit or EWMP requirements. Similarly, the Hermosa Beach and Manhattan Beach piers are not part of the MS4; they are non-point sources excluded from the MS4 Permit scope and therefore the EWMP. The Redondo Beach Pier including the King Harbor Marina are included in the geographic scope of the Beach Cities WMG EWMP as these areas are equipped with MS4 infrastructure. The Wylie Sump, Bishop Montgomery Basin, and Ocean Basin are all retention basins with no outlet. Therefore, their drainage areas have been excluded from the EWMP, with no analyses required. The Del Amo Retention Basin also has not outlet, and is sized to capture runoff from at least the 85th percentile, 24 hour storm event. Because the Del Amo Retention Basin is within the Machado Lake Watershed, this drainage area is excluded from the EWMP.
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Figure 1-1. Beach Cities EWMP Area
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1.2.1 CITY OF REDONDO BEACH CONTRIBUTION AND COMPLIANCE STRATEGY IN THE
MACHADO LAKE WATERSHED Machado Lake is a 40 acre lake located in the Ken Malloy Harbor Regional Park and is managed by the City of Los Angeles, Department of Recreation and Parks. The Machado Lake watershed includes portions of Lomita, Torrance, Carson, City of Los Angeles, County of Los Angeles, Palos Verdes Estates, Rancho Palos Verdes, Rolling Hills, Rolling Hills Estates and California Department of Transportation. Machado Lake is listed on the 1998, 2002, and 2006, and 2010 Clean Water Act Section 303(d) lists of impaired water bodies due to eutrophic conditions, algae and odors (Nutrients); chlordane, dichlorodiphenyltrichloroethane (DDT), dieldrin, Chem A, and PCBs in tissue; and impaired sediment due to chlordane, DDT, and PCBs (Toxics). The listed impairments are caused by the overloading of nutrients, such as nitrogen and phosphorus, resulting in excessive algal growth which leads to increased turbidity, decreased levels of oxygen, and odor problems. The Los Angeles Regional Water Quality Control Board (RWQCB) established TMDLs for Machado Lake for algae, ammonia and odors (Nutrients) on May 1, 2008, and for Pesticides and PCBs (Toxics) on September 2, 2010. In addition, on June 7, 2007, the RWQCB adopted an amendment to the Water Quality Control Plan for the Los Angeles Region (Basin Plan) incorporating a TMDL for Trash in Machado Lake (March 6, 2008 was the effective date of the Machado Lake Trash TMDL). The Machado Lake TMDL describes the watershed as: “Machado Lake is a receiving body of urban and storm water runoff from the storm drain system covering an approximately 20-square mile watershed. The Wilmington Drain collects runoff from the surrounding cities of Lomita, Torrance, Carson, and Los Angeles, and then discharges over 50 percent of the watershed into Machado Lake at the northeast corner. The rest of the waters enter the lake through other storm drains including the Project No. 77 channel, the Harbor City Relief Drain located at the west end of the lake, the City of Los Angeles drains for runoff from streets, and the Harbor Park Municipal Golf Course. The Wilmington Drain Project 77 and the Harbor City Relief Drain collect storm water from the communities of Harbor City, Lomita, Carson, Torrance, and Wilmington, and from the Walteria Lake drainage area. In addition, two project 643 outlets discharge to the wetlands area. During the dry season, Machado Lake is replenished via a City of Los Angeles Department of Water And Power potable water pipeline and dry weather runoff.” The City of Redondo Beach is situated in the western portion of the Machado Lake subwatershed and makes up 0.018% (approximately 0.94 acres) of the total watershed area. This has been reduced from previously reported percentages based on a staff field visit the week of January 4, 2016 during a heavy rain event when stormwater runoff from a small area was observed to drain to the Santa Monica Bay, not Machado Lake, as previously assumed. The City of Redondo Beach has no direct discharges into Machado Lake and has 0 (zero) point source area miles, which results in a calculated waste load allocation of zero for the City’s drainage area. The City’s contributory drainage area consists of no catch basins or storm drains.
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Two corrected watershed maps identifying the drainage area are attached as Appendices C and D in this EWMP. The drainage from the City’s area to Machado Lake has been determined to be “de minimus” and poses an insignificant threat to Machado Lake water quality and pollutant loading. The City of Redondo Beach will manage and included this described area as part of the City’s Santa Monica Bay Beaches Bacteria (SMBBB) TMDL and overall MS4 NPDES program, including the implementation of all minimum control measures and oversight. The City of Redondo Beach sent a letter to the State Water Resources Control Board dated October 31, 2007 (Appendix E) requesting to be exempted from the Machado Lake Trash TMDL and sent another letter to the RWQCB on December 18, 2008 (Appendix F) requesting the City be removed as a responsible agency under the Machado Lake TMDL requirements. The Watershed agencies agreed to this; therefore, they did not included the City of Redondo Beach in the Machado Lake Trash TMDL Monitoring and Reporting Plan. Based on these items, the City of Redondo Beach has requested to be deemed “in-compliance” with their Machado Lake Watershed drainage area and be removed from the Machado Lake Watershed Implementation Plan for the following reasons:
• The City of Redondo Beach’s drainage area is only 0.018% (approximately 0.94 acres) of the total Machado Lake Watershed area. This area has been determined to be “de minimus” and post an insignificant threat to Machado Lake Watershed water quality and pollutant loading. The portion of the City’s contributory drainage area consists of no catch basins or storm drains.
• The City of Redondo Beach proposes that it would be more reasonable for the City to focus its resources to implement the SMBBB TMDL and other relevant TMDLs. The majority of the City land area discharges into the Santa Monica Bay, which would make it more feasible and effective to use resources on projects and programs that will have the most impact on water quality improvements. The insignificant area draining into Machado Lake would be subject to the same control measures of the implementation plan developed for the SMBBB TMDL and all other MS4 NPDES measures. As a result, this area would benefit from the appropriate BMPs designed for the entire City. 1.3 EWMP DEVELOPMENT PROCESS Section VI.C.1.f.v of the Permit requires a stakeholder process for collaboration on EWMP development. The development process must:
• Provide appropriate opportunity for stakeholder input;
• Include participation in the Permit-wide Technical Advisory Committee (TAC); and
• Incorporate applicable State agency input on priority setting and other key implementation issues. The Beach Cities WMG has conducted public outreach to engage the public, LARWQCB staff, and other interested parties to support EWMP development. Input has been incorporated as appropriate. These efforts are described in more detail below.
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Public Workshops. Public workshops were held on May 21, 2014 at the Joslyn Center in Manhattan Beach and on May 27, 2015 at the Redondo Beach Public Library. An informational presentation was provided followed by a question and answer period to encourage stakeholder input. Concerns were noted and considered during EWMP development by the Beach Cities WMG.
Technical Advisory Committee (TAC). The Beach Cities WMG has, and will continue to, actively participate in the Los Angeles region TAC and applicable subcommittees throughout the EWMP process.
LARWQCB Presentations. The Beach Cities WMG presented the proposed RAA approach to LARWQCB staff on April 9 and June 6, 2014. LARWQCB staff provided feedback during these meetings and in general they were supportive of the proposed approach. One additional meeting was held on July 31, 2014 to discuss Torrance-specific matters. The EWMP also addressed other State agency priorities, including the following:
California Water Action Plan (2014). The California Water Action Plan proposes several statewide actions that are well aligned with the expected benefits of the proposed projects in this EWMP, including:
• Expand Water Storage Capacity and Improve Groundwater Management (infiltration BMPs): This action aims to address the need to expand the state’s storage capacity, whether in surface or groundwater to provide widespread public and environmental benefits. The California Water Action Plan states that “state agencies will work with tribes and federal, regional and local agencies on other actions related to promoting groundwater recharge and increasing storage, including improving interagency coordination, aligning land use planning with groundwater recharge...” The regional and distributed BMP projects proposed in the Beach Cities EWMP may contribute to groundwater recharge and expanding storage capacity throughout the Beach Cities WMG.
• Increase Operational and Regulatory Efficiency: Monitoring data collected under the CIMP to measure progress toward achieving RWLs and WQBELs and to determine if modifications to the Beach Cities EWMP are necessary may provide the benefit of increased operational and regulatory efficiency. Improving data availability may also improve coordination of operations of all major water supply, flood control, hatchery facilities, and habitat restoration projects.
2014 Greater Los Angeles County Integrated Regional Water Management Plan (GLAC
IRWM Plan). The goal of the GLACR IRWM Plan is to achieve sustainable management of water resources in the Greater Los Angeles County. The plan lists several regional objectives to achieve this goal. The Beach Cities EWMP contributes to some of the objectives outlined in the plan, including the following:
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• Water Quality: This objective aims to comply with water quality regulations by improving the quality of urban runoff, stormwater, and wastewater. The Beach Cities EWMP contributes to this objective by proposing new distributed and regional stormwater capture opportunities in areas prioritized by statewide and regional regulations and water quality conditions.
• Open Space and Recreation: This objective aims to protect, restore, and enhance natural process and habitats. Several of the regional EWMP projects (i.e. Park #3 BMP and the Powerline Easement in Analysis Region SMB-6-01) provide opportunity for expanded habitat and increased green space.
STORMS Storm Water Strategy (California Water Boards, 2015). The Storm Water Strategy assists in achieving the actions identified in the California Water Action Plan, including the aforementioned action of expanding water storage capacity and improving groundwater management. The Storm Water Strategy supports efforts to improve interagency coordination and identify needs for groundwater recharge opportunity. The Storm Water Strategy also lists six overarching objectives. The Beach Cities EWMP contributes to some of these objectives, including the following:
• Increase Stakeholder Collaboration on a Watershed Scale: the Beach Cities WMG agreed to collaborate on the development of this EWMP for the Santa Monica Bay and Dominguez Channel Watershed areas within their jurisdictions to facilitate effective, watershed-specific Permit implementation strategies in accordance with Permit Part VI.C.
• Establish Financially Sustainable Storm Water Programs: This EWMP provides an overview of potentially available funding sources for programs proposed in the EWMP. The funding sources identified for consideration are grants, interagency partnerships, bonds, State Revolving Funds, local funding opportunities, and public private partnerships.
• Increase Source Control and Pollution Prevention: This EWMP identifies the cumulative benefits from non-modeled programmatic source control BMPs that target the pollutants addressed in this EWMP.
Final Storm Water Resource Plan Guidelines (Guidelines) (December 2015). The Guidelines establish guidance for public agencies to develop Storm Water Resource Plans (Plans) consistent with Water Code sections 10561 through 10565. The Water Code states that a Plan is required as a condition to receive funding for stormwater and dry weather runoff capture projects from any bond approved by voters after January 2014, which also applies to Proposition 1 funding. The Guidelines provide guidance such as clarification on the applicability of the Guidelines, appropriate geographic scale of watersheds for stormwater resource planning, guidance on agencies and organizations to be consulted during Plan development, methods for identifying and prioritizing stormwater and runoff capture projects, project scheduling and implementation strategies, and so forth.
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A Self-Certified Checklist provided in the Guidelines includes a complete list of the elements of a Stormwater Resource Plan that are considered mandatory per the California Water Code. Fulfilling the mandatory requirements would make the Beach Cities WMG eligible for Proposition 1 Stormwater Grant funding which would be applied toward the proposed Beach Cities EWMP projects. The mandatory required elements highlighted in the Checklist and Self-Certification are either entirely fulfilled by the Beach Cities EWMP (including appended documents) or will be fulfilled on a project-specific basis. For example, maximizing flood control will be part of detailed design at the project level. 1.4 REPORT ORGANIZATION This Beach Cities EWMP addresses the required EWMP elements from Section VI.C. of the Permit for both the SMB and Dominguez Channel Watersheds. Because the SMB and Dominguez Channel Watersheds have their own unique water quality conditions, their technical evaluations were performed independently and are documented in separate sections in this EWMP. This includes the water quality prioritization, RAA, and BMP identification. Section 2 summarizes the technical aspects of the EWMP for Santa Monica Bay watershed while Section 3 covers the same technical elements for Dominguez Channel Watershed. Section 4 presents individual EMWP implementation schedules for both watersheds. In Section 5, the adaptive management process proposed by the Beach Cities WMG is described, and in Section 6, the cost opinions associated with EWMP implementation are summarized. Section 7 describes potential funding sources and financial strategies. Sections 8 and 9 include the legal authority and references, respectively. 1.5 TERMS OF REFERENCE This work was conducted by Geosyntec Consultants for the Beach Cities WMG with the purpose of developing a comprehensive control plan to facilitate Permit compliance and achievement of water quality standards and serves as the deliverable for Task 4.5 of the Beach Cities WMP contract. This work was managed by Ken Susilo, P.E., D.WRE., CPSWQ, with support from Megan Otto, P.E., Chris Wessel, P.E., Stacy Luell, P.E, Stacey Schal, Curtis Fang, and Scott Mansell, Ph.D. Peer review was provided by Megan Otto, P.E., Chris Wessel, P.E., and Lucas Nguyen. Senior review was provided by Brandon Steets, P.E. and Ken Susilo, P.E., in accordance with Geosyntec's quality assurance policies.
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2 SANTA MONICA B AY WATERSHED 2.1 BACKGROUND
2.1.1 GEOGRAPHICAL CONTEXT The western portion of the Beach Cities EWMP Area consists of approximately 7,840 acres of land that drains to SMB. This accounts for 52% of the total Beach Cities WMG area, and includes portions of the cities of Manhattan Beach, Redondo Beach, and Torrance, and the entirety of the City of Hermosa Beach (Figure 2-1). This portion of the study area is hereinafter referred to as the SMB Watershed. The majority of the SMB Watershed consists of residential land uses (Figure 2-2). The 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 2-1 provides a breakdown of the Beach Cities EWMP Area by agency and watershed. This section of the EWMP focuses on the SMB Watershed only.
Table 2-1. Beach Cities WMG EWMP 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%)
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Figure 2-1. Beach Cities WMG MS4 Infrastructure within the Santa Monica Bay Watershed
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Figure 2-2. Beach Cities WMG Land Uses within the Santa Monica Bay Watershed
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2.2 IDENTIFICATION OF WATER QUALITY PRIORITIES As part of the EWMP, the Permit requires the Beach Cities WMG to identify water quality priorities within their WMA. To accomplish this per Permit Section VI.C.5.a, the Beach Cities WMG conducted the following for the Santa Monica Bay 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 water body-pollutant combinations (WBPCs); and 3. Assess sources for high priority water body. A summary of results is provided below.
2.2.1 WATER QUALITY CHARACTERIZATION
Beneficial Uses The Basin Plan (LARWQCB, 1995, updated 2011) identifies receiving waters within the Los Angeles region and sets regulatory objectives for these receiving waters. Within the SMB Watershed, identified receiving water bodies include SMB itself as well as coastal beaches within the Beach Cities WMG Area. Regulations set forth in the California Ocean Plan (SWRCB, 2012) are therefore also applicable to the SMB Watershed. Both the Basin Plan and Ocean Plan regulate 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 include:
• Municipal and Domestic Supply (MUN): Uses of water for community, military, or individual water supply systems including, but not limited to, drinking water supply.
• Industrial Service Supply (IND): Uses of water for industrial activities that do not depend primarily on water quality including, but not limited to, mining, cooling water supply, hydraulic conveyance, gravel washing, fire protection, or oil well re-pressurization.
• Navigation (NAV): Uses of water for shipping, travel, or other transportation by private, military, or commercial vessels.
• Water Contact Recreation (REC-1): Uses of water for recreational activities involving body contact with water, where ingestion of water is reasonably possible. These include, but are not limited to, swimming, wading, water-skiing, skin and scuba diving, surfing, what water activities, fishing, or use of natural hot springs.
• Non-Contact Water Recreation (REC-2): Uses of water for recreational activities involving proximity to water, but not normally involving body contact with water, where ingestion of water is reasonably possible. These uses include, but are not limited to, picnicking, sunbathing, hiking, beachcombing, camping, boating, tide pool and marine life study, hunting, sightseeing, or aesthetic enjoyment in conjunction with the above activities.
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• High Flow Suspension (HFS): Applies to water contact recreational activities associated with the swimmable goal regulated under the REC-1 use, non-contact water recreation involving incidental water contact regulated under the REC-2 use, and the associated bacteriological objectives set to protect those activities.
• Commercial and Sport Fishing (COMM): Uses of water for commercial or recreational collection of fish, shellfish, or other organisms including, but not limited to, uses involving organisms intended for human consumption or bait purposes.
• Warm Freshwater Habitat (WARM): Uses of water that support warm water ecosystems including, but not limited to, preservation or enhancement of aquatic habitats, vegetation, fish, or wildlife, including invertebrates.
• Marine Habitat (MAR): Uses of water that support marine ecosystems including, but not limited to, preservation or enhancement of marine habitats, vegetation such as kelp, fish, shellfish, or wildlife (e.g., marine mammals, shorebirds).
• Wildlife Habitat (WILD): Uses of water that support terrestrial ecosystems including, but not limited to, preservation and enhancement of terrestrial habitats, vegetation, wildlife (e.g., mammals, birds, reptiles, amphibians, invertebrates), or wildlife water and food sources.
• Rare, Threatened, or Endangered Species (RARE): Uses of water that support habitats necessary, at least in part, for the survival and successful maintenance of plant or animal species established under state or federal law as rare, threatened, or endangered.
• Migration of Aquatic Organisms (MIGR): Uses of water that support habitats necessary for migration, acclimatization between fresh and salt water, or other temporary activities by aquatic organisms, such as anadromous fish.
• Spawning, Reproduction, and/or Early Development (SPWN): Uses of water that support high quality aquatic habitats suitable for reproduction and early development of fish.
• Shellfish Harvesting (SHELL): Uses of water that support habitats suitable for the collection of filter-feeding shellfish (e.g., clams, oysters, and mussels) for human consumption, commercial, or sports purposes.
• Wetland Habitat (WET): Uses of water that support wetland ecosystems, including, but not limited to, preservation or enhancement of wetland habitats, vegetation, fish, shellfish, or wildlife, and other unique wetland functions which enhance water quality, such as providing flood and erosion control, stream bank stabilization, and filtration and purification of naturally occurring contaminants. According to the Ocean Plan (SWRCB, 2012), “The beneficial uses of the ocean waters of the State that shall be protected include industrial water supply (IND); water contact recreation (REC-1) and non-contact recreation (REC-2), including aesthetic enjoyment; navigation (NAV); commercial and sport fishing (COMM); mariculture; preservation and enhancement of designated Areas of Special Biological Significance (ASBS); rare and endangered species (RARE); marine habitat (MAR); fish migration (MIGR); fish spawning (SPWN) and shellfish* harvesting (SHELL).” Additional beneficial uses are defined as follows:
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• Mariculture: The culture of plants and animals in marine waters independent of any pollution source.
• ASBS: Those areas designated by the State Water Board as ocean areas requiring protection of species or biological communities to the extent that maintenance of natural water quality is assured. ASBS are also referred to as State Water Quality Protection Areas – Areas of Special Biological Significance (SWQPA-ASBS).
Table 2-2 summarizes the existing beneficial uses for the Santa Monica Bay water bodies in the Beach Cities WMG Area, as designated in the Basin Plan.
Table 2-2. Beach Cities EWMP Area - Santa Monica Bay Watershed Water Bodies and
Beneficial Uses
Water Body MUN IND NAV REC1 REC2 HFS COMM WARM MAR WILD RARE MIGR SPWN SHELL WET2 Santa Monica Bay Nearshore + Offshore1 E E E E E E E E E E E Manhattan Beach E E E E E E P E Hermosa Beach E E E E E E E3 E King Harbor E E E E E E E E Redondo Beach E E E E E E E E E E3 E Torrance Beach E E E E E E E E3 E E = Existing beneficial use 1 The Preservation of Biological Habitats (BIOL) beneficial use is not included since no Areas of Special Biological Significance are present within the Beach Cities WMG Area. 2 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. 3 Most frequently used grunion spawning beaches. Other beaches may be used as well.
SMB Watershed Data Analysis An evaluation of existing water quality conditions, including characterization of stormwater discharges from the MS4 as well as receiving water quality 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. To evaluate water-quality conditions within the SMB Watershed, a review of previous studies was conducted to characterize receiving water bodies within the Beach Cities WMG Area. Monitoring data analyzed were limited to bacteria data collected as part of the SMB Beaches Bacteria TMDL CSMP and limited PCB and DDT data collected as part of the 2008 Bight Regional Monitoring Program. A summary of this analysis is provided below. Additional details can be found in the Beach Cities EWMP Work Plan.
2.2.2 WATER BODY-POLLUTANT CLASSIFICATION Receiving waters for stormwater runoff from the Santa Monica Bay Watershed portion of the Beach Cities EWMP Area were screened for water quality priorities by reviewing TMDLs, the State’s
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303(d) list, and additional 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. No 303(d) listings exist beyond the TMDL WBPCs, and no other recent monitoring data are available beyond the SMBBB TMDL Coordinated Shoreline Monitoring Plan (CSMP) data; therefore, no Category 2 or 3 WBPCs have been identified for the Beach Cities portion of SMB at this time.
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:
• SMB beaches for bacteria (wet and dry weather): These are considered Category 1 due to the SMBBB TMDL.
• SMB offshore/nearshore for dichloro-diphenyl-trichloroethanes (DDTs) and polychlorinated biphenyls (PCBs)7: These are considered Category 1 due to the USEPA TMDL for DDT and PCBs for SMB Offshore/Nearshore. However, the TMDL relies on a limited dataset to establish stormwater load allocations, relying on a single study (Curren et al., 2011) from a single creek (Ballona Creek, which is outside the Beach Cities watershed area) to establish MS4 WLAs throughout the entire SMB Watershed. It does not present sufficient data to assign MS4 contributions to the DDT and PCB concentrations observed in SMB; therefore, standard RAA modeling for these pollutants cannot reasonably be conducted at this time. Despite the lack of data for RAA modeling purposes, the load-based WQBELs for DDT and PCBs established by the TMDL were set to be the existing stormwater loads (i.e., based on data used in the TMDL, no MS4 load reduction is expected to be required to achieve TMDL compliance)8. Therefore, it is assumed that no reductions in DDT and PCB loading from the Beach Cities WMG MS4s are required to meet the TMDL and reasonable assurance of compliance is assumed to be demonstrated without modeling. Monitoring of these pollutants will occur under the Beach Cities CIMP. 7 SMB Offshore/Nearshore is 303(d)-listed for fish consumption advisory due to DDT and PCBs. Therefore, the fish consumption advisory will be assumed to be addressed by the DDT and PCB categorization. SMB Offshore/Nearshore is also 303(d) listed for toxicity. USEPA's data evaluation showed only 3 out of 116 samples exhibited toxicity (USEPA, 2012). USEPA made a finding in the TMDL that, following the California listing policy, Santa Monica Bay is meeting the toxicity objective and there is sufficient evidence to de-list sediment toxicity. EPA therefore concluded in the TMDL that there is no significant toxicity in Santa Monica Bay and recommended that Santa Monica Bay not be identified as impaired by toxicity in the California's next 303(d) list.
8 The TMDL states, “Because existing stormwater loads from the watersheds are lower than the calculated total allowable loads to achieve sediment targets, the waste load allocations for stormwater in this TMDL are based on existing load estimates of 28 g/yr for DDT and 145 g/yr for PCBs.” These WLAs are further divided among Los Angeles County MS4, CalTrans, the Construction General Permit, and the Industrial General Permit. The assigned WLAs for the entire LA County MS4 within the Santa Monica Bay Watershed is 27.08 g/yr for DDT and 140.25 g/yr for PCBs, which are equivalent to the TMDL-estimated existing MS4 stormwater loads.
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• SMB offshore/nearshore for debris: This is considered Category 1 due to the TMDL for Debris for SMB Offshore/Nearshore. Section VI.E.5.b(i) of the Permit states, “Pursuant to California Water Code section 13360(a), Permittees may comply with the trash [debris] effluent limitations using any lawful means. Such compliance options are broadly classified as full capture, partial capture, institutional controls, or minimum frequency of assessment and collection… and any combination of these may be employed to achieve compliance.” While trash was not modeled as part of the RAA, the RAA qualitatively described how the Beach Cities WMG Agencies will comply with the SMB Debris TMDL WQBELs by stating the following: “Compliance with the Debris TMDL will be met through a phased retrofit of all catch basins throughout the SMB EWMP area to meet each interim compliance deadline (20% load reduction per year between 2016 and 2019) as well as the final compliance deadline (100% load reduction) in 2020. Consistent with the Trash Monitoring and Reporting Plans (TMRP) from each of the Beach Cities agencies (Beach Cities WMP, 2014), “vertical insert[s] with 5-mm openings and flow activated opening screen covers are the best suited for implementation within the City to achieve compliance with Trash TMDLs.” To date, data for trash discharges from the MS4 are unavailable for the SMB Watershed. The SMB Debris TMDL can be satisfied through the submittal of the TMRP and the Plastic Pellet Monitoring and Reporting Program (PMRP) or via the CIMP. Trash Monitoring and Reporting Plans (TMRPs) were submitted to the Regional Board by each Beach Cities WMG Agency before the TMDL-specified deadline of September 20, 2012. Additionally, each Beach Cities WMG Agency submitted a request to the Regional Board by September 20, 2013 to be exempt from the TMDL requirement to conduct monitoring for plastic pellets based on absence of industrial activities related to the manufacturing, handling, or transportation of plastic pellets within their jurisdictions in the SMB watershed. A review letter on the draft CIMP, dated May 22, 2015, approved the TMRP and PMRP exemption requests from the City of Hermosa Beach, the PMRP exemption request from the City of Torrance, the PMRP exemption request from the City of Manhattan Beach, and the three year extension of the final TMRP compliance date for the City of Manhattan Beach (LARWQCB, 2015). The Board approved the TMRP for the City of Redondo Beach on May 22, 2015. The City of Redondo Beach request for exemption from the PMRP was approved by the Board on November 12, 2015 [LARWQCB, 2015c]. Monitoring for trash in the City of Redondo Beach, City of Manhattan Beach, City of Hermosa Beach, and City of Torrance will begin in the SMB Watershed in accordance with each Agency’s respective TMRP. Exemption of the Beach City WMG Agencies from the PMRP means that monitoring for plastic pellets within the SMB Watershed will not be conducted by the Beach Cities. “Highest Priority” WBPCs have been assigned based strictly on the Permit definition. Not all of these pollutants (e.g., DDT and PCBs) have been definitively linked to MS4 sources. As a result, this categorization and prioritization will be reevaluated based on results from the future water quality monitoring efforts conducted under the Coordinated Integrated Monitoring Program (CIMP).
Category 2 – High Priority WBPCs under Category 2 (high priority) are defined in the Permit as, “Pollutants for which data indicate water quality impairment in the receiving water according to the State’s Water Quality
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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.” There are no Category 2 WBPCs in the SMB Watershed portion of the Beach Cities EWMP area.
Category 3 – Medium Priority WBPCs under Category 3 (medium priority) are defined in the Permit as, ”Pollutants for which there are insufficient data to indicate water quality impairment in the receiving water according to the State’s Listing Policy, but which exceed applicable RWLs contained in this Order and for which MS4 discharges may be causing or contributing to the exceedance.” There are no Category 3 WBPCs in the SMB Watershed portion of the Beach Cities EWMP area. 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 and the EWMP will be updated.
Figure 2-3 provides a brief conceptual overview of the process used to identify and categorize the WBPCs within the Beach Cities EWMP Area.
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Figure 2-3. Process for Categorizing Water Body-Pollutant Combinations
Table 2-3 presents the prioritized WBPCs within the SMB Watershed portion of the Beach Cities EWMP Area. WBPCs categorized below are subject to change based on future data collected as part of the CIMP or other monitoring program. Grouped RWLs for the SMB Beaches Bacteria TMDL are also expressed in the Permit in terms of allowable exceedance days (AEDs), which vary by season and by Coordinated Shoreline Monitoring Plan (CSMP) monitoring station. These AEDs, as revised per the Reconsideration of the SMB Beaches Bacteria TMDL (LARWQCB, 2012b), are summarized in Table 2-4. The final grouped RWLs are effective for dry weather and will be effective July 15, 2021 for wet weather. The CSMP monitoring stations are shown in Figure 2-5.
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Table 2-3. Water Body-Pollutant Combination Prioritization and Pollutant Interim and Final Compliance Targets for Santa
Monica Bay Watershed Portion of the Beach Cities EWMP Area
Category Water
Body Pollutant Reason for Categorization WQBEL/RWL/
Objective Basis
Interim WQBEL/
RWL
Final WQBEL/
RWL/Objective
1: Highest Priority
Santa Monica Bay Beaches
Dry Weather Bacteria SMB Beaches Dry Weather Bacteria TMDL Daily and Weekly Sampling Schedule N/A Summer-Dry Single Sample Allowable Exceedance Days (AED)1 met Winter-Dry period Single Sample AED1 met Wet Weather Bacteria SMB Beaches Wet Weather Bacteria TMDL Daily and Weekly Sampling Schedule/
50% cumulative percentage reduction from total required exceedance day reduction2
Single Sample and Geometric Mean AED1 and GM target met
Santa Monica Bay
Trash/ Debris SMB Debris TMDL Annual monitoring Incremental reduction from baseline waste load allocation3 (6815.6 gals/year)
100% reduction from baseline waste load allocation3 (6815.6 gals/year) DDTs SMB PCBs and DDT TMDL 3-Year Average N/A 27.08 g/year4 PCBs SMB PCBs and DDT TMDL 3-Year Average N/A 140.25 g/year4 2: High Priority N/A None No other 303(d) listings exist for the Beach Cities portion of SMB
3: Medium Priority N/A None Outfall and receiving water monitoring data are not available for the Beach Cities portion of SMB
1Per the Basin Plan Objective REC1 Water Bodies Limit for Bacteria. Please refer to Table 2-4 for allowable exceedance day limits of each subwatershed. 2 Total required exceedance day reduction is defined as the difference between existing exceedance day and the allowable exceedance day for each subwatershed 3 Baseline WLA is the sum of baseline WLA from Manhattan Beach, Redondo Beach and Hermosa Beach 4This limit is applicable to all of Santa Monica Bay.
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Table 2-4. Bacteria RLWs for Beach Cities WMG Shoreline Monitoring Stations
Station Station Name
Summer Dry Weather
(Apr 1 – Oct 31)
Winter Dry Weather
(Nov 1 – Mar 31)a
Wet Weather
(Year-Round)
Daily
Sampleb
Weekly
Sample
Daily
Sampleb
Weekly
Sample
Daily
Sampleb
Weekly
Sample SMB 5-01c Manhattan State Beach at 40th St (El Porto Beach) 0 0 1 1 4 1 SMB 5-02 Terminus of 28th Street Drain in Manhattan Beach 0 0 9 2 17 3 SMB 5-03 Manhattan Beach Pier 0 0 3 1 6 1 SMB 5-04c Near 26th Street on Hermosa Beach 0 0 3 1 12 2 SMB 5-05c Hermosa Beach Pier 0 0 2 1 8 2 SMB 6-01 Herondo Storm Drain 0 0 9 2 17 3 SMB 6-02c Redondo Municipal Pier – 100 Yards South 0 0 3 1 14 2 SMB 6-03 4’x4’ Outlet at Projection of Sapphire Street 0 0 5 1 17 3 SMB 6-04c 120’ North of Topaz groin 0 0 9 2 17 3 SMB 6-05 Storm Drain at Projection of Avenue I 0 0 4 1 11 2 SMB 6-06c Malaga Cove, Palos Verdes Estates 0 0 1 1 3 1 a The number of allowable exceedance days established in the revised TMDL have increased from the values outlined in the original TMDL. b SMB 5-02 and SMB 6-01 are the only monitoring sites that have been sampled daily (5 days/week), although SMB 6-01 switched to weekly sampling in 2013. All other monitoring sites were sampled weekly (on average). c SMB 5-01, 5-04, 5-05, 6-02, 6-04, and 6-06 are all open beach monitoring locations which are not associated with major storm drain outfalls.
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Sections VI.C.2 and VI.C.3 of the Permit describes how compliance with RWLs/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).
• 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 Category 1 WBPCs, adherence to all implementation actions and compliance dates identified in the approved EWMP will constitute compliance with applicable TMDL-based interim water quality based effluent limits and interim receiving water limits. 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.
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2.2.3 SOURCE ASSESSMENT The following data sources were reviewed as part of the source assessment for the WBPCs listed previously:
• Findings from the Permittees’ Illicit Connections and Illicit Discharge Elimination Programs (IC/ID);
• 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
• Any other pertinent data, information, or studies related to pollutant sources and conditions that contribute to the highest water quality priorities. The following source assessment is broken down by pollutants applicable to the SMB Watershed.
Indicator Bacteria The SMBBB TMDLs for dry and wet weather were the first bacteria TMDLs adopted by the LARWQCB. The SMBBB TMDLs were recently opened for reconsideration, although the source assessment was not part of this update. As a result, the general findings from the original source assessment remain unchanged. These findings are summarized in the 2012 Basin Plan Amendment for the reopened SMBBB TMDL (Attachment A to Resolution No. R12-007): “With the exception of isolated sewage spills, dry weather urban runoff and stormwater runoff conveyed by storm drains and creeks is the primary source of elevated bacterial indicator densities to SMB beaches. Limited natural runoff and groundwater may also potentially contribute to elevated bacterial indicator densities during winter dry weather” (LARWQCB, 2012b). The SMBBB TMDL source assessment (LARWQCB, 2002) maintained that dry weather urban runoff and stormwater runoff were the primary sources of elevated bacteria concentrations at SMB beaches at the time of the TMDL. Although definitive information regarding the specific sources of bacteria within the watershed was not presented, speculation provided in the dry weather staff report provided some insight into possible sources at the time: “Urban runoff from the storm drain system may have elevated levels of bacterial indicators due to sanitary sewer leaks and spills, illicit connections of sanitary lines to the storm drain system, runoff from homeless encampments, illegal discharges from recreational vehicle holding tanks, and malfunctioning septic tanks among other things. Swimmers can also be a direct source of bacteria to recreational waters. The bacteria indicators used to assess water quality are not specific to human sewage; therefore, fecal matter from animals and birds can also be a source
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of elevated levels of bacteria, and vegetation and food waste can be a source of elevated levels of total coliform bacteria, specifically” (LARWQCB, 2002). Information on non-MS4 sources of surf zone bacteria along specific SMB beaches was provided by the City of Malibu in its comment letter on the SMBBB TMDL reconsideration, based on a comprehensive review of local and Southern California source identification studies (City of Malibu, 2012): “A number of recent Santa Monica Bay studies have further identified and confirmed natural (non-anthropogenic) sources of fecal indicator bacteria including plants, algae, decaying organic matter, beach wrack and bird feces – implicating these as potentially significant contributors to exceedances (Imamura et al 2011, Izbicki 2012b). Beach sands, sediments and beach wrack have been shown to be capable of serving as reservoirs of bacteria, possibly by providing shelter from UV inactivation and predation by allowing for regrowth (Imamura et al 2011, Izbicki et al 2012b, Lee et al 2006, Ferguson et al 2005, Grant et al 2001, Griffith 2012, Litton et al 2010, Phillips et al 2011, Jiang et al 2004, Sabino et al 2011, and Weston Solutions 2010). In fact, enterococci include non-fecal or “natural” strains that live and grow in water, soil, plants and insects (Griffith, 2012). Thus, elevated levels of enterococci in water could be related to input from natural sources. The phenomenon of regrowth of bacteria from either anthropogenic or natural sources has been suggested by several studies as a possible source of beach bacteria exceedances (Griffith 2012, Litton et al 2010, Weston Solutions 2010, Izbicki
et al 2012b, Weisberg et al 2009).” In 2009, a dry weather bacterial source identification study was undertaken at the Redondo Beach Pier (Los Angeles County Sanitation District [LACSD], 2009). This study implemented a multi-tiered toolbox approach to investigate sources of dry weather fecal indicator bacteria (FIB) exceedances near Redondo Beach Pier (CSMP monitoring location SMB 6-02).). Utilizing microbial source tracking, the sampling focused on the shoreline near the pier, a storm drain under the pier, and ponded water near the storm drain. Investigators found a lack of human fecal markers within the surf zone: “Lack of detectable human viruses and the de minimus quantities detection of human-associated Bacteroidales in the ocean water strongly implied that a human source was not present. Other sources of FIB may include bacterial persistence in the sand and sea wrack, as well as endogenous sea life and birds. Tide, wave action, wind, and other natural fluctuations may be affecting FIB levels at the shoreline monitoring locations next to the pier.” However, the study also indicated that, “…the storm drain under the pier and the pond that forms at the storm drain outlet are probably impacted by human fecal pollution but are not contributing to microbial contamination of the ocean water during the dry season. This conclusion is most strongly supported by the differences between the FIB concentrations and Bacteroidales populations at the shoreline sites compared to the pond and storm drain samples, particularly with respect to human-associated Bacteroidales.”
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Another dry weather MS4 microbial source tracking study was conducted in 2010, focusing on two high priority analysis regions (SMB-5-02 and 6-01) within the Beach Cities EWMP Area (Geosyntec Consultants, 2010). Although both of these shoreline monitoring locations are served by low flow diversions, the purpose of the study was to investigate FIB sources to inform identification of new source control measures. Observational results indicated that non-human sources include pet waste, irrigation runoff, and in-drain sources (i.e., re-growth, sediment, etc.). Similar to the Redondo Beach pier study, human Bacteroidales marker (HBM) was also identified in some MS4 dry weather samples, suggesting that human fecal sources may also be present. Although specific sources of human waste were not definitively identified in the study, “sources were surmised to include direct contamination (i.e., illicit connections, RV discharges, homeless deposits), and indirect contamination (i.e., sewer exfiltration).”9 To address the identification of dry weather bacteria sources within or to the MS4s, the Beach Cities WMG agencies have implemented measures to divert dry weather flows from all storm drains discharging at point zero shoreline monitoring locations. A total of seven low flow diversions are operational within the Beach Cities EWMP area. No wet weather bacteria source identification studies have been conducted in the Beach Cities EWMP area to date. Wet weather bacteria sources are believed to be derived from the entire watershed, and potentially include a mixture of human sources, non-human anthropogenic sources (e.g., pet waste), and non-anthropogenic sources (e.g., birds and other urban wildlife, storm drain biofilms/regrowth, beach sands and wrack). A wet weather stormwater monitoring study by the Southern California Coastal Water Research Project (SCCWRP) investigated bacteria concentrations in stormwater runoff from various land uses in the Los Angeles region (Stein et al, 2007). Results showed that wet weather runoff event mean concentrations (EMCs) for fecal coliform bacteria were highest for agricultural land uses, followed by commercial and educational, single family residential, multi-family residential, open space, industrial, and transportation. In this study, results showed that bacteria concentrations in stormwater are highly variable, with concentrations often varying by one to two orders of magnitude during a single storm, and by up to five orders of magnitude on seasonal and inter-annual scales. Additional local monitoring data will be needed to quantify the contribution of MS4 discharges – particularly relative to the many other identified sources that have been documented along SMB beaches – to the elevated bacteria concentrations measured at Beach Cities WMG compliance monitoring locations during dry and wet weather. 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 waste load allocations (WLAs) through a future reopener10. And the combination of MS4 outfall monitoring (through the 9 The LACSD and Geosyntec microbial source tracking studies predate the 2013 California Source Identification Pilot Project, which identifies and recommends new, more definitive microbial source tracking markers for multiple source types, including human waste. Therefore new analytical methods may need to be applied to these previously studied areas to verify or update prior findings. 10 For example, if human fecal sources are found to be undetected in MS4 discharges to SMB beaches using a rigorous sampling design, the latest analytical markers, and a credible laboratory, then TMDL revisions may be proposed.
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CIMP) and source identification (through special studies) could support future BMP planning and EWMP updates.
DDT and PCBs As stated previously, limited data are available characterizing DDT and PCBs within Santa Monica Bay, particularly since direct discharges of these pollutants from publically owned treatment works (POTWs) have ceased. The largest concentration of DDT and PCBs within SMB is contained within the Palos Verdes shelf, which is being addressed by the USEPA as a Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) site. Loadings from the shelf to the bay are large and have been well characterized (USEPA, 2012). With respect to stormwater, the TMDL does not specifically characterize MS4 loadings, though it does recognize that “DDT and PCBs are no longer detected in routine stormwater sampling from Ballona Creek or Malibu Creek.” However, the TMDL also states that current detection limits used to analyze DDT and PCB concentrations are too high to appropriately assess the water quality. Despite a lack of supporting data, however, EPA assumed that stormwater inputs of DDT and PCBs come from urban areas (USEPA, 2012). No other data or source information are available at this time. Once three years of water quality data are collected under the CIMP and evaluated consistent with the recommendations by USEPA in the TMDL to utilize a three-year averaging period, then further source assessment will be considered and the categorization and prioritization of PCB and DDTs as MS4-related pollutants of concern will be reevaluated.
Trash Source information for trash within SMB is provided by the SMB Nearshore Debris TMDL. A detailed source breakdown is not provided, but other debris TMDLs attribute trash to general areas such as “litter from adjacent land areas, roadways, and direct dumping and deposition” (LARWQCB, 2008) while also attributing trash inputs to point sources such as storm drains. The plastic pellet portion of the SMB Debris TMDL is not applicable to the Beach Cities WMG, as the respective Agencies have applied and have gained approval to be exempt from this portion of the TMDL.
2.2.4 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 2-3). 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, as there are no Category 2 or 3 pollutants in the SMB Watershed within the Beach Cities WMG. WBPCs will be further prioritized based on the applicable compliance schedules, as discussed in Section 4.
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2.3 SELECTION OF APPROPRIATE BEST MANAGEMENT PRACTICES
2.3.1 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.
2.3.2 DEFINITION OF BEST MANAGEMENT PRACTICES The Permit defines BMPs as “practices or physical devices or systems designed to prevent or reduce pollutant loading from stormwater or non-stormwater discharges to receiving waters, or designed to reduce the volume of stormwater or non-stormwater discharged to the receiving water.” These BMPs may include: 1. Structural and/or non-structural BMPs and operation and maintenance procedures that are designed to achieve applicable WQBELs and/or RWLs; 2. Retrofitting areas of existing development known or suspected to contribute to the highest water quality priorities with regional or sub-regional BMPs; 3. Stream and/or habitat rehabilitation or restoration projects where stream and/or habitat rehabilitation or restoration are necessary for, or will contribute to demonstrable improvements in the physical, chemical, or biological receiving water conditions and restoration and/or protection of water quality standards in receiving waters. Structural BMPs involve the construction of a physical control measure to alter the hydrology or water quality of incoming stormwater or non-stormwater. There are two categories of structural BMPs, defined by the runoff area treated by the BMP: regional BMPs 11 and distributed BMPs. Regional BMPs are designed to treat runoff from a large drainage area expected to include multiple parcels and various land uses. These may include infiltration basins, treatment plants, and subsurface flow wetlands, among others. Distributed BMPs are designed to treat runoff from 11 The term “regional BMP” does not necessarily indicate that the project can capture and retain the 85th percentile storm, as described in the Permit. The term “regional EWMP project” is therefore used for those regional BMPs that are expected to be able to capture and retain the 85th percentile storm.
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smaller drainage areas and are normally installed to collect runoff close to the source from a limited number of parcels. Distributed BMPs typically include swales, bioretention facilities, biofiltration facilities, and cisterns, among others. Relevant regional and distributed structural BMPs are described below. Non-structural BMPs prevent or reduce the release of pollutants or transport of pollutants within the MS4 area but do not involve construction of physical facilities. Non-structural BMPs are often implemented as programs or strategies which seek to reduce runoff and/or pollution close to the source. Examples include but are not limited to: street sweeping, downspout disconnect programs, pet waste cleanup stations, irrigation ordinances, or illicit discharge elimination. Minimum control measures (MCMs) as set forth in the Permit are a subset of non-structural BMPs even though some MCMs include measures that require the implementation of structural BMPs by private parties.
2.3.3 INCORPORATED PROVISIONS Permit Section VI.C.5.b.iv sets forth the provisions regarding the types of BMPs that must be considered in development of the EWMP. These provisions are described in more detail below.
Minimum Control Measures The Beach Cities WMG has assessed the MCMs defined in the Permit to identify opportunities for focusing resources on the high priority issues in each watershed. The Permit requires the permittees to implement prescribed MCMs in each of six categories/programs: Public Information & Participation Program (PIPP), Industrial/Commercial Facilities, Planning & Land Development, Development Construction, Public Agency Activities, and Illicit Connection & Illicit Discharges Elimination. These measures include procedures such as outreach programs, inspections, and reporting requirements designed to reduce runoff-related pollution within each permittees’ MS4 area. MCMs in each of these categories are already being implemented by the Beach Cities WMG as prescribed under the previous MS4 Permit (Order 01-182), and in some cases MCM program enhancements have been implemented to address watershed priorities for TMDL implementation. Details on the selected MCMs, including proposed modifications to any programs, are provided in Section 2.6.2 (Santa Monica Bay Watershed) and Section 3.6.2 (Dominguez Channel Watershed).
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. As previously stated, the Beach Cities WMG agencies currently operate seven low flow diversions along the Santa Monica Bay to eliminate non-stormwater discharges. 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).
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The watershed control measures proposed for 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 Santa Monica Bay watershed:
• December 28, 2016—Source investigation will be completed on 50% of the major outfalls with significant non-stormwater discharges in the Beach Cities EWMP Area (including outfall SMB-O-7).
• March 28, 2017— Outfall monitoring will be initiated as required for the investigated outfalls, based on results of source investigation in accordance with Section 5.6 of the Beach Cities CIMP, to determine compliance with applicable non-stormwater WQBELs derived from TMDL WLAs.
• June 26, 2017—Elimination of all significant, unauthorized non-stormwater contributions will be completed for the investigated outfalls.
• December 28, 2017—Source investigations will be completed on the remaining 50% of the major outfalls with significant non-stormwater discharges in the Beach Cities EWMP area, (source investigation will be 100% complete by this date).
• March 28, 2018—Outfall monitoring will be initiated as required for the remaining 50% of investigated outfalls, based on results of source identification in accordance with Section 5.6 of the Beach Cities CIMP, to determine compliance with applicable non-stormwater WQBELs derived from TMDL WLAs.
• June 26, 2018—Elimination of all significant, unauthorized non-stormwater contributions will be completed for 100% of the major outfalls in the Beach Cities EWMP Area. Source investigations will take place in accordance with Section 5.5 of the Beach Cities CIMP. Non-stormwater discharge elimination will be prioritized in Santa Monica Bay due to the fact that the dry weather final compliance date for the Santa Monica Bay Beaches Bacteria TMDL has passed.
TMDL-Specific Control Measures The Beach Cities WMG has evaluated BMPs that have been previously identified in TMDLs and corresponding implementation plans. Those BMPs that have been constructed are discussed in Section 2.6.4 (Santa Monica Bay Watershed) and Section 3.6.4 (Dominguez Channel Watershed). Other measures identified in TMDLs and TMDL implementation plans were evaluated as part of the RAA process in order to determine what combination of measures would achieve compliance with Permit-specified WQBELs and/or RWLs.
Additional BMPs In addition to the MCMs, non-stormwater discharge measures, and TMDL control measures, the Beach Cities WMG has identified additional BMPs to achieve compliance with Permit-specified WQBELs and/or RWLs. These BMPs are discussed in more detail in Section 2.6 (Monica Bay Watershed) and Section 3.6 (Dominguez Channel Watershed) below.
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Demonstration of BMP Performance – Introduction to the Reasonable Assurance
Analysis The EWMP is a planning document intended to lay out a framework of activities that will comply with water quality requirements. Therefore, it is necessary to demonstrate that selected BMPs are reasonably expected to meet defined goals and objectives. This demonstration of performance is described through a technically robust and rigorous RAA. Through this analysis the Beach Cities WMG identified and evaluated BMP implementation scenarios within the Beach Cities EWMP Area for each WBPC identified in Section 2.2. The RAA process demonstrates that implementation of EWMP-defined activities should result in the attainment of applicable Permit-specified WQBELs, and will also prevent discharges from causing or contributing to exceedances of applicable RWLs. Since the modeling conducted as part of the RAA serves as the basis not only for BMP evaluation but also BMP identification, Section 2.4 is devoted to providing details on the RAA process. Results from the RAA are presented in Section 2.7.
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.
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Figure 2-4. Non-Stormwater Outfall Screening Program
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2.4 REASONABLE ASSURANCE ANALYSIS APPROACH The following subsections provide a summary of the modeling tools and approach, modeling data, calibration, and validation.
2.4.1 DESCRIPTION OF RAA TOOLS AND APPROACH The approaches for performing the RAA in both dry and wet weather are described below.
Dry Weather Demonstrating “reasonable assurance” of compliance with dry weather limits for the SMBBB TMDL requires a methodology that accounts for many factors which cannot be accurately modeled based on urban runoff processes alone (Thoe et al, 2014), despite the extensive summer-dry and winter-dry weather beach-specific monitoring datasets that are available. Therefore, to perform the RAA for dry weather for the Beach Cities WMG area, a semi-quantitative methodology has been developed to follow a permit compliance structure, as independent lines of evidence for demonstrating that MS4 discharges could not be causing or contributing to receiving water exceedances at the beaches. Because FIB are considered the “controlling” pollutants of concern during dry weather in the Beach Cities WMG area (i.e., if MS4 discharges are compliant for bacteria during dry weather, they will be compliant for all TMDL and 303(d) pollutants during dry weather), the methodology was developed to focus on bacteria (Beach Cities WMG, 2014). The following criteria form the proposed dry weather RAA methodology. This methodology was presented to LARWQCB staff on April 9, 2014, and verbal feedback received at the time was supportive. If one criterion is met for CSMP compliance monitoring location (CML), then “reasonable assurance” is considered to be demonstrated. 1. A dry weather low flow diversion, disinfection system, or infiltration system is located at the CML. To meet this criterion, any such system should have records to show that it is consistently operational, well maintained, and sized to effectively eliminate freshwater surface discharges to the surf zone during year-round dry weather days. 2. There are no MS4 outfalls owned by the Beach Cities WMG Agencies within the CML’s drainage area, and therefore MS4 discharges could not be contributing to pollutant concentrations at the CML. 3. Non-stormwater MS4 outfall discharges do not reach the wave wash and thus are effectively eliminated within the CML’s drainage area. For this criterion to be met, supporting records from the non-stormwater outfall screening program should be supplied.
Wet Weather The wet-weather RAA process 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 separately-permitted lands, Federal land, State land, etc.);
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• For each analysis region (Figure 2-5), develop target load reductions (TLRs) for 90th percentile year for bacteria in SMB watershed based on LARWQCB RAA Guidelines, limit expressions in the Permit, and critical periods identified in the TMDLs;
• 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. TLRs, as discussed previously, represent a numerical expression of the Permit compliance metrics (e.g., bacteria allowable exceedance days [AEDs] per year for wet weather) that can be modeled and can serve as a basis for confirming, with reasonable assurance, that implementation of the proposed BMPs will result in attainment of the applicable TMDL-based WQBELs and RWLs in the Permit for Category 1 pollutants, or the Water Quality Objectives for Category 2 and Category 3 pollutants.
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Figure 2-5. Analysis Regions and Monitoring Locations within the SMB Watershed portion
of the Beach Cities EWMP Area
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Structural BMP Prioritization and Analysis Tool (SBPAT) Model The recommended RAA approach leverages the strengths of the publicly available, Permit-approved, Geographical Information System (GIS)-based model that has already been developed for the region and previously utilized in Jurisdictional Group 5 and 6 (J5&6): the Structural BMP Prioritization and Analysis Tool (SBPAT)12. SBPAT is a public domain, “open source,” GIS-based water quality analysis tool intended to: 1) facilitate the prioritization and selection of BMP project opportunities and technologies in urbanized watersheds; and 2) quantify benefits, costs, variability, and potential compliance risk associated with stormwater quality projects. The decision to use SBPAT for the SMB EWMP RAA in the manner described below is based on the model capabilities and the unique characteristics of the SMB, specifically: 1. Modeling of SMB hydrologic and watershed processes – SBPAT utilizes EPA’s Stormwater Management Model (SWMM) as the hydrologic engine, and SBPAT has been calibrated to local rainfall and Santa Monica Bay (SMB) stream flow gauges, consistent with requirements of the RAA Guidelines; 2. SMB pollutants of concern and their compliance metric expression – SBPAT has been utilized for planning applications related to Bacteria TMDL compliance (and specifically exceedance-day predictions, based on SMB criteria), including a demonstrated linkage of modeled bacteria loads to measured exceedance days; 3. Availability of new open space water quality loading data – Recently developed EMC data are consistent with SBPAT and were also updated to reflect new data developed in SMB as part of this RAA-development effort; 4. Capability to conduct opportunity and constraints screening – SBPAT was designed to support structural BMP placement, prioritization, and cost-benefit quantification, and was previously successfully used for such purposes in the SMB EWMP Group area and other nearby SMB subwatersheds; 5. Characterization of water quality variability – SBPAT is capable of quantifying model output variability and confidence levels, which is a requirement of the LARWQCB’s RAA Guidance; and 6. Supports quantification of both structural and non-structural BMPs, and
demonstrating compliance at both interim and final compliance dates – SBPAT’s modeling framework is easily compatible with methods for addressing non-structural BMPs and provides quantitative results for multiple BMP phasing milestones, as required by the Permit.
12 SBPAT is specifically referenced in the MS4 Permit Part VI.C.5.b.iv and was presented at the first two Permit Group TAC RAA Subcommittee meetings. Furthermore, SBPAT has been used for reasonable assurance analysis purposes in the Los Angeles region for four TMDL Implementation Plans, two WMPs, four EWMPs, and, in the San Diego region, for two Combined Load Reduction Plans and two Water Quality Improvement Plans.
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The quantification analysis component of SBPAT includes a number of features. The model:
• Calculates and tracks inflows to BMPs, treated discharge, bypassed flows, evaporation, and infiltration at each 10 minute time step;
• Distinguishes between individual runoff events by defining six-hour minimum inter-event time in the rainfall record (in order to track rain events), while also tracking inter-event antecedent conditions;
• Tracks volume captured by and bypassing BMPs, and summarizes and records these volumes by storm event; and
• Produces a table of each BMP’s hydrologic performance, including concentrations and loads by storm event, and consolidates these outputs on an annual basis.
2.4.2 MODELING DATA Data used for the quantification/analysis module include both fixed and stochastic parameters. The model utilizes Los Angeles region land use EMCs, USEPA SWMM, USEPA/American Society of Civil Engineers/Water Environment Research Foundation (USEPA/ASCE/WERF) International BMP Database (IBD) BMP effluent concentrations, watershed/GIS data, and a Monte Carlo approach (relying on repeated random sampling) to quantify water quality benefits and uncertainties. Model data flow is provided below in Figure 2-6.
Figure 2-6. SBPAT Model Data Flow Each model simulation integrates Monte Carlo methods that rely on repeated random sampling to obtain numerical results. Model simulations are run 20,000 to 50,000 times to calculate a distribution of outcomes that can support the definition of confidence levels and quantify variability. Consistent with the SBPAT usage, Monte Carlo methods are used in physical and mathematical problems when it is difficult to obtain a closed-form expression or when a
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deterministic algorithm is not desired. A schematic of SBPAT’s Monte Carlo process is provided in
Figure 2-7. Model documentation, as well as links to related technical articles and presentations, is provided at www.sbpat.net.
Figure 2-7. SBPAT Monte Carlo Method Components The spatial domain of the RAA includes the land within the Beach Cities EWMP area tributary to SMB and Dominguez Channel. Adjustments were made to account for contributions from agencies not party to this EWMP (e.g., State/Federal, California Department of Transportation [Caltrans], Industrial General Permit holders, etc.) and are described in more detail later in this document. GIS layers used in SBPAT included, but were not limited to, the following:
• Storm drains;
• Soils;
• Rain gauge polygons;
• Parcels;
• Land use; and
• Catchments.
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SBPAT utilizes a customized version of SWMM for continuously simulating study area hydrology and BMP hydraulics. Long-term, hourly rainfall data and average monthly evapotranspiration values are used along with land use-linked catchment imperviousness and soil properties to estimate runoff volumes. Revised and recalibrated SBPAT database values and EWMP-defined BMP information are used to estimate the volume of runoff generated from watershed areas and captured by BMPs. Storm events are individually tracked for the entire simulation so that the volumes of runoff infiltrated, evapotranspired, captured, and released (if applicable) by BMPs are estimated for every storm event. Hourly rainfall data from LAX (NCDC ID45114) were used in the portion of the Beach Cities EWMP area draining to Santa Monica Bay. Hourly rainfall data from a Los Angeles County rainfall gauge at Manhattan Beach (Station ID 1070) was used for the portion of the Beach Cities EWMP area draining to Dominguez Channel. Rain gauges are shown in Figure
2-8.
Figure 2-8. SBPAT Rain and Stream Gauges
Critical Condition Definition Consistent with the SMBBB TMDL and the LARWQCB RAA Guidance Document, the RAA was performed on the 90th percentile critical year. This year was determined by evaluation of local rainfall records for all four EWMP Groups located along Santa Monica Bay over the 1989 to 2011 period of record, evaluating “TMDL years” as defined by the SMBBB TMDL (i.e., November 1 –
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October 31). Of the local rain gauges evaluated, the Manhattan Beach gauge (Station ID 1070) (Figure 2-8), was determined to be the most representative of the Beach Cities WMG area. The rainfall record was analyzed to determine the 90th percentile year based on both the number of wet days (days with >=0.10-inch for rainfall and the three days following, per the SMBBB TMDL) as well as total annual rainfall. Table 2-5 below presents these results. The 90th percentile year was determined to be either 1995 or 2005 based on wet days (73 total). TMDL year 1995 was selected to be the most conservative of these two years because while it is the 90th percentile year based on number of wet days, 1995 also had slightly more total rainfall than 2005. Therefore, the RAA was performed on TMDL year 1995. Although detailed results are only provided for the Beach Cities WMG, the 90th percentile year was determined to be 1995 across all four SMB EWMP Groups (Santa Monica Bay, North Santa Monica Bay Coastal Watersheds, Beach Cities, and Peninsula). A summary of annual rainfall data for the gauge above is provided in Appendix Q.
Table 2-5. Rainfall Summary at Manhattan Beach Precipitation Gauge (Station ID 1070)
90th Percentile TMDL Year (Type) TMDL Year Wet Days* Total Rainfall (in) Number of Wet Days 1995 73 22.0 Total Annual Rainfall 2005 73 21.9 *Compliance with the wet weather SMBBB TMDL is based on the number of allowable exceedance days. The priority WBPCs for the Beach Cities EWMP area, combined with data availability, establishes the specific WBPCs addressed by the RAA. As previously described, SBPAT links the long-term hydrologic output from SWMM to a stochastic Monte Carlo water quality model to develop statistical descriptions of stormwater quantity and quality. Through this approach, the predicted runoff volumes for each storm are randomly sampled from the long-term storm event runoff volume record produced by SWMM. Land use-based wet weather pollutant EMC values (see
Appendix I) and BMP effluent concentrations (see Appendix J) for each storm are then randomly sampled from their lognormal statistical distributions. The runoff volumes (including volumes treated and bypassed by BMPs), land use EMCs, and BMP effluent concentrations are combined to determine the total pollutant loads and load reductions (i.e., difference between existing and post-BMP load estimates) for each sampled storm event. This procedure is then repeated thousands of times, each time recording the volume, pollutant concentrations, loads, and load reductions for each selected storm event. The statistics of these recorded results are then used to characterize the average daily values as well as the average (mean) values for the annual volume, pollutant loads, and pollutant concentrations in stormwater runoff from the modeled area, with and without BMPs implemented. The IBD is a comprehensive source of BMP performance information (www.bmpdatabase.org), comprised of data from a peer-reviewed collection of studies that have monitored the effectiveness of a variety of BMPs in treating water quality pollutants for a variety of land use types. Water quality performance data from the IBD were used to develop effluent concentrations (averages and standard deviations) for the BMPs and constituents in Table 2-6. As with land use EMCs, the effluent quality of BMPs is highly variable. To account for this variability in SBPAT, effluent quality data were analyzed and descriptive statistics were generated for use in the Monte Carlo statistical sampling technique. Appendix J contains detailed information on the BMP effluent statistics.
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Table 2-6. BMPS and Constituents Modeled in SBPAT1
BMPs Constituents Constructed Wetland / Retention Pond (with Extended Detention) Constructed Wetland / Retention Pond (without Extended Detention) Dry Extended Detention Basin Hydrodynamic Separator Media Filter Subsurface Flow Wetland Treatment Plant Bioswale Bioretention with underdrain Bioretention (volume reduction only)2 Cistern (volume reduction only)2 Green Roof (volume reduction only)2 Porous Pavement (volume reduction only)2 Low Flow Diversion (volume reduction only)2
Fecal Coliform (FC) Total lead (TPb) Total suspended solids (TSS) Total phosphorus (TP) Dissolved phosphorus as P (DP)3 Ammonia as N (NH3) Nitrate as N (NO3) Total Kjeldahl nitrogen as N (TKN) Dissolved copper (DCu) Total copper (TCu) Dissolved zinc (DZn) Total zinc (TZn)
1 Constituents are addressed for BMPs that provide treatment (i.e., excluding those identified as “volume reduction only”). 2 For these BMPs, it is assumed that 100% of pollutant loads associated with the volume of water infiltrated is treated by the BMP. Water that bypasses or otherwise discharges from the BMP is assumed to receive no treatment. 3 Dissolved phosphorus and orthophosphate datasets were combined to provide a larger dataset and because the majority of orthophosphate is typically dissolved and many datasets either report dissolved phosphorus or orthophosphate, but not both.
2.4.3 CALIBRATION
Hydrology The hydrology component of SBPAT was calibrated for the only location in the entire greater SMB watershed where all data requirements (daily flow, hourly precipitation, and daily beach bacteria concentrations) were met - the Topanga Creek subwatershed. No other SMB areas have sufficient data available. The Topanga Creek subwatershed is located north of the Beach Cities WMG area. Since primary output for SBPAT’s prediction of the SMB watershed are annual volumes and pollutant loads, the calibration focused on accurate prediction of annual discharge volumes from the Topanga Creek subwatershed outlet, with estimated baseflow removed. Hourly rainfall data were used for the nearby Lechuza Patrol Station #72 gauge (gauge reference ID 352b, see Figure
2-8, in Malibu, with these data adjusted upward based on an annual rain depth ratio between the higher elevation Topanga Fire Station #69 gauge (gauge reference ID 6) and the coastal Lechuza gauge. Los Angeles County’s Topanga Creek streamflow gauge (gauge reference ID F54C-R) was used to estimate measured annual discharge volumes for comparison with modeled volumes. The effective impervious percentage for the open space land use category and the saturated hydraulic conductivity of all mapped soil types served as calibration parameters.
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Previous hydrologic calibration reported in the Beach Cities EWMP Work Plan (Beach Cities WMG, 2014) was refined to include additional precipitation and streamflow data. The refined calibration used a vacant undifferentiated land use effective imperviousness value of 1 percent. The refined calibration required the evaluation of various saturated hydraulic conductivity multipliers that would result in increased model runoff (i.e., each soil type’s original hydraulic saturated conductivity was multiplied by the same value). The calibration was performed iteratively with multipliers ranging from 0.1 to 2.0 until the average annual modeled volume produced an acceptable error value when compared to the average annual observed volumes. A multiplier of 0.20 was selected as most appropriate. Figure 2-9 is a depiction of the refined hydrologic calibration results, including the 0.20 saturated hydraulic conductivity multiplier. The emphasis of the calibration effort focused on accurate, unbiased prediction of “non-extreme” annual conditions (annual volumes exceeding a 25-year frequency, 4 percent probability, were excluded from the calibration effort). Based on available data, the period of calibration was 12 years, between 2001 and 2012, with water years 2005 and 2008 excluded due to outlying streamflow measurement results13. These calibrated input parameter values were used throughout the SMB watersheds in the wet weather RAAs. Figure 2-10 presents these same results in a flow duration curve format, which compares the distribution of annual discharge volume magnitudes throughout the period analyzed between the modeled and observed data.
Figure 2-9. Annual Runoff Volumes for Topanga Creek Subwatershed: Modeled vs.
Observed. 13 The stream gauge annual volume measurement in 2008 was unexplainably high (corresponding to a runoff coefficient greater than one), and the 2005 year included a 15-day period of near-record rainfall levels that were anomalously high (where the mean annual rainfall depth fell between December 27 and January 10, and major landslides were reported in coastal Ventura County).
0
1,000
2,000
3,000
4,000
5,000
6,000
0 1,000 2,000 3,000 4,000 5,000 6,000Annual Modeled Flows After Calibration (acre-ft)Topanga Annual Observed Flows (no baseflow) (acre-ft)
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Figure 2-10. Annual Runoff Volumes for Topanga Creek Subwatershed: Modeled vs.
Observed (Flow Duration Curve Format). Following calibration, average relative prediction error (or the percent differences between the average annual observed and modeled annual runoff volume) was calculated to be -0.24%. According to the LARWQCB’s RAA Guidance Document, which is based on Donigian, 2000, SBPAT model performance with respect to hydrology as a result of this calibration is in the “very good” category.
Water Quality The RAA Guidelines require water quality calibration based on available monitoring data from each analysis region over the most recent 10 years. However, in the SMB EWMP analysis regions, freshwater (i.e., mass emission type) monitoring stations with fecal coliform data 14 are not available from a recent 10 year period. Therefore, calibration that meets the guidelines is not possible at this time. After several years of CIMP monitoring data have been collected, this may be reevaluated as part of the EWMP adaptive management process. Also, since a conventional water quality calibration was not possible at this time, a validation of baseline exceedance day output was performed for the Leo Carrillo reference watershed using recent beach bacteria monitoring results, as described below. The reference watershed was used for this validation because it is the basis of the TMDL Waste Load Allocations, which the RAA TLRs are intended to represent.
14 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.
01,0002,0003,0004,0005,0006,000
0 10 20 30 40 50 60 70 80 90 100Annual Runoff Volume (ac-ft)Percent of Results Below Y-Axis Value (%)
Measured Data (No Baseflow) - LACDPW Gauge ID F54C-R Modeling Output
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2.4.4 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 Canyon15 (SMB-1-18) between 2005 and 2013. Figure 2-11 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.
Figure 2-11. Correlation between Modeled Fecal Coliform Loads and Observed Exceedance
Days (each point represents one TMDL year, 2005-2013) 2.5 BASELINE LOADS AND TARGET LOAD REDUCTIONS The process for establishing TLRs for the modeled WBPC (bacteria in Santa Monica Bay) is described in the following section. For analysis regions with SMBBB TMDL CMLs that have anti-degradation-based allowable exceedance days for wet weather, a target load reduction of zero was 15 This subwatershed is 88 percent open space and was selected for water quality validation due to it being the hydrologic calibration subwatershed as well as because it had daily shoreline monitoring data, which was necessary in order to have a sufficiently robust dataset of annual wet weather exceedance days.
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assumed consistent with the TMDL’s approach which acknowledges that historic bacteria exceedance rates for each of these analysis regions are lower than that of the reference beach, on average. This assumption of zero target load reduction applies for seven of the 11 total SMBBB TMDL CMLs in this Beach Cities watershed – i.e., SMB-5-1, SMB-5-3, SMB-5-4, SMB-5-5, SMB-6-2, SMB-6-5, and SMB-6-6. Historic wet weather monitoring data (2005 – 2013) at these sampling locations confirm this understanding, as the long-term exceedance rate at all seven sites varies between 6.4 and 22%, below the long-term wet weather exceedance rate at the reference beach (26%). Bacteria reductions were still modeled using SBPAT in these analysis regions, but BMP modeling results were not compared with a target load reduction; i.e., quantification only serves to express the additional water quality benefits of existing and proposed BMPs in these analysis regions.
2.5.1 BACTERIA In order to establish a TLR for each modeled Santa Monica Bay analysis region, a modeling methodology was developed and tested to relate the annual number of modeled calendar days with rainfall-generated runoff (or “discharge days”) to the expected annual bacteria exceedance days, which is the Permit’s WQBEL expression for the SMBBB TMDL. To be consistent with the SMBBB TMDL for wet weather, which established the allowed exceedance day Waste Load Allocations based on monitoring results from the Leo Carrillo reference beach, this modeling methodology was first tested on Leo Carrillo and its Arroyo Sequit subwatershed for the same critical year as the TMDL (TMDL year 1993). The goal of this analysis was to validate the modeling methodology by comparing its predicted exceedance days for Leo Carrillo with the 17 exceedance days from the TMDL, for TMDL year 1993. This analysis occurred in three steps: 1. The calibrated SBPAT model, using the nearby Lechuza Patrol Station gauge for TMDL year 1993 (consistent with the TMDL), resulted in 59 discharge days for Arroyo Sequit. 2. Based on 2003 to 2013 Leo Carrillo monitoring data, 27% of wet weather samples exceeded the single sample recreational Water Quality Objectives on days with rainfall greater than 0.10-in. In other words, 27% of wet weather days when runoff discharges might be expected (i.e., days with rainfall), FIB concentrations at the beach exceeded the objectives. 3. Multiplying 59 discharge days by the 27% exceedance percentage results in 16 predicted wet weather exceedance days for Leo Carrillo for TMDL Year 1993. This result is within 6% of the 17 exceedance days that were determined through the original analysis in the SMBBB wet weather TMDL, thereby validating the proposed exceedance day calculation methodology. After validation of the modeling methodology using the reference watershed, it was applied to all SMB analysis regions to predict baseline exceedance days for the 90th percentile year, or TMDL year 1995. Once baseline exceedance days were estimated for every analysis region, the exceedance day count was compared with allowed exceedance days from the TMDL (i.e., 17 for all non-anti-degradation compliance monitoring beaches). To determine the TLR necessary for each analysis region to meet the allowed exceedance days, a virtual retention BMP was modeled at the outlet of
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each analysis region. This approach was presented to LARWQCB staff on June 6, 2014 and verbal feedback received during the meeting was supportive. Each virtual retention BMP included a diversion with a virtual hydraulic capacity that results in in a model-derived bypass frequency (or number of discharge days), during TMDL year 1995 that meets the allowable exceedance day criteria. Each diversion is modeled as a full capture system. The net 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) for the 90th percentile year (1995) becomes the TLR for each analysis region. For the RAA, reasonable assurance of compliance is established when load reductions associated with proposed BMPs equal the TLR for each analysis region. In summary, the following approach was implemented to calculate a TLR for each modeled analysis region (see Appendix K for example calculation): 1. Each analysis region was modeled in SBPAT for the 90th percentile year (TMDL 1995). 2. The existing, baseline condition (i.e., without any outlet retention BMP) was modeled for each analysis region, resulting in a mean baseline fecal coliform (FC) load for the 90th percentile year (baseline load). 3. The exceedance percentage of samples collected during days with precipitation greater than 0.1 inches was determined for each analysis region. 4. The allowable number of discharge days for each analysis region was calculated by dividing 17 TMDL allowable exceedance days by the exceedance percentage calculated in Step 3. 5. An instream diversion to a large virtual retention BMP at the outlet of each analysis region was iteratively sized so that it only bypasses during the number of allowable discharge days determined in Step 4. 6. Each diversion and virtual retention BMP was then modeled in SBPAT to produce a mean FC load for the 90th percentile year (allowed load). 7. For each analysis region , the difference between the baseline load (step 2) and the allowed load (step 6) resulted in a TLR for the 90th percentile year, which was the target load reduction required to meet the 17 allowable TMDL exceedance days for wet weather. By implementing the steps described above, TLRs were developed for all analysis regions within the MS4, including both open beach and point zero CMLs. These TLRs are presented in Table 2-7 for both the interim and final compliance deadlines. TLRs for the interim compliance deadlines are assumed to be 50% of the final TLR. TLRs for analysis regions located between two point zero CMLs, but not representing an open beach site, were assigned the TLR of the geographically smaller of the two adjacent CML analysis regions. It should be noted that a zero percent TLR was calculated in the analysis region draining to CML SMB-6-03. This analysis region and CML had a lower average wet weather exceedance rate than the reference watershed based on a recent nine year period (2005-2013), produced relatively few modeled stormwater discharge days, and had few years with measured wet weather exceedance
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days greater than allowable exceedance days (i.e., only three of the recent nine years exceeded the allowed days, and each year by just one exceedance day). Similarly, a zero percent TLR was also calculated in the analysis region draining to CML SMB-6-04. The frequency of exceedance at SMB-6-04 (27.6%) was lower than that of the surrounding anti-degradation sites SMB-6-02 (33.3%) and SMB-6-05 (31.0%) and also lower than the exceedance rate of SMB-6-03 (37.9%), which was calculated to have a TLR of zero. Further, SMB-6-04 is an open beach CML with no major MS4 outfall at the sampling location. As stated earlier, nine CMLs with anti-degradation-based wet weather allowable exceedance days were assigned zero TLRs to reflect their historic good water quality. Although the SMBBB TMDL requires only that beach water quality at anti-degradation compliance locations be maintained, the Beach Cities EWMP will seek to implement nonstructural and Low Impact Development (LID)-based BMPs within the SMB portion of their EWMP area which will protect and potentially improve water quality at these beaches and is consistent with the J5&6 Implementation Plan (Geosyntec Consultants, 2011) for the SMBBB TMDL. These measures, though not required for RAA demonstration, are quantified in Section 2.6.3 below.
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Table 2-7. Target Load Reductions for Fecal Coliform for each Modeled Analysis Region in Santa Monica Bay Watershed - TMDL Year 1995
Analysis Region
2003-2013
Historical
Exceedance
Frequency
Allowable
Discharge
Days
Diversion
Flowrate
(cfs)
Baseline Condition for the Critical Year Allowed Condition for the Critical Year6 Target Load Reduction for the Critical Year6
Annual
Runoff
Average
Pollutant
Concentration5
Annual
Pollutant
Load Annual Runoff
Average Pollutant
Concentration5
Annual Pollutant
Load
Interim Target Load
Reduction Final Target Load Reduction
(Daily Rainfall
>0.10-in)
(Daily Rainfall
> 0.10-in) (ac-ft)
(MPN/
100mL) (1012 MPN) (ac-ft)
(MPN/
100mL) (1012 MPN)
Absolute
Load
% of
Baseline
Annual Load
Absolute
Load
% of
Baseline
Annual Load (1012 MPN) (1012 MPN) SMB-5-011 10.3% 4 0 39 15,400 7.4 39 15,400 7.4
Interim target load reduction assessed on a watershed-wide basis
0 0% SMB-O-06 N/A 4 0 90 20,700 23.0 90 20,700 23.0 0 0% SMB-5-02 67.9% 17 53 1516 28,600 534.8 1516 15,400 287.2 247.6 46.3% SMB-5-02/ SMB-5-032 N/A 12 0 123 23,000 34.9 123 23,000 34.9 0 0% SMB-5-031 17.2% 6 0 65 36,200 29.0 65 36,200 29.0 0 0% SMB-5-03/ SMB-5-042 N/A 9 0 251 28,800 89.3 251 28,800 89.3 0 0% SMB-5-041 31.0% 12 0 51 27,200 17.1 51 27,200 17.1 0 0% SMB-5-04/ SMB-5-052 N/A 10 0 37 17,800 8.2 37 17,800 8.2 0 0% SMB-5-051 31.0% 8 0 472 31,400 182.8 472 31,400 182.8 0 0% SMB-5-05/ SMB-6-012 N/A 13 0 36 15,100 6.7 36 15,100 6.7 0 0% SMB-6-013 63.9% 17 70 2118 27,100 706.6 2118 15,100 394.3 312.1 44.2% BCSump3 63.9% 17 40 1191 25,800 379.4 1191 13,700 201.4 178 46.9% SMB-6-01/ SMB-6-022 N/A 16 0 621 21,200 162.5 621 21,200 162.5 0 0% SMB-6-021,4 33.3% 14 0 358 22,600 99.6 358 22,600 99.6 0 0% SMB-6-03 37.9% 17 0 206 24,500 62.2 206 24,500 62.2 0 0% SMB-6-04 27.6% 17 0 621 27,400 209.9 621 27,400 209.9 0 0% SMB-6-051 31.0% 11 0 230 32,000 90.9 230 32,000 90.9 0 0% SMB-O-08 N/A 7 0 425 26,500 138.9 425 26,500 138.9 0 0% SMB-6-061 10.3% 3 0 19 28,000 6.7 19 28,000 6.7 0 0%
SMB Watershed-
Wide N/A N/A N/A 8468 26,700 2789.9 8468 19,600 2052.1 368.9 13% 737.7 26% 1 Anti-degradation site. 2 For the unmonitored tributary areas located in-between the CML tributary areas, TLRs were assigned from the geographically smaller of the two adjacent CML analysis regions. 3 “BCSump” was defined as a separate analysis region for modeling purposes. The baseline load for “BCSump” analysis region was combined with the baseline load of the “SMB-6-01” analysis region to equal the total baseline load contributing to the SMB-6-01 CML (“SMB-6-01+BCSump”). 4 The drainage area to Outfall SMB-O-07 is encompassed by analysis region SMB-6-02; therefore SMB-O-07 was analyzed as part of analysis region SMB-6-02. 5 Average pollutant concentrations are estimated as the total annual load divided by the total annual runoff volume. 6 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 target load reductions in terms of runoff volume and concentration are shown for informational purposes only.
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2.6 BEST MANAGEMENT PRACTICES
2.6.1 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 first); 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 WMG. 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); 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 (2003) 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 output are reported for both the interim (2018) and final (2021) TMDL compliance dates.
2.6.2 RECOMMENDED MCMS AND NONSTRUCTURAL BMPS The Permit allows permittees developing an EWMP the opportunity to customize the MCMs specified in the Permit to focus resources on high priority issues within their watersheds. Modifications to the MCMs must be appropriately justified and still be consistent with 40 CFR § 122.26(d)(2)(iv)(A)-(D). A control measure may only be eliminated based on the justification that it is not applicable to a particular permittee (per Section IV.C.5.b.iv.1(c). Customized measures, once approved as part of the EWMP, will replace in part or in whole the prescribed MCMs in the Permit. The Planning & Land Development Program is not eligible for customization in that it may be no
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less stringent than the baseline requirements in the Permit. However, it can be enhanced over the baseline permit requirements if desired. The Permit-specified MCMs (baseline MCMs) build upon the MCMs in the previous MS4 Permit (Order 01-182). Although similar in many ways to the previously required MCMs, in most cases the baseline MCMs contain more prescriptive record-keeping and/or implementation requirements. Summary assessments of each MCM contained in the Permit are provided in Table 2-8, as well as a determination as to whether the Beach Cities WMG will implement the MCM provisions as defined in the Permit, or whether modifications will be made. Additional modifications may also be made through the Adaptive Management Process, outlined in Section 5.
General Framework for MCM Customization An approach for evaluating existing institutional MCMs was developed as part of the Beach Cities EWMP Work Plan and was used to evaluate existing MCMs and develop the customized MCMs. The following steps provide a general framework for MCM customization: 1. Identify MCMs for potential customization. This may include identifying: a. MCM requirements prescribed by the Permit which are not already being implemented by the permittee; b. Currently implemented MCMs which have been enhanced over the previous Permit as part of TMDL implementation, e.g., Clean Bay Restaurant Program; c. Programmatic solutions/non-structural controls identified in TMDL implementation plans which may not yet have been implemented; and d. MCMs which are currently being implemented but which may be excessive in scope. For example, commercial inspections being conducted of retail gasoline facilities which are already heavily regulated through other environmental programs in areas that have no receiving water impairments for the pollutants of concern may be carried out less frequently, or discontinued indefinitely. 2. Identify MCMs which are not applicable. A control measure may be eliminated based on the justification that it is not applicable to a particular permittee. For example if it is the policy of a permittee not to use pesticides in public agency activities, then there is no need for tracking of pesticide use and this MCM may be proposed for elimination. 3. Assess the effectiveness of the incremental baseline MCM requirements with respect to water quality priorities. The data necessary to quantify this will vary greatly by MCM, but may include information such as: receiving water quality, inspection and reporting records, number of qualifying projects (e.g., number of construction projects greater than 1 acre), number of pet station bags used, amount of material picked up by street sweeping activities, number of employees trained, and maintenance records. Additionally, the California Stormwater Quality Association (CASQA) provides a tool to estimate the effectiveness of stormwater management programs (CASQA, 2015). The tool recommends possible assessment metrics that can be used for various stormwater programs.
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4. Quantify the additional resources required to implement the incremental baseline MCMs. This may include estimating additional staff resources in terms of full-time employees, consulting resources, and contracted services. 5. Assess the effectiveness and resources required to implement the customized MCM. The process to quantify these will be the same as the process used to quantify the baseline effectiveness of the existing MCM. 6. Compare the assessed effectiveness and resources required to implement the incremental baseline MCMs and the customized MCMs. Customization can be justified in several ways: a. If the customized MCM effectiveness is equal to or greater than the baseline MCM, customization can be justified. b. If an MCM requirement is not applicable, then elimination is justified. c. If the incremental MCM requires additional resources that are disproportionate to the increased effectiveness achieved, then retention of the existing MCM may be justified. 7. Document the customized MCM justification. MCMs were evaluated based on their effectiveness in addressing the WBPCs specific to the Beach Cities EWMP Area and based on the Beach Cities WMGs knowledge and experience with existing MCMs. In many ways, the Group’s practical experience with MCM implementation over time provides the best insight as to what MCM modifications/ enhancements will be most helpful to target the WBPCs of concern in the Beach Cities EWMP Area.
Table 2-8 summarizes the proposed MCM modifications common to the Beach Cities EWMP WMG, which include promotion of Ocean Friendly Landscaping Workshops as part of the residential outreach permit requirement, distribution of a Clean Bay Restaurant Program brochure to promote public education, establishment of a stormwater website for J5&6, implementation of the Clean Bay Restaurant Program as an assistance program for small businesses, and annual restaurant inspection as commercial pollutant sources. The LACFCD will implement the MCMs identified in VI.D.44 of the MS4 Permit with no additional modifications. In addition to the MCM modifications being implemented by the WMG as a group, the Beach Cities WMG has identified additional individual city-specific MCM enhancements, which include organization of educational and cleanup-oriented events, installation of pet waste collection stations as a part of the residential outreach requirement, a ban on plastic bags in Manhattan Beach and polystyrene food containers in Hermosa Beach, and development of environmentally oriented city websites. City-specific MCMs enhanced beyond the 2012 Permit requirements are specified in
Table 2-8. Details and descriptions of these enhancements are provided in Appendix L. The MCM enhancements shown in Table 2-8 and Appendix L are examples and are not comprehensive. The Beach Cities WMG agencies’ LID Ordinances and Green Street Policies are included as Appendix M and Appendix N, respectively.
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Table 2-8. MCM Modifications and Agency-Specific Enhancements for Beach Cities EWMP Area
2012 Permit Requirement
Baseline
Requirement
Maintained by
all Cities
General Beach
Cities MCM
Enhancement
(all Cities)
City-Specific MCM Enhancement
City of Manhattan Beach City of
Redondo Beach
City of
Hermosa Beach City of Torrance
MCM Milestone/ Already
Implemented? MCM Milestone/ Already
Implemented? MCM Milestone/ Already
Implemented? MCM Milestone/ Already
Implemented?
D.2 Progressive Enforcement (Applies D.6, D.7, D.8, and D.10) Develop and maintain a Progressive Enforcement Policy X X Milestone: 1/1/2016 Conduct follow-up inspection within 4 weeks of date of initial inspection X Take progressive enforcement X X Milestone: 1/1/2016 Retain records X Refer violations to LARWQCB X Investigate complaints from LARWQCB X Assist LARWQCB with Enforcement Actions X
D.5 Public Information and Participation Program (PIPP) Participate in a Countywide PIPP, WMP PIPP, or individual PIPP that measurably increases knowledge and changes behavior, and involves a diversity of socio economic and ethnic communities X X Implemented Maintain reporting hotline X X Implemented Publish hotline info on web, telephone book X ID staff/department that serve as the contact (publish this info) X Organize events (e.g., clean ups) X X X Implemented X Implemented X Implemented X Implemented Residential Outreach (Individually or with group): X X X Implemented X Implemented X Implemented X Implemented Public Service Announcements X X X Implemented X Implemented X Implemented (Develop) Public education materials on: vehicle fluids; household waste; construction waste; pesticides, fertilizers, and integrated pest management (IPM); green wastes; and animal wastes X X Implemented except for IPM materials (Milestone of June 2017 for IPM) X All except IPM are implemented (Milestone of June 2017 for IPM materials) X Implemented
Distribute public education materials at points of purchase X X X Implemented X Implemented X Implemented Maintain stormwater website X X X Implemented X Implemented X Implemented Provide schools with materials to educate children (K-12); can use state produced materials X X Implemented X Implemented X Implemented
D.6 Industrial/ Commercial Track Critical Sources - maintain inventory (watershed based or lat/long recorded) X Educate - notify critical sources of BMP requirements X Implement a Business Assistance Program for select sectors or small businesses - technical assistance, and distribute materials to specific sectors X X X Implemented X Milestone: 1/1/2016 Inspect Commercial Sources X X X Implemented Inspect Industrial Sources - Initial mandatory inspection X N/A N/A X Implemented Secondary mandatory inspection X N/A N/A
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2012 Permit Requirement
Baseline
Requirement
Maintained by
all Cities
General Beach
Cities MCM
Enhancement
(all Cities)
City-Specific MCM Enhancement
City of Manhattan Beach City of
Redondo Beach
City of
Hermosa Beach City of Torrance
MCM Milestone/ Already
Implemented? MCM Milestone/ Already
Implemented? MCM Milestone/ Already
Implemented? MCM Milestone/ Already
Implemented? No Exposure - evaluate and conduct 2nd inspection at 25% of facilities X N/A N/A As needed, conduct Progressive Enforcement follow-up inspections (see Part VI.D.2) X
D.7 Planning and Land Development Update ordinance/design standards to conform with new requirements (LID) X X Implemented LID ordinance enhanced beyond permit minimum X Implemented
Optional: Establish alternative compliance for technical infeasibility, e.g., allow onsite biofiltration or offsite infiltration or groundwater replenishment or retrofit X
Optional if allowing offsite mitigation: Develop a prioritized list of offsite mitigation projects X Optional if allowing offsite mitigation: Develop a schedule for completion of offsite projects (must be with 4 yr of the Certificate of Occupancy of the first project that contributed funds) X
Optional if allowing offsite mitigation: Notice offsite projects to RB website X Optional if allowing offsite mitigation: List of mitigation projects descriptions and estimated pollutant and flow reductions X
Optional if allowing offsite mitigation: Provide aggregated comparison of alternative compliance to results that would have been expected with on-site retention of the SWQDv X
Optional: Submit documentation that a previously adopted LID ordinance provides equivalent pollutant loading and flow reduction X
Plan Review process - check LID and BMP sizing, etc., X X Implemented X Implemented X Implemented Establish internal agreements with structure for communication and authority for departments overseeing plan approval and project construction X
Require O&M plan for LID, treatment and hydromod BMPs X Implement tracking and enforcement program for LID, treatment and hydromod BMPs X Inspect all development sites upon completion and prior to occupancy certificates X Verify O&M of BMPs operated by Permittee through inspection X Develop maintenance inspection checklist X Require private parties that operate BMPs to submit verification of O&M; enforce as needed X
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2012 Permit Requirement
Baseline
Requirement
Maintained by
all Cities
General Beach
Cities MCM
Enhancement
(all Cities)
City-Specific MCM Enhancement
City of Manhattan Beach City of
Redondo Beach
City of
Hermosa Beach City of Torrance
MCM Milestone/ Already
Implemented? MCM Milestone/ Already
Implemented? MCM Milestone/ Already
Implemented? MCM Milestone/ Already
Implemented? As needed, conduct Progressive Enforcement follow-up inspections (see Part VI.D.2) X
D.8 Development Construction Program Update erosion and sediment control ordinance/procedures to conform with new requirements X X Implemented X Implemented Sites < 1 acre; inspect based upon water quality threat X X Implemented Establish priority inspection process X X Implemented Site < 1 acre; Require sites with soil disturbing activities to implement minimum BMPs X Require construction sites to prepare erosion sediment control plan(ESCP); review and approve (≥ 1 acre) X Verify construction sites coverage under the CGP and 401 cert X Develop/implement ESCP review checklist X Require construction sites to adhere to standards and make standards readily available X Conduct inspections at public and private sites (at least 1x/2 weeks for high threat sites (more frequently when rain is predicted or occurs; at least monthly for lower threat; also must inspect during all phases of construction - at least 3 times) X
Develop/implement SOPs/inspection checklist X Track number of inspections for inventoried sites and verify minimum inspections are completed X As needed, conduct Progressive Enforcement follow-up inspections (see Part VI.D.2) X Train plan review staff and inspectors X X Implemented X Implemented Staff must be knowledgeable in QSD/P key objectives, local BMPs standards X
D.9 Public Agency Activities Require public construction sites to implement Planning and Land Development requirements, implement Erosion and Sediment Control BMPs, and obtain Construction General Permit coverage X X Implemented Maintain inventory of Permittee owned facilities (including parks and recreation facilities,) X Update inventory X Develop retrofit opportunity inventory; evaluate and rank X X Implemented X Milestone: 1/1/2016 Cooperate with private land owners to encourage site specific retrofitting; includes pilot projects and outreach X Obtain IGP coverage for public facilities where appropriate X
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2012 Permit Requirement
Baseline
Requirement
Maintained by
all Cities
General Beach
Cities MCM
Enhancement
(all Cities)
City-Specific MCM Enhancement
City of Manhattan Beach City of
Redondo Beach
City of
Hermosa Beach City of Torrance
MCM Milestone/ Already
Implemented? MCM Milestone/ Already
Implemented? MCM Milestone/ Already
Implemented? MCM Milestone/ Already
Implemented? Develop procedures to assess impact of flood mgmt. projects on water quality of receiving waters; evaluate to determine if retrofitting is feasible X
Evaluate existing structural flood control facilities to determine if retrofitting facility to provide additional pollutant removal is feasible X
Implement source control BMPs at Permittee owned facilities/activities X Require city-hired contractors to implement source control BMPs X Prevent vehicle/equipment washing discharges to the MS4, including firefighting and emergency response vehicles X X Implemented
Ensure new/redeveloped/replaced wash facilities are plumbed to the sanitary sewer or self-contained. X Implement IPM program X X Implemented Ordinances, policies, and procedures reflect IPM techniques and include commitments and schedules to reduce the use of pesticides that cause impairments X X Implemented
Annually update in inventory of pesticides used by agency; quantify pesticides used by staff and contractors; demonstrate IPM alternatives to reduce pesticide use X X Implemented
Use SOPs for pesticide application X X Implemented Ensure no application of pesticides or fertilizers when two or more days with a 50% chance of rain is predicted by NOAA; within 48 hr of 1/2 inch of rain; or when water is flowing off the site X
Ensure staff applying pesticides are certified or working under supervision of a certified applicator in the appropriate category X
Update catch basin map add GPS locations and update priority X Inspect/Clean catch basin in areas not subject to Trash TMDL- Priority A: 3x during wet season, 1x during dry 1x; Priority B: 1x during wet 1x and 1x during dry; Priority C: 1x per yr. Maintain records. X
Required trash management at public events X X Implemented X Implemented Place and maintain trash receptacles/capture devices at newly identified high trash generating areas X X Implemented X Implemented X Implemented X Implemented Label storm drains X X Implemented Inspect labels prior to each wet season X Record and relabel illegible labels within 180 days of inspection X Post signs at access points to water bodies (open channels, creeks; lakes) X
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2012 Permit Requirement
Baseline
Requirement
Maintained by
all Cities
General Beach
Cities MCM
Enhancement
(all Cities)
City-Specific MCM Enhancement
City of Manhattan Beach City of
Redondo Beach
City of
Hermosa Beach City of Torrance
MCM Milestone/ Already
Implemented? MCM Milestone/ Already
Implemented? MCM Milestone/ Already
Implemented? MCM Milestone/ Already
Implemented? In areas not subject to the Trash TMDL, install trash excluders on catch basins or outfalls in areas defined as Priority A, or implement substantially equivalent BMPs X X Implemented X Implemented X Implemented X Milestone: 1/1/2016 Inspect and Remove trash and debris from open channels and other drainage structures 1x/yr before rainy season. X Eliminate discharge of contaminants during MS4 maintenance X Implement controls to limit infiltration of seepage from sanitary sewers to the storm drains X Implement routine preventative maintenance for both systems, survey sanitary sewer and MS4. May use SSO General Waste Discharge Requirement [WDR] to fulfill this requirement. X
Implement inspection and maintenance program for Permittee owned BMPs X Manage residual water in treatment control BMPs removed during maintenance X Street sweeping - Priority A: 2x/mo; B: 1x/mo; C: as needed, not less than 1x/yr X X Implemented X Implemented X Implemented X Implemented Implement road construction maintenance BMPs (e.g., restrict paving activity to exclude periods of rain) X Inspect and/or clean Permittee owned parking lots 2x/mo X X Implemented Train employees and contractors on stormwater requirements X X Implemented Train employees and contractors on pesticide use X
D.10 Illicit Connections and Illicit Discharges Elimination Continue IC/ID program X X Implemented X Implemented X Implemented X Implemented Written procedures for conducting investigations and eliminations X X Milestone: 1/1/2016 Initiate investigation within 72 hours from becoming aware of the discharge X X Implemented Implement solutions to eliminate discharge; conduct follow-up investigation to verify elimination; follow Progressive Enforcement Plan (see Part VI.D.2) X X Implemented X Implemented X Implemented X Implemented When discharge originates upstream of jurisdiction, notify the upstream jurisdiction and LARWQCB within 30 days X
Initiate investigation within 21 days for illicit connection X Permit or document illicit connection that only discharge stormwater or allowed non-stormwater X Eliminate illicit connection within 180 days of investigation X Facilitate public reporting via hotline X X Implemented
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2012 Permit Requirement
Baseline
Requirement
Maintained by
all Cities
General Beach
Cities MCM
Enhancement
(all Cities)
City-Specific MCM Enhancement
City of Manhattan Beach City of
Redondo Beach
City of
Hermosa Beach City of Torrance
MCM Milestone/ Already
Implemented? MCM Milestone/ Already
Implemented? MCM Milestone/ Already
Implemented? MCM Milestone/ Already
Implemented? Signage adjacent to open channels provide info re: public reporting X Document calls and actions associated with hotline X X Implemented Implement procedures on responding to complaints; evaluate and update procedures X X Implemented Implement a spill response plan X X Implemented Train staff and contractors on ID/IC X X Implemented Create a list of positions and contractors that require ID/IC training X
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2.6.3 QUANTIFIED NON-STRUCTURAL BMPS Non-structural BMPs have been categorized as follows for purposes of RAA. Specific model inputs are summarized in tabular format below.
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 including implementation of each agency’s Sanitary Sewer Management Plan consistent with Statewide WDRs, 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. A combined credit of 2.5 – 7.5% load reduction (average of 5%) was applied for all pollutants to represent the cumulative benefit from these BMPs.
Modeled Redevelopment Beginning in 2001, redevelopment projects were required by the Permit (via the Standard Urban Stormwater Management Program [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 2003 (the point at which the Bacteria TMDL was implemented) and 2015 for the SMB 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, 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 2-9).
Table 2-9. Estimated Annual Redevelopment Rates
Land Use
Annual Redevelopment Rate (% of total land use area)
Cities of Redondo Beach and
Torrance1
City of Hermosa
Beach
City of Manhattan
Beach Residential 0.18 0.31 0.10 Commercial 0.15 0.79 0.38 Industrial 0.34 0.79 0.38 Education 0.16 0.16 0.16 Transportation 2.7 2.7 2.7 1 Regionally developed redevelopment rates were applied to the City of Torrance and Redondo Beach (City of Los Angeles Bureau of Sanitation, 2012). Redondo Beach and Torrance areas used regionally developed redevelopment rates. For Hermosa Beach, the recent 4-year rate for redevelopment of residential areas was used based on city-specific
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LID implementation tracking data. The rate of redevelopment in all commercial land use categories tracked by SUSMP was combined to give an overall rate for both commercial and industrial (as that City has very few light industrial parcels), for historical as well as future redevelopment. For Manhattan Beach, a City-specific redevelopment rate of 3.8 percent for commercial redevelopment was provided based on historical SUSMP data over the past ten years. This value was also assumed for historical industrial redevelopment as well as future commercial and limited industrial redevelopment. For the residential land use, because there are insufficient data to project LID rates, a nominal 0.10 percent was assumed. BMPs were assumed to be implemented and to continue to be implemented in the future, at these rates across two distinct time periods:
• 2003 (SMBBB TMDL Effective Date) - 2015: The SUSMP requirements, based on the 2001 MS4 Permit, were assumed to be implemented over this period as flow-through media filters at a 0.2 in/hr design intensity (Los Angeles County Department of Public Works, 2002).
• 2015 – 2021 (SMBBB TMDL Final 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)16 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 2-1 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 by the BMPs described below (Table 2-10) 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 inches.
16 150% of the 1-year, 1-hour design storm was used per Section VI.D.7.c.iii of the Permit.
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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. 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 (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. It was assumed 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 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.
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Table 2-10. Redevelopment and Public Retrofit Incentives Model Assumptions
Implementation
Level BMP Type Design
Storm
Longitudinal
Slope
(ft/ft)
Manning
n
Hydraulic
Residence Time
(min)
Water Quality
Flow Depth
(in)
Effective
Retention
Depth (in)
Infiltration
Rate (in/hr) Redevelopment (2003-2015) Media Filter 0.2 in/hr - - - - - -
Redevelopment (2015-2021) Biofilters1 0.3 in/hr 0.03 0.25 10 4 2 Based on analysis region-specific soil type Bioretention 0.75 in - - - - 12 0.15 Public Retrofit Incentives (2015-2021) Bioswales representing downspout disconnects 0.2 in/hr 0.03 0.25 10 4 2 Based on analysis region-specific soil type 1 Modeled as bioswales using bioretention effluent EMCs
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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 2-12). A 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 (0.2 in/hr), with an effluent concentration set equal to the water quality standard (Table 2-11). For fecal coliform, 400 MPN/100mL was used.
Table 2-11. Non-MS4 Parcels – Modeled as Treated by Treatment Plants (i.e., BMPs that
will treat stormwater to the Water Quality Objectives)
Implemen-
tation Level BMP Type
Treatment
Flowrate
(cfs)
Design
Storm
(in/hr)
Average
Basin
Depth
(ft)
Equal-
ization
Volume
(cu-ft)
Diversion
Flowrate
(cfs)
Infiltration
Rate
(in/hr) Non-MS4 Parcels Treatment Plant 10,000 0.20 100.00 1,000 10,000 0.00001
2.6.4 STRUCTURAL BMPS Existing (constructed between 2003 and 2014) and proposed structural BMPs (regional and distributed) were modeled in SBPAT based on best available design information. The following sections outline the structural BMPs that were modeled as well as their drainage areas, design details in SBPAT, and any relevant assumptions. Modeled regional BMPs are depicted in Figure
2-13. Modeled distributed BMPs are depicted in Figure 2-14.
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Figure 2-12. IGP and Caltrans Area within the Santa Monica Bay portion of the Beach Cities
EWMP Area
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Figure 2-13. Existing and Proposed Regional BMPs within EWMP Area
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Figure 2-14. Existing and Proposed Distributed BMP Locations within the EWMP Area
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Existing Regional BMPs
Analysis Regions SMB-5-02 and SMB-5-03/SMB-5-04 The Manhattan Beach Green Belt Infiltration Project tributary area spans analysis regions SMB-5-02 and SMB-5-03/SMB-5-04. The Project, completed in February 2013, utilizes the linear greenbelt parkland that runs through the City to intercept and infiltrate dry weather and wet weather low flows from existing storm drains that intersect the parkway. The Project was designed to reduce the downstream peak flow and runoff volume from the 55.2 acres of contributing developed residential land use while also increasing groundwater recharge and subsequently increasing the effective permeability of the developed area. The 55.2 acre drainage area is part of the 161 acre tributary area that drains to the 1st Street outfall and Santa Monica Bay , which is part of the approximately 205 acres of drainage influencing the SMB-5-04 open beach monitoring site under the CSMP (2004).
Analysis Region SMB-5-05 The Pier Avenue Improvement Project captures and treats stormwater/urban runoff from residential areas on surrounding streets and commercial development in the downtown corridor along Pier Avenue (36-acre drainage area). The Project includes drainage improvements for treatment and infiltration of dry and wet-weather flows up to the design storm to reduce pollutant loading at the beach and to reduce flooding. The Hermosa Strand Infiltration Trench project receives runoff from a 76.2-acre, intensely developed mixed commercial and residential coastal subdrainage area conveyed via the Pier Avenue storm drain. The Pier Avenue storm drain was retrofit with a diversion structure and tide gate to direct dry-weather flows and wet weather low flows from the storm drain into a pump well, through a baffle-box pretreatment unit, then into the subsurface infiltration trench 1,000 feet long constructed on the beach adjacent to the Strand. The diversion pump was designed to divert up to 250 gallons per minute (GPM), which is significantly greater than would be required solely to divert dry weather runoff from the drainage area, thereby allowing for diversion of some wet weather flows.
Analysis Region SMB-6-01 Three existing regional BMPs were modeled within analysis region SMB-6-01. These include Amie Basin, Entradero Basin, and Henrietta Basin in their post-enhancement state. Since the basins were in existence prior to the 2003 TMDL effective date, pollutant removal credit was not assigned to the basins for their pre-2003 function, rather only the basin improvement design parameters that 1) improved water quality and 2) were implemented post-2003 were modeled. Infiltration rate, depth, volume, and discharge rate of the basins and their extended storage were extracted from
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analysis of the stage-discharge curves provided in the Stormwater Basin Enhancement Project Design Memorandum (CWE Corp., 2012).
Amie Basin, post-enhancements. Amie Detention Basin is an existing BMP that captures runoff from 409 acres of upstream land in analysis region BCSump, which drains to SMB-6-01. Based on boring test results, the average on-site infiltration rate is reported as 0.0082 in/hr. Due to its limited infiltration capacity, Amie Detention Basin is not designed for the purpose of on-site infiltration. Instead, its primary purpose is to discharge runoff slowly to the downstream Henrietta Detention Basin. The basin enhancements, completed in August 2015 (City of Torrance, 2014), increased the extended retention volume by reducing the permanent pool volume by 25% by creating additional flow paths within the basin. Due to the nature of the basin enhancements, Amie Detention Basin was modeled as a wet pond with extended detention capacity.
Entradero Basin, post-enhancements. Entradero Detention Basin is an existing BMP that treats runoff from 436 acres of upstream land in analysis region SMB-6-01 and is sized to capture the 0.75 inch storm. Based on boring test results, the average on-site infiltration rate is 1.28 in/hr. To increase the infiltration capacity, the post-enhancement design project, which was completed in August 2015 (City of Torrance, 2014), significantly increased the infiltration surface area from 0.03 acres to 1.44 acres. Entradero Detention Basin was modeled as an infiltration basin. The basin includes a small permanent pool (1500 cubic feet), the volume of which was excluded from the calculation of total storage capacity.
Henrietta Basin, post-enhancements. Henrietta Detention Basin is an existing BMP that treats runoff from Amie Detention Basin as well as an additional 153 acres of upstream land in analysis region BCSump for up to 0.75 inches storm. Based on boring test results, the average on-site infiltration rate is 2.1 in/hr. To further increase the infiltration capacity, recent design enhancements (completed in August 2015 (City of Torrance, 2014)) increased the maximum basin depth from 23 feet to 30 feet, and created additional flow path within the basin. In SBPAT, the Henrietta basin is modeled as an infiltration basin. The basin included a small permanent pool (6900 cubic feet), the volume of which was excluded from the total storage capacity.
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Analysis Region SMB-6-02 The Alta Vista Park Diversion and Re-Use Project is located in Redondo Beach and is designed to divert wet weather flows up to a rainfall event of 0.3 inches in 24 hours, collected from its 101-acre watershed. HDPE pipes comprise the approximately 100,000 gallons of underground storage. Excess overflows from the tank go into a 4,200 square feet infiltration bed located under the tank. The Project diversion facilities include structures that divert up to 4.5 cfs of the storm flow through a gross pollutant removal device.
Analysis Region SMB-6-03 The Sapphire Street Infiltration BMP consists of a low flow diversion and infiltration bed. The low flow diversion is intended to divert all dry weather flow and wet weather runoff from a storm up to 0.1 inches in 24 hours. The diversion facilities include a structure that will divert up to 11 cfs of the storm flow through a CDS unit. A smaller amount, up to 160 gpm, are diverted to a pump station that pumps the water to two stormwater bioretention filtration units, where it is then conveyed to the infiltration bed.
Summary of Existing Regional BMPs The existing regional BMPs, including their location, analysis region, model inputs, and expected performance, are summarized in Table 2-12 and Table 2-13. Wylie Sump and its tributary area were excluded from the RAA analysis because it is an 85th percentile capture project and also does not produce outflow and would therefore have no impact on the TLR or contribute any loads. The Wylie Sump receives runoff from 38 acres of the City of Manhattan Beach, 20 acres of Hermosa Beach, and 73 acres of Redondo Beach. There are no other 85th percentile capture projects in the Santa Monica Bay Watershed portion of the Beach Cities EWMP Area.
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Table 2-12. Parameters and Performance for Existing Regional BMPs Modeled as Infiltration Basins
Location
of BMP
Analysis
Region Project Name
Model Inputs Expected
Performance (load
reduction as a % of
analysis region
baseline load)
Design
Storage
Volume
(cu-ft)
Design
Storm
(in)
Average
Depth
(ft)
Diversion Rate
(cfs)
Infiltration
Rate
(in/hr) Manhattan Beach SMB-5-03/ SMB-5-04 Manhattan Beach Green Belt Infiltration - 0.45 2.6 6.7 2.1 4.7% SMB5-02 1.1% Hermosa Beach SMB-5-05 Pier Avenue Improvement Project infiltration systems - 0.21 2.6 11 0.77 2.3%
Hermosa Beach
SMB-5-03/ SMB-5-04
Hermosa Strand Infiltration Trench 1,400 - - 2.9 0.56
0.5% SMB-5-04/ SMB-5-05 1.9% SMB-5-05/ SMB-6-01 2.0% SMB5-04 1.4% SMB5-05 0.9% SMB6-01 0.2%
Torrance SMB-6-01 Entradero Detention Basin Enhancement 88,860 - 2.0 16 1.3 2.6% Henrietta Detention Basin Enhancement 383,000 - 12.0 54 2.1 4.6% Redondo Beach SMB-6-02 Alta Vista Park Diversion and Re-Use Project - 0.30 3.0 4.5 0.18 3.8% Redondo Beach SMB-6-03 Sapphire St Infiltration BMP - 0.10 1.5 11 0.74 9.5%
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Table 2-13. Parameters and Performance for Existing Regional BMPs Modeled as Wet Ponds with Extended Detention
Location
of BMP
Analysis
Region Project Name
Model Assumptions Expected
Performance (load
reduction as a % of
analysis region
baseline load)
Volume
(cu-ft)
Surcharge
Depth
(ft)
Surcharge
Drawdown
Time
(hr)
Permanent
Pool
Volume
(cu-ft)
Permanent
Pool Depth
(ft)
Diversion
Flowrate
(cfs)
Torrance SMB-6-01 Amie Detention Basin Post Enhancement 5,600,000 45 160 99,750 5 46 8.8%
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Proposed Regional BMPs
Analysis Region SMB-5-02 Regional BMP Parameters and Criteria One regional BMP (Alternative 1) is being proposed and was modeled within analysis region SMB-5-02 (Figure 2-15) — Manhattan Beach Infiltration Trench Project (see Table 2-13). The Manhattan Beach Infiltration Trench site is proposed along a public beach adjacent to a walking/bike path and consists of recreational open space. The project has an approximate infiltration footprint of 2.2 acres and drainage area of 1,600 acres. The storage volume of the project was estimated as 4.6 acre-feet, with an estimated drawdown time of 72 hours. Additional benefits achieved by this project include infiltration to help prevent intrusion of shallow saline groundwater associated with sea level rise in order to protect subsurface infrastructure from corrosion, as well as potential dune habitat restoration. This BMP can also increase public awareness through educational signage. An alternative design (Alternative 2) is for a beach infiltration trench at 80% of Alternative 1 in combination with an infiltration-based BMP at Polliwog Park, which would achieve approximately 10% of the target load reduction needed for analysis region SMB-5-02 and could potentially offset 20% of the required storage capacity of the Manhattan Beach Infiltration Project (Figure 2-15). In other words, the load reduction of Polliwog Park infiltration is equivalent to that of Manhattan Beach Infiltration Trench at 20% of its full Alternative 1 treatment volume. The addition of the Polliwog Park BMP would result in the additional benefits of neighborhood greening, mitigating issues such as the urban heat island effect, and also raising public education/awareness. The construction of a wetland would provide the additional benefit of expanding riparian habitat, and also help mitigate downstream flood control issues.
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Figure 2-15. Proposed Regional Projects, Analysis Region SMB-5-02
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Analysis Region SMB-6-01 Regional BMP Parameters and Criteria Three regional BMPs (and one potential alternative) are proposed within Analysis Region SMB-6-01, as described below, and depicted in Figure 2-16.
Park #3. The Park #3 Project was identified as a potentially suitable site for several different BMP types, including infiltration, wetlands, or a detention basin. Park #3 is located northwest of Blossom Ln. and 190th St, and has an approximately footprint of 0.4 acres and drainage area of 1,430 acres. The storage volume of the project was estimated as 87,100 cubic feet. Diversion flowrate was assumed to be 0.015% of the volume for preliminary planning purposes. This BMP would provide the additional benefits of neighborhood greening, mitigating issues such as the urban heat island effect and also raising public education/awareness. The construction of a wetland would provide the additional benefit of expanding riparian habitat, and also help mitigate downstream flood control issues.
Hermosa Beach Greenbelt Project. The Greenbelt site in Hermosa Beach was identified as a potentially suitable site for several different BMP types, including infiltration, wetlands, or a detention basin. The Greenbelt is situated between Valley Dr. and Ardmore Ave. and has a potential footprint of 1.5 ac and an approximate tributary area of 1,800 acres. The project storage volume is a function of its footprint. The diversion flowrate was assumed to be 0.015% of the volume for preliminary planning purposes.
Powerline Easement. A potential alternative location to the Hermosa Beach Greenbelt Project facility is located south of Herondo Street between N. Francisca Ave. and N. Catalina Ave., within a powerline easement.17 Both potential locations for the greenbelt project would provide the additional benefits of neighborhood greening, mitigating issues such as the urban heat island effect and also raising public education/awareness. The construction of a wetland would provide the additional benefit of expanding riparian habitat, and also help mitigate downstream flood control issues.
17 If this proposed design is to be developed within the powerline easements, certain considerations should be made. To alleviate concerns of saturating soils around powerline footings, and to allow for powerline maintenance activities to occur, stormwater facilities should be installed at least 100 feet from any tower and 10 feet from any pole. Special consideration and increased distances may be necessary when working around “dead-end” towers, or towers where transmission lines change direction. Access road clearance should also be maintained and basin depth must be considered for safety and illegal dumping purposes.
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Hermosa Beach Infiltration Trench. The Hermosa Beach Infiltration Trench project has a tributary area of 2000 acres. The project may be designed to reduce downstream water volumes and facilitate compliance with the dry-and wet-weather WLAs allotted in the SMBBB TMDL at the SMB-6-01 CML. If upstream projects (e.g., LID projects) and other City activities are implemented, TMDL compliance may be able to be achieved under reduced design requirements. Additional benefits achieved by this project include infiltration to help prevent intrusion of shallow saline groundwater associated with sea level rise in order to protect subsurface infrastructure from corrosion, as well as potential dune habitat restoration. This BMP can also increase public awareness through educational signage.
Figure 2-16. Proposed Regional Projects, Analysis Region SMB-6-01
Summary of Proposed Regional BMPs Four regional BMPs are proposed in the Santa Monica Bay Watershed 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 2-14.
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Table 2-14. Parameters and Performance for Proposed Regional BMPs Modeled as Infiltration Basins
Analysis
Region Location of BMP Project Name
Model Assumptions
Expected Performance
(load reduction as a % of
analysis region baseline
load)
Design
Storage
Volume
(cu-ft)
Design
Storm
(in)
Average
Depth
(ft)
Diversion
Rate
(cfs)
Infiltration
Rate
(in/hr)
SMB-5-02 Manhattan Beach
Manhattan Beach Infiltration Trench, Alt 1 198,000 - 2.1 160 13 36.5% Manhattan Beach Infiltration Trench, Alt 2 158,400* - 2.1 160 13 32.1%1 Polliwog Park Infiltration, Alt 2 148,000 - 4.0 11 0.7 4.4%
SMB-6-01 Hermosa Beach
Hermosa Beach Greenbelt Infiltration 319,000 - 5.0 48 12 15.1% Hermosa Beach Infiltration Trench 13,300 - 1.70 25 13 0.4% Redondo Beach Park #3 BMP Project 87,100 - 5.00 410 1.0 1.3% 1 The treatment volume of Manhattan Beach Infiltration Trench in Alternative 2 is set at 80% of the Alternative 1 volume so that load reductions achieved by BMP configurations in Alternative 1 and Alternative 2 are identical.
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Existing Distributed BMPs In 2008-09, the City of Hermosa Beach retrofitted the east side of Hermosa Avenue between 27th and 35th Streets with a series of seven filter/infiltration boxes to intercept, filter, and infiltrate low flows conveyed down side streets from the areas east of Hermosa Avenue prior to entry into catch basin inlets on Hermosa Avenue. The infiltration boxes were modeled in the RAA analysis as two bioretention systems due to their infiltration capabilities and combined into two systems (System A and System B) — one system per analysis region SMB-5-04 and SMB-5-03/SMB-5-04, respectively. The City of Manhattan Beach also replaced several downtown asphalt parking lots with pervious concrete. See Table 2-15 and Figure 2-14 for design assumptions and BMP locations.
Proposed Distributed BMPs Proposed distributed BMPs, including green streets, were modeled by assuming that stormwater runoff from high priority land use areas can be treated in the right-of-way, and 50%-50% use of biofilters and bioretention. Biofilters (also known as bioretention with underdrains) were sized to 150% of the 85th percentile, 24-hour design storm (0.3 in/hr) because they do not retain on site (they are flow-through systems), while bioretention units were sized to 100% of the 85th percentile, 24-hour design storm depth, calculated as the mean for each analysis region. Biofilters were modeled using bioswale volume reduction and bioretention effluent EMCs. Default modeling assumptions included longitudinal slopes of 0.03 ft/ft, Manning’s n of 0.25, hydraulic residence time of 10 min, and water quality flow depth of 4 in. Distributed green streets were implemented at similar rates (as a percentage of land use area) in residential and commercial land uses. Distributed BMPs were applied at levels unique to each analysis region, iteratively determined based on compliance with TLRs, after accounting for load reductions attributable to nonstructural and regional BMPs. They were applied by assuming treatment of stormwater from analysis region-specified percentages of single family, multi-family, and commercial land use areas, until TLRs are met. These land use and BMP type combinations were chosen based on their ability to result in maximum bacteria load reduction. In order to minimize redundancy of BMP coverage and avoid double-counting BMP benefits, distributed BMPs were not applied in the drainage area footprints of existing regional BMPs. However, they were modeled in the drainage area of proposed BMPs, as long as both were included in the same model run to avoid double counting. Performance of existing and proposed distributed BMPs are shown in Table 2-16.
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Table 2-15. Existing and Proposed Distributed BMPs
Implementation
Level
Analysis
Region(s) BMP Type
Design
Storm
Longitudinal
Slope
(ft/ft)
Manning
n
Hydraulic
Residence
Time
(min)
Water Quality
Flow Depth
(in)
Effective
Retention
Depth (in)
Infiltration
Rate (in/hr) Existing Manhattan Beach Porous Paving Project – El Porto Lot SMB-5-01 Porous Pavement Removal of existing asphalt and replacement with 10 inches of porous concrete
Existing Distributed Green Streets BMPs (2003-2015)1
SMB-5-04 (System A) Bioretention 0.038 - - - - 35 10 SMB-5-03/SMB-5-04 (System B) Bioretention 0.026 - - - - 35 10
Proposed Distributed Green Street BMPs (2015-2021)
MFR and COM/SFR land uses in BCSump, SMB-5-02, and SMB-6-01
Biofilters2 0.3 in/hr 0.03 0.25 10 4 2 Based on analysis region-specific soil type Bioretention Varies by analysis region (0.77 to 0.82 in) - - - - 12 0.15
1 In 2008-09 the City of Hermosa Beach retrofit the east side of Hermosa Avenue with a series of seven (7) filter/infiltration boxes to intercept, filter, and infiltrate low flows conveyed down side streets from the areas east of Hermosa Avenue prior to entry into catch basin inlets on Hermosa Avenue. The infiltration boxes were modeled as two bioretention systems due to their infiltration capabilities and combined into two systems (System A and System B) — one system per defined subcatchment. 2Modeled as a bioswale using bioretention EMCs.
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Table 2-16. Existing and Proposed Distributed BMP Performance
Analysis Region Implementation Level Status
Estimated load reduction
(as % of analysis region
baseline load) SMB-5-04 N/A - Existing Existing 1% SMB-5-03/ SMB-5-04 N/A - Existing Existing 0.1% SMB-5-02 5% on MFR/COM/SFR land uses Proposed 3% SMB-6-01+BCSump1 25% on MFR/COM/SFR land uses Proposed 2% 1 “BCSump” was defined as a separate analysis region for modeling purposes. The baseline load for “BCSump” analysis region was combined with the baseline load of the “SMB-6-01” analysis region to equal the total baseline load contributing to the SMB-6-01 CML (“SMB-6-01+BCSump”). 2.7 REASONABLE ASSURANCE ANALYSIS RESULTS
2.7.1 WET WEATHER Quantitative analyses were conducted for each analysis region separately and are summarized below. Average BMP load reduction results for each analysis region are presented in Table 2-17 below. Detailed results for all BMPs in terms of volume, concentration, and load for each WBPC and analysis region can be found in the electronic data files submitted along with the Beach Cities EWMP. An example illustrating the modeling results of applicable pollutant concentrations at the downstream outlet of the watershed system is included in Appendix K. The values provided correspond to the fecal coliform load reductions attributable to the BMP types at both the interim (2018) and final (2021) TMDL compliance deadlines. As shown, the TLRs were met in all analysis regions as a result of varying levels of implementation of non-structural and regional BMPs as described previously. The interim 50% TLR is met through a combination of nonstructural and existing regional BMPs. 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 subwatershed and within the same timeline, to meet an equivalent subwatershed load reduction, unless the TLRs or compliance schedules are modified. Because USEPA’s Santa Monica Bay DDT and PCBs TMDL effectively implements an anti-degradation approach to set MS4 WLAs to maintain and protect the receiving waters and meet water quality standards, the existing MS4 PCB and DDT loads from the Beach Cities EWMP Area are reasonably assumed to be in compliance with the applicable WLAs. Therefore, a target load reduction of zero has been set for PCBs and DDT. In spite of the zero required load reduction for PCBs and DDT in Santa Monica Bay for the Beach Cities EWMP Group, the BMPs proposed in this EWMP are expected to reduce sediment and sediment-associated pollutants such as DDTs and PCBs, so the non-quantified but greater-than-zero anticipated BMP load reductions for DDTs and PCBs will exceed the TMDL WLA. Therefore, compliance with the TMDL-based permit limits for DDTs and PCBs has been demonstrated through this narrative RAA evaluation.
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Table 2-17. Santa Monica Bay Watershed – Fecal Coliform RAA Results – Interim and Final Compliance
Analysis
Region
Implementation Benefits (average load reduction as % of baseline load for critical year)
TLR
Compliance
(TLR Met)?
Non-
Structural
BMPs (Non-
Modeled)
Public Retrofit
Incentives +
Redevelopment
Non-
MS4
Regional
BMPs
Distributed
BMPs
Distributed
BMP
Implementation
Level
Estimated
Load
Reduction SMB-5-01 5% 2% 0% 0% 0% N/A 7% 0% Yes SMB-O-06 5% 2% 0% 0% 0% N/A 7% 0% Yes SMB-5-02 5% 4% 2% 36% 3% 5% MFR/COM/SFR 50% 46% Yes SMB-5-02/5-03 5% 3% 0% 0% 0% N/A 8% 0% Yes SMB-5-03 5% 3% 0% 0% 0% N/A 8% 0% Yes SMB-5-03/5-04 5% 4% 0% 5% 0% N/A 15% 0% Yes SMB-5-04 5% 5% 0% 1% 1%2 N/A 12% 0% Yes SMB-5-04/5-05 5% 4% 0% 2% 0% N/A 11% 0% Yes SMB-5-05 5% 4% 5% 3% 0% N/A 18% 0% Yes SMB-5-05/6-01 5% 3% 0% 2% 0% N/A 10% 0% Yes SMB-6-01+ BCSump1 5% 3% 3% 33% 2% 25% MFR/COM/SFR 46% 45% Yes SMB-6-01/6-02 5% 2% 4% 0% 0% N/A 11% 0% Yes SMB-6-02 5% 3% 1% 4% 0% N/A 13% 0% Yes SMB-6-03 5% 3% 5% 10% 0% N/A 23% 0% Yes SMB-6-04 5% 4% 3% 0% 0% N/A 12% 0% Yes SMB-6-05 5% 3% 6% 0% 0% N/A 15% 0% Yes SMB-O-08 5% 2% 0% 0% 0% N/A 7% 0% Yes SMB-6-06 5% 5% 0% 0% 0% N/A 10% 0% Yes
Final Compliance
Deadline (2021) 5% 3% 3% 21% 1% N/A 33% 26% Yes
Interim
Compliance
Deadline (2018)3
2.5% 0.8% 1.5% 9.6% 0% N/A 14.4% 13% Yes
1 “BCSump” was defined as a separate analysis region for modeling purposes. The baseline load for “BCSump” analysis region was combined with the baseline load of the “SMB-6-01” analysis region to equal the total baseline load contributing to the SMB-6-01 CML (“SMB-6-01+BCSump”). 2 D istributed green street BMP load reduction in SMB-5-04 is a result of the existing filter/infiltration boxes retrofitted on the east side of Hermosa Avenue in the City of Hermosa Beach. 3 The total interim load reduction is the sum of the load reductions calculated for each analysis region by 2018. The TLR is met through a combination of nonstructural and existing regional BMPs.
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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
Consistency with LARWQCB Guidance The approaches described above, including model selection, data inputs, critical condition selection (90th percentile year), calibration performance criteria, and output types were selected for consistency with the LARWQCB RAA Guidance Document (LARWQCB, 2014).
2.7.2 DRY WEATHER For dry weather bacteria compliance, a qualitative analysis was conducted to show compliance at each of the CMLs. Table 2-18 outlines the results of this analysis. Many CMLs have an effective diversion18 such that they are consistently operational, well maintained, and sized to effectively eliminate discharges to the surf zone during year-round dry weather days. For the remaining smaller outfalls a systematic screening conducted in 2002 demonstrated that there was no discharge to the wave wash during summer dry weather from these storm drains. Rescreening of outfalls will be conducted as part of the Non-Stormwater Screening and Monitoring in the Coordinated Integrated Monitoring Program and will include both summer dry weather and winter dry weather screening. For the CMLs in the SMB Watershed that have anti-degradation based allowed exceedance days for both winter-dry and summer-dry weather, reasonable assurance is assumed to be demonstrated through the basis that the TMDL established their allowed exceedance days based on historic conditions (i.e., no water quality improvements were necessary). If following dry weather outfall re-screening, dry weather reasonable assurance has not been demonstrated by the evaluation criteria shown in Table 2-18, the Beach Cities EWMP Group’s compliance approach is consistent with the Permit requirement to eliminate 100 percent of non-exempt dry weather MS4 discharges. The Group’s implementation approach for achieving this is to use a suite of non-structural source controls (e.g., water conservation incentives, enhanced illicit discharge detection and elimination [IDDE] efforts, and enhanced education/outreach and inspection/enforcement to prevent non-exempt sources of stormwater flow) and source investigations. By eliminating flows, this is equivalent to 100 percent load reduction for all pollutants, thereby demonstrating reasonable assurance of meeting all applicable TMDL limits and water quality objectives in the Permit 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. Since the dry weather compliance deadlines for the SMBBB TMDL have passed, this analysis is provided for informational purposes only, and is not intended to support or justify a new
18 The seven existing low flow diversions include Polliwog Park, SMB 5-2 (28th Street), SMB 5-3 (Manhattan Beach Boulevard), SMB 5-5 (south of Pier Avenue), SMB 6-1 (Herondo Street), SMB 6-3 (Sapphire Street), and SMB 6-5 (Avenue I).
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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 on-site 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
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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 MUN IND NAV REC1 REC2 HFS COMM WARM MAR WILD RARE MIGR SPWN SHELL WET3 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 𝐿𝐿𝐿𝐿𝐿𝐿𝐿𝐿𝐸𝐸�𝐿𝐿𝑚𝑚 𝑁𝑁𝐿𝐿�=
0.4111+107.204 −𝑝𝑝𝑝𝑝+58.41+10𝑝𝑝𝑝𝑝−7.204 (Equation 1)
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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, multi-family 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 pre-treatment 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 spreadsheet-based 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 log-normal 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
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6,000
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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 SBPAT 22
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
SBPAT 23
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 wet 25 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 coliforms 26.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 ac-ft/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 flow-through 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, high-capacity 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 DC-Torrance 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 non-structural 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 Non-
MS4 Regional
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 anti-degradation 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 DC-Torrance 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 level 28. 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 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 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 DC-Torrance 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 sub-surface 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 County-owned) 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
DC- MB/RB Distributed 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 DC-Torrance 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 rate 30. 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 Green
Streets
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/Demobilization $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 $3,000,00
0 $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 DC-
TORRANCE 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 A-2236(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 Life-
Cycle1 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-of-way, has established a minimum runoff capture design goal for such projects, and will also use the EWMP to identify opportunities for green street BMP retrofits in 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/WaterSMART/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 non-structural 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 self-reliance, 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 non-potable water purposes
• Surface water pollution prevention
• Increase non-potable water storage through installation of underground cisterns Parks, Coastal Commission • Terrestrial and marine habitat protection by reducing trash from entering the ocean and other terrestrial habitats
• Water pollution prevention
• Erosion reduction 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 tax-exempt 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 AB-850-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
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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.
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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 stormwater-related 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).
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Pollution prevention is an important component in stormwater management. Given that majority of the pollutants in stormwater runoff originate from vehicles, some local governments have used other non-property-related surcharges to provide funding for stormwater programs. For example, the Orange County Transportation Authority has used the County’s sales tax to provide some funding for a water quality improvement and environmental cleanup program. The San Mateo County has also added a surcharge on the vehicle license fee to provide funding for their stormwater pollution management program. It is also foreseeable that pollutant specific, such as a TMDL-related fee could be established to provide funding for TMDL compliance related programs in the future. In addition to fees that provide steady revenue, another possible revenue source would be to charge fines to property owners that violate discharge limits (volumetric- or TMDL-based). Fines are not considered as a stable financial income, however 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)
Property-
related fees and
assessments Flexible 1. All water-related and refuse collection services: strict cost-of-service requirements 2. All water-related and refuse collection services: property-owner protest hearing 3. Floods and stormwater: 50% of property owners or two-third popular vote
(rules from the earlier
proposition remain in
place)
Non-property-
related fees Flexible 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.
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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.
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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.
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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 infrastructure-
related 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
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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 (fire- inspection & enforcement) $135,000 a. Consultant $1,112 $ 900 Included Included $3,263 $900 N/A N/A
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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) $10,500,000 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
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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
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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.
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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. American Rivers, The Water Environment Federation, the American Society of Landscape Architects, and ECONorthwest, 2012. Banking on Green: A Look at How Green Infrastructure Can Save Municipalities Money and Provide Economic Benefits Community-wide. April. Beach Cities Watershed Management Group, 2014. Enhanced Watershed Management Program (EWMP) Work Plan for the Beach Cities Watershed Management Group. June. Brown, W., and Schueler, T., 1997. The Economics of Stormwater BMPs in the Mid-Atlantic Region: Final Report. Center for Watershed Protection, Silver Spring, Maryland. August. California Financing Coordinating Committee (CFCC), 2015. 2015 Funding Fairs Handbook. California Stormwater Quality Association (CASQA), 2015. Vision and Strategic Actions for Managing Stormwater in the 21st Century (Version 1). January. California Water Boards, 2015. STORMS Storm Water Strategy: Strategy to Optimize Resource Management of Storm Water. December 11. DRAFT. Carollo Engineers (Carollo), 2014. Broadway Neighborhood Greenway Project 100% Cost Estimate—General Conditions (DRAFT). Los Angeles, California. October. Center for Neighborhood Technology (CNT), 2010. The Value of Green Infrastructure. (http://www.cnt.org/repository/gi-values-guide.pdf) City of Malibu, 2012. Comment Letter – Bacteria TMDL Revisions for Santa Monica Bay Beaches. May 7. City of Palo Alto, 2015. Innovative Stormwater Measures Rebate Program. http://www.cityofpaloalto.org/gov/depts/pwd/stormwater/rebates/default.asp) City of Torrance, 2011. Stormwater Quality Master Plan. City of Torrance, 2014. Current Capital Improvement Projects: Stormwater Basin Enhancement Project, I-102. (http://www.torranceca.gov/15435.htm) County of Montgomery, 2015. RainScapes Rewards Rebate Program. Environmental Protection. County of Montgomery, MD. (http://www.montgomerycountymd.gov/DEP/water/rainscapes-rebates.html) CWE Corp., 2012. City of Torrance Stormwater Basin Enhancement Project Design Information Memorandum Amie, Henrietta, and Entradero Basins. September 10.
444
Beach Cities EWMP | Section 9 | References
9-3 | Page 2018
Dominguez Channel Watershed Management Area Group (DC WMG), 2015. Enhanced Watershed Management Program for the Dominguez Channel Watershed Management Area Group. June. 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. Federal Aviation Administration (FAA), 2015. Aviation Gasoline, about Aviation Gasoline. (http://www.faa.gov/about/initiatives/avgas/) Geosyntec Consultants, 2008. A User’s Guide for the Structural BMP Prioritization and Analysis Tool (SBPAT v1.0): Technical Appendices. December. Geosyntec Consultants, 2011a. Structural BMP Siting and Conceptual Design Study, Santa Monica Bay Beaches Bacteria TMDL Implementation. Produced for SMBBB TMDL Jurisdictional Groups 5 & 6. June. Geosyntec Consultants, 2011b. Dry Weather Source Characterization and Control Summary, Santa Monica Bay Beaches Bacteria TMDL Implementation. Produced for SMBBB TMDL Jurisdictional Groups 5 & 6. June. International Cost Engineering Council, 2014. (www.icoste.org) LADWP, 2015. Authorization to Establish a Joint Powers Authority for Water Financing. Los Angeles Department of Water and Power. [http://clkrep.lacity.org/onlinedocs/2015/15-0148_misc_02-05-2015.pdf] Los Angeles County Sanitation District (LACSD), 2009. Model Program for Bacterial Source Identification and Abatement Plan – Redondo Beach Pier Pilot Program. Final Report and Abatement Plan. December 1. Los Angeles Regional Water Quality Control Board (LARWQCB), 1995. Water Quality Control Plan (Basin Plan). June. LARWQCB, 2011. Dominguez Channel and Greater Los Angeles and Long Beach Harbor Waters Toxic Pollutants TMDL. May 5. LARWQCB, 2012a. Order No. R4-2012-0175 NPDES Permit No. CAS004001 Waste Discharge Requirements for Municipal Separate Storm Sewer System (MS4) Discharges within the Coastal Watersheds of Los Angeles County, except those Discharges Originating from the City of Long Beach MS4. November 8. LARWQCB, 2012b. Attachment A to Resolution No. R12-007, Proposed Amendment to the Water Quality Control Plan – Los Angeles Region to revise the Santa Monica Bay Beaches Bacteria TMDL. June 7. LARWQCB, 2014. Guidelines for conducting reasonable assurance analysis in a watershed management program, including an enhanced watershed management program. March 25.
445
Beach Cities EWMP | Section 9 | References
9-4 | Page 2018
LARWQCB, 2015. Approval, With Conditions, of The Beach Cities Watershed Management Group’s Coordinated Integrated Monitoring Program, Pursuant to Attachment E, Part IV.B of The Los Angeles County Municipal Separate Storm Sewer System (MS4) Permit (NPDES Permit No. CAS004001; Order No. R4-2012-0175). August 25. LARWQCB, 2015c. Final Approved Beach Cities Watershed Management Group’s Coordinated Integrated Monitoring Program, Pursuant to Attachment E, Part IV.B of The Los Angeles County Municipal Separate Storm Sewer System (MS4) Permit (NPDES Permit No. CAS004001; Order No. R4-2012-0175). November 12. New Model Colony Builders, LLC (NMC Builders), 2008. New Model Colony Storm Water Quality Treatment Alternatives (DRAFT). Chino, California. September. Public Policy Institute of California (PICC), 2014. Paying for Water in California. RSMeansOnline, v. 6.0.0. 2015. The Gordian Group. (http://www.rsmeansonline.com/) Southern California Coastal Water Research Project (SCCWRP), 2007. Technical Report 510 Sources, Patterns, and Mechanisms of Storm Water Pollutant Loading from Watersheds and Land Uses of the Greater Los Angeles Area, California, USA. Written by E.D. Stein, L.L. Tiefenthaler, and K.C. Schiff. March 2007. San Francisco Public Utilities Commission (SFPUC), 2015. San Francisco’s Non-potable Water Program. A Guidebook for Implementing Onsite Water Systems in the City and County of San Francisco. City and County of San Francisco, CA. Seattle Public Utilities (SPU), 2015. RainWise Rebates for Cisterns and Rain Gardens. WA. (http://www.seattle.gov/util/environmentconservation/projects/drainagesystem/greenstormwaterinfrastructure/rainwise/rebates/) State Water Resources Control Board (SWRCB), 2004. Water Quality Control Policy for Developing California’s Clean Water Act Section 303(d) List. September. SWRCB, 2012. Water Quality Control Plan for Ocean Waters in California, California Ocean Plan (Ocean Plan). Adopted October 16, 2012. Stein, E.D., Tiefenthaler, L.L., and Schiff, K.C., 2007. “Sources, Patterns and Mechanisms of Storm Water Pollutant Loading From Watersheds and Land Uses of the Greater Los Angeles Area, California, USA.” Southern California Research Project (SCCWRP), Technical Report 510, March. TDC Environmental, 2013. Estimate of Urban Runoff Copper Reduction in Los Angeles County from the Brake Pad Copper Reductions Mandated by SB 346. February. Thoe, W., Gold, M., Griesbach, A., Grimmer, M., Taggart, M.L., and A.B. Boehm, 2014. Sunny with a Chance of Gastroenteritis: Predicting Swimmer Risk at California Beaches. Environmental Science and Technology. 49(1), pp 423-431.
446
Beach Cities EWMP | Section 9 | References
9-5 | Page 2018
United States Environmental Protection Agency (USEPA), 2005. National Management Measures to Control Nonpoint Source Pollution from Urban Areas. EPA-841-B-05-004, U.S. Environmental Protection Agency, Washington, D.C. USEPA, 2012. Santa Monica Bay Total Maximum Daily Loads for DDTs and PCBs. USEPA, 2013a, 2013. “Aquatic life ambient water quality criteria for ammonia – freshwater.” EPA 822-R-12-001. USEPA, 2013b. The Importance of Operation and Maintenance for the Long-Term Success of Green Infrastructure. A Review of Green Infrastructure O&M Practices in ARRA Clean Water State Revolving Fund Projects. Office of Water. United State Environmental Protection Agency. PA-832-R-12-007. 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.
447
Beach Cities Watershed
Management Group
Revised Enhanced
Watershed
Management
Program
JUNE 2021
Presented to the Los Angeles Regional
Water Quality Control Board 448
Beach Cities
Watershed
Management
Group
AGENCY CONTACTS
City of Hermosa Beach
1315 Valley Drive
Hermosa Beach, CA 90254
Douglas Krauss
(310) 750-3603
City of Manhattan Beach
3621 Bell Avenue
Manhattan Beach, CA 90266
Lourdes Vargas
(310) 802-5320
Los Angeles County Flood
Control District
900 S. Fremont Avenue
Alhambra, CA 91803
Yao Kouwonou
(626) 458-4329
Document and analysis
prepared by Geosyntec
Consultants
City of Torrance
20500 Madrona Avenue
Torrance, CA 90503
John Dettle
(310) 618-3059
City of Redondo Beach
415 Diamond Street
Redondo Beach, CA 90277
Geraldine Trivedi
(310) 318-0661
449
DRAFT
Revised Beach Cities Enhanced Watershed
Management Program (EWMP)
Update 2021
Prepared for
The Los Angeles Regional Water Quality Control Board
Prepared by
Beach Cities Watershed Management Group
(Cities of Hermosa Beach, Manhattan Beach, Redondo Beach, and Torrance
and the Los Angeles County Flood Control District)
DRAFT May 17, 2021
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TABLE OF CONTENTS
1 Introduction and Background 4
1.1 Revised EWMP Updates 4
1.2 Beach Cities EWMP Area 6
1.3 EWMP Organization 8
2 EWMP Approach 8
2.1 Selection of Appropriate Best Management Practices 9
2.1.1 Minimum Control Measures 10
2.1.2 Non-Stormwater Discharge Measures 10
2.1.3 Additional BMPs 10
2.2 BMP Selection and Prioritization 11
2.3 Legal Authority 11
3 Santa Monica Bay Watershed Management Area 11
3.1 Identification of Water Quality Priorities 11
3.2 RAA Results – Baseline Loads and Target Load Reductions 12
3.3 BMP Summary 15
3.3.1 Redevelopment 15
3.3.2 Analysis Region SMB-5-2 15
3.3.3 Analysis Region SMB-6-1 18
3.4 RAA Results – Load Reductions and Compliance Demonstration 23
3.5 RAA Results - Dry Weather Compliance Demonstration. 27
4 Dominguez Channel Watershed Management Area 27
4.1 Identification of Water Quality Priorities 27
4.2 RAA Results – Baseline Loads and Target Load Reductions 28
4.3 BMP Summary 31
4.3.1 Redevelopment 31
4.3.2 Copper Brake Pad Reduction 31
4.3.3 Analysis Region DC-N-MB & DC-N-RB 31
4.3.4 Analysis Region DC-S 36
4.3.5 Analysis Region DC-TL 37
4.4 RAA Results – Load Reductions and Compliance Demonstration 37
4.5 RAA Results – Dry Weather Compliance Demonstration 42
5 Cost Estimate 42
5.1 BMP Cost Methodology and Assumptions 43
5.1.1 Hard Cost Assumptions 43
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5.1.2 Soft Cost Assumptions 43
5.1.3 Operations and Maintenance 44
5.1.4 Additional Design Assumptions 45
5.2 Summary of Cost Estimates 45
6 Assessment and Adaptive Management Framework 46
7 Compliance Schedule 48
7.1 Santa Monica Bay WMA 48
7.2 Dominguez Channel WMA 49
8 References 50
LIST OF ATTACHMENTS
A. History and Regulatory Background
B. Water Quality Prioritization and Source Assessment
C. Minimum Control Measure Customization and Summary
D. RAA Report
E. Project Concept Fact Sheets
F. Background Information on the LACFCD
G. Potential Funding Sources and Financial Strategy
H. Community Involvement for EWMP Implementation
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1 INTRODUCTION AND BACKGROUND
Following adoption of the 2012 Los Angeles Municipal Separate Storm Sewer System (MS4) National
Pollutant Discharge Elimination System (NPDES) Permit (Permit),1 the Cities of Hermosa Beach,
Manhattan Beach, Redondo Beach and Torrance, together with the Los Angeles County Flood Control
District (LACFCD), collectively referred to as the Beach Cities Watershed Management Group (Beach
Cities WMG) agreed to collaborate on the development of an Enhanced Watershed Management Program
(EWMP) for the Santa Monica Bay (SMB) and Dominguez Channel areas within their jurisdictions
(referred to herein as the Beach Cities EWMP Area).
On June 26, 2015, in accordance with the Permit, the Beach Cities WMG submitted a draft EWMP to the
Los Angeles Regional Water Quality Control Board (LARWQCB). Following public review and
comment, as well as multiple reviews by LARWQCB, the Beach Cities WMG submitted a second revised
EWMP on February 9, 2016. On April 18, 2016 the Beach Cities’ second revised EWMP was approved
by LARWQCB.
Based on the Permit-specified adaptive management process, as well as other relevant changes within the
Beach Cities Area, multiple updates to the Beach Cities EWMP have occurred since its original approval
in April 2016: one in March 2018, and a second in August 2019.
In addition to regularly adapting the EWMP, Permittees are required to submit an updated EWMP with an
updated Reasonable Assurance Analysis (RAA) by June 30, 2021 for review and approval by the
Regional Water Board Executive Officer. The updated RAA is required to incorporate both water quality
data and control measure performance data, and any other information informing the adaptive
management process, gathered through December 31, 2020.
The latest version of the Beach Cities EWMP (June 2021) has been drafted to meet these requirements,
along with applicable requirements of State Order WQ 2020-0038, issued by the State Water Resources
Control Board (State Board) on November 17, 2020 (SWRCB, 2020).
Additional information related to the history of the Beach Cities EWMP development and the regulatory
background upon which it is built can be found in Appendix A.
1.1 Revised EWMP Updates
This revised Beach Cities EWMP has been developed to build upon and improve the original Beach
Cities EWMP. Since the Beach Cities EWMP was first approved in 2016, significant advancements have
been made in the state-of-the-practice of stormwater project planning and RAA modeling. Additionally,
the Group has gained invaluable experience and insight with respect to implementation of the EWMP,
1 Order No. R4-2012-0175 NPDES Permit No. CAS004001 Waste Discharge Requirements for Municipal Separate
Storm Sewer System (MS4) Discharges within the Coastal Watersheds of Los Angeles County, except those
Discharges Originating from the City of Long Beach MS4.
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understanding more about both the opportunities and challenges they face in successfully implementing
effective stormwater projects.
In particular, the revised Beach Cities EWMP has been updated in the following critical ways:
• Incorporation of newly available, EWMP-specific data. The Beach Cities WMG has been
successfully implementing their Coordinated Integrated Monitoring Program (CIMP) since 2015,
resulting in five years of outfall and receiving water monitoring data from the EWMP Area.
Coupled with the long-term Santa Monica Bay Beaches Bacteria (SMBBB) Coordinated
Shoreline Monitoring data that has been collected consistently since 2005, the Beach Cities
WMG has updated their EWMP to incorporate applicable data. Water quality priorities have
been re-evaluated (see Appendix B) based on updated receiving water compliance assessments,
as well as paired outfall data that allows for a more-definitive determination of whether MS4
outfalls are causing or contributing to receiving water exceedances.
• Utilization of the recently updated, County-wide RAA modeling tool. While the original
RAA leveraged the strengths of the Structural BMP Prioritization and Analysis Tool (SBPAT) to
perform the wet weather modeling analysis, the revised RAA uses the newly released WMMS 2
modeling platform to maintain consistency with the majority of RAAs across Los Angeles
County. Developed by LACFCD and publicly released in May 2020, WMMS 2 utilizes remote
sensing, water quality, and hydrology data collected through 2018 to simulate contaminant
loading, runoff volume, and flow rate. WMMS 2 contains two major components: a Loading
Simulation Program in C++ (LSPC) to determine hydrology and pollutant loading; and a System
for Urban Stormwater Treatment and Analysis Integration (SUSTAIN) to assist in BMP
selection and performance. An advantage of using the WMMS 2 model is the extensive regional
calibration effort that has gone into this recent update of the model. Further details of the RAA
modeling can be found in Appendix D.
• Thorough calibration of the RAA model. Although WMMS 2 has been calibrated on a
regional basis, the default WMMS 2 model was further calibrated and validated using Beach
Cities CIMP monitoring data collected through June 30, 2020 to best reflect the baseline
hydrology and water quality conditions within the Beach Cities EWMP Area. Further details of
the RAA calibration process can be found in Appendix D.
• A focus on new multi-benefit regional projects. Although distributed BMPs are necessary and
beneficial for watershed planning, regional projects are generally more preferable, as they
provide multiple benefits, are more cost-effective, and have a higher likelihood of receiving
outside funding. Removing projects and programs that were no longer feasible, the Beach Cities
WMG is committed to adding new regional, multi-benefit projects, including regional green
streets, that seek to enhance water quality, maximize community benefits, and amplify other
environmental objectives.
Incorporating these changes, the revised Beach Cities EWMP more accurately reflects the actual water
quality and flow conditions in the EWMP Area; provides updated, measurable milestones that can be
tracked over time; and identifies implementable, cost-effective solutions to achieve compliance.
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1.2 Beach Cities EWMP Area
This EWMP is applicable to the Beach Cities Watershed Management Area (WMA), which consists of all
of the incorporated MS4 areas of the cities of Redondo Beach, Manhattan Beach, Hermosa Beach and
Torrance (excluding the Machado Lake Watershed) and includes the infrastructure of the LACFCD
within those jurisdictions (Figure 1).2 This area includes portions of two distinct HUC-12 watersheds,3
Santa Monica Bay Watershed and Dominguez Channel Watershed, as summarized in Table 1.
The Machado Lake Watershed, which is addressed by the separate Machado Lake Watershed EWMP
developed by City of Torrance, is not part of the Beach Cities WMA or Beach Cities EWMP.
As shown in Figure 1, the Beach Cities WMA is divided into two geographic areas, the Santa Monica
Bay (SMB) Watershed and Dominguez Channel (DC) Watershed. The western portion of the Beach
Cities WMA consists of approximately 7,800 acres of land that drains to SMB (Table 1). This accounts
for 53% of the total Beach Cities WMA, and includes portions of the cities of Manhattan Beach, Redondo
Beach, and Torrance, and the entirety of the City of Hermosa Beach. This portion of the study area
hereinafter is referred to as the SMB WMA.4
The eastern portion of the Beach Cities WMA is tributary to Dominguez Channel5 (including Torrance
Carson Channel 6 ) and is comprised of approximately 7,024 acres of land (Table 1). This watershed
accounts for 47% of the total Beach Cities WMA, 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 WMA.
2 The 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 F.
3 A HUC-12 watershed is defined by a 12-digit hydrologic unit code (HUC) delineation, which identifies the
watershed area based on six levels of classification: regional, sub-region, hydrologic basin, hydrologic sub-basin,
watershed, and subwatershed.
4 The Wylie Basin is a retention basin within the SMB WMA with no outlet that is sized to handle events
significantly larger than the 85th percentile, 24-hr storm event. Therefore, its drainage area has been excluded from
the EWMP RAA.
5 Other portions of the Dominguez Channel Watershed, including Los Angeles County Unincorporated areas, are
addressed by separate EWMP groups.
6 Also known as the Torrance Lateral.
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Figure 1. Beach Cities EWMP Area Overview
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Table 1. Beach Cities Watershed Management Area Summary
Participating Agency
Area (acres)
Santa Monica Bay
WMA
Dominguez Channel
WMA
Total Beach Cities
WMA
City of Redondo Beach 2,592 1,252 3,844
City of Manhattan Beach 2,089 363 2,452
City of Hermosa Beach 846 - 846
City of Torrance 2,274 5,409 7,683
Total 7,801 7,024 14,825
1.3 EWMP Organization
This Beach Cities EWMP addresses the Permit-required watershed management program elements for
both the SMB and Dominguez Channel WMAs. Because the SMB and Dominguez Channel WMAs have
their own unique water quality conditions, their technical evaluations were performed independently and
are documented in separate sections in this EWMP. This includes the water quality prioritization, RAA,
and BMP identification. Section 2 provides general information on the EWMP approach that is applicable
to both WMAs. Section 3 summarizes the technical aspects of the EWMP specific to Santa Monica Bay
WMA while Section 4 covers the same technical elements for Dominguez Channel WMA. Section 5
provides the cost opinions associated with EWMP project implementation. In Section 6, an overview of
the adaptive management framework the WMG utilizes to actively manage their EWMP is provided.
Building on all of this, Section 7 provides a compliance schedule for the Beach Cities WMG. Lastly,
Section 8 includes the references cited in the EWMP.
A large quantity of information in the revised Beach Cities EWMP has been moved to the appendices.
This includes a significant amount of detailed background information, such as regulatory framework,
water quality prioritization, minimum control measure customization, RAA details, financial strategy, and
more. The goal of this approach is to simplify and streamline the information presented within the main
body of the EWMP, while still providing the technical details and thoroughness required by such a
significant regulatory plan. The hope is that all users, including the permittees, regulators, residents, non-
governmental organizations, and other stakeholders will find the revised Beach Cities EWMP to be more
user-friendly.
2 EWMP APPROACH
The EWMP is a planning document intended to lay out a framework of activities that will comply with
water quality requirements. Therefore, it is necessary to demonstrate that selected BMPs are reasonably
expected to meet defined goals and objectives. This demonstration of performance is described through a
technically robust and rigorous RAA. Through this analysis, the Beach Cities WMG identified and
evaluated BMP implementation scenarios within the Beach Cities EWMP Area for each Waterbody
Pollutant Combination (WBPC) identified.
The EWMP approach, including model selection, data inputs, critical condition selection, calibration
performance criteria, and output types is consistent with the LARWQCB Reasonable Assurance Analysis
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Guidance Document (LARWQCB, 2014) and also leverages previous efforts where relevant models have
already been developed. The individual water quality targets, BMPs, RAAs, schedules, and costs for each
of the watersheds are summarized in watershed-specific sections that follow.
Details of the RAA, including model selection, calibration, and execution can be found in Appendix D.
2.1 Selection of Appropriate Best Management Practices
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.
The Permit defines BMPs as “practices or physical devices or systems designed to prevent or reduce
pollutant loading from stormwater or non-stormwater discharges to receiving waters.”
Structural BMPs involve the construction of a physical control measure to alter the hydrology or water
quality of incoming stormwater or non-stormwater. There are two categories of structural BMPs, defined
by the runoff area treated by the BMP: regional BMPs 7 and distributed BMPs. Regional BMPs are
designed to treat runoff from a large drainage area expected to include multiple parcels and various land
uses. These may include infiltration basins, treatment plants, and subsurface flow wetlands, among others.
Distributed BMPs are designed to treat runoff from smaller drainage areas and are normally installed to
collect runoff close to the source from a limited number of parcels. Distributed BMPs typically include
drywells, swales, bioretention facilities, biofiltration facilities, and cisterns, among others.
Non-structural BMPs prevent or reduce the release of pollutants or transport of pollutants within the MS4
drainage area but do not involve construction of physical facilities. Non-structural BMPs are often
implemented as programs or strategies which seek to reduce runoff and/or pollution close to the source.
Examples include but are not limited to: street sweeping, downspout disconnect programs, pet waste
cleanup stations, irrigation ordinances, or illicit discharge elimination. Minimum control measures
7 The term “regional BMP” does not necessarily indicate that the project can capture and retain the 85th percentile
storm, as described in the Permit. The term “regional EWMP project” is therefore used for those regional BMPs that
are expected to be able to capture and retain the 85th percentile storm.
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(MCMs) as set forth in the Permit are a subset of non-structural BMPs even though some MCMs include
measures that require the implementation of structural BMPs by both public and private parties.
In accordance with the Permit, the following types of BMPs were considered in the development of the
Beach Cities EWMP.
2.1.1 Minimum Control Measures
The Beach Cities WMG has assessed the MCMs defined in the Permit to identify opportunities for
focusing resources on the high priority issues in each watershed. The Permit requires the permittees to
implement prescribed MCMs in each of six categories/programs: Public Information & Participation
Program (PIPP), Industrial/Commercial Facilities, Planning & Land Development, Development
Construction, Public Agency Activities, and Illicit Connection & Illicit Discharges Elimination. These
measures include procedures such as outreach programs, inspections, and reporting requirements
designed to reduce runoff-related pollution within each permittees’ MS4 area. MCMs in each of these
categories have been effectively implemented by the Beach Cities WMG for years. In some cases, MCM
program enhancements have been implemented to address watershed priorities for TMDL
implementation. Details on the selected MCMs, including proposed modifications to any programs, are
provided in Appendix C.
2.1.2 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 the SMB Watershed, eight low flow diversions have been implemented successfully along the coast to
effectively divert significant non-stormwater discharges and prevent them from reaching the ocean.
Additionally, due in part to setbacks for smaller outfalls, non-stormwater discharges to the ocean are
known to be non-existent. The effectiveness of these measures is consistently confirmed by observations
made during weekly and daily shoreline monitoring.
Since initiation of the Permit, the Beach Cities WMG has attempted to eliminate non-exempt dry weather
MS4 discharges using a suite of structural BMPs and non-structural source controls (e.g., water
conservation incentives, enhanced IDDE efforts, enhanced education/outreach, and inspection/
enforcement to prevent sources of non-stormwater flow). To-date, monitoring has shown that the WMG
has been successful at this endeavor, and although dry weather flows do still exist in some outfalls
draining to Dominguez Channel, particularly within Torrance Carson Channel, the Group has successfully
demonstrated that these discharges are considered conditionally exempt.
2.1.3 Additional BMPs
In addition to the MCMs and non-stormwater discharge measures, the Beach Cities WMG considered
numerous additional BMPs to achieve compliance with Permit-specified WQBELs and/or RWLs. Some
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of these BMPs have already been implemented, while others have been identified as part of the revised
EWMP process.
2.2 BMP Selection and Prioritization
In order to demonstrate reasonable assurance of achieving water quality priorities, BMP opportunities
were identified and evaluated in a prioritized manner. Prioritization was based on 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); implementation feasibility as determined by
the Beach Cities WMG; and cost (low cost BMPs were prioritized first).
The RAA process was then carried out in an iterative manner to demonstrate that implementation of the
selected BMPs will result in the attainment of applicable Permit-specified WQBELs, and will also
prevent discharges from causing or contributing to exceedances of applicable RWLs.
Details on how each BMP was accounted for in the RAA can be found in Appendix D. A summary of
existing and proposed BMPs within each watershed can be found in the respective watershed section of
the EWMP.
2.3 Legal Authority
The Beach Cities WMG Permittees have the necessary legal authority to implement the BMPs identified
in the EWMP. Table 2 includes the water quality ordinance for each agency with a reference link.
Table 2. Beach Cities Water Quality Ordinances
City Water Quality Ordinance
Hermosa Beach Chapter 8.44 - Stormwater and Urban Runoff Pollution Control Regulations
Manhattan Beach Chapter 5.84 – Storm Water and Urban Runoff Pollution Control
Redondo Beach Title 5 Chapter 7 - Stormwater Management and Discharge Control
Torrance Division 4 Chapter 10 – Stormwater and Urban Runoff Pollution Control
LACFCD Flood Control District Code, Chapter 21 - Stormwater and Runoff Pollution Control
3 SANTA MONICA BAY WATERSHED MANAGEMENT AREA
3.1 Identification of Water Quality Priorities
As part of the EWMP process, the Permit requires the Beach Cities WMG to identify water quality
priorities within their WMA. The list of water body pollutant combinations (WBPCs) defined in the
original Beach Cities EWMP has been revised based on the most recent updates to applicable TMDLs and
303(d) listings, as well as CIMP monitoring data collected through June 2020. The updated WBPC list for
SMB is summarized in Table 3.
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Table 3. Water Body Pollutant Combinations – Santa Monica Bay
Category Water Body Pollutant – Applicable
Condition Reason for Categorization
1: Highest
Priority Santa Monica Bay
(including SMB
Beaches)
Bacteria – Wet and Dry Weather SMB Beaches Bacteria TMDL
(LARWQCB, 2012b)
Trash/Debris – Wet and Dry
Weather
SMB Debris TMDL (LARWQCB,
2010)
DDTs – Wet and Dry Weather SMB PCBs and DDT TMDL (USEPA,
2012) PCBs – Wet and Dry Weather
2: High
Priority
Mercury– Wet and Dry Weather 2014-2016 303(d) list Arsenic– Wet and Dry Weather
Details related to the identification, prioritization, and potential sources of each of the SMB WBPCs can
be found in Appendix B. Unless otherwise noted, all WBPCs identified in Table 2 have been addressed as
part of the revised RAA.
3.2 RAA Results – Baseline Loads and Target Load Reductions
Consistent with the original Beach Cities EWMP RAA, baseline and target load reduction analyses were
performed for each analysis region in the Santa Monica Bay WMA. Figure 2 illustrates these analysis
regions. Appendix D provides details on how the analysis regions were determined.
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Figure 2. Santa Monica Bay Analysis Region Overview
The process for establishing pollutant target load reductions (TLRs) necessary to meet water quality
objectives for the SMB WBPCs is detailed in Appendix D. Based on monitoring data collected
throughout the SMB WMA as part of the Beach Cities CIMP efforts, fecal indicator bacteria (i.e., fecal
coliform) is the only WBPC for which a TLR was estimated; all other WBPCs have TLRs of zero.
Appendix A provides more information on the selection and modeling of WBPCs.
A summary of estimated baseline loads and TLRs for fecal coliform in each analysis region in the SMB
WMA is provided in Table 4. For non-zero TLRs, an equivalent 24-hour runoff management volume was
estimated as the maximum daily diverted volume needed to achieve the TLR during the critical condition
(i.e., throughout the modeled year). Both load-based TLR and the equivalent 24-hour runoff management
volume are considered eligible Beach Cities EWMP compliance metrics. Appendix D provides detailed
information on the process to calculate TLRs and 24-hour management volumes.
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Table 4. Wet Weather Fecal Coliform TLRs for Santa Monica Bay WMA
Analysis
Region
Critical
Condition
Baseline Load
(1012 MPN/ year)
Final Target Load Reduction
Absolute TLR
(1012 MPN/ year)
% of
Baseline
Load
TLR Equivalent
24-Hour
Management
Volume (ac-ft)
SMB-5-01
90th
percentile
water year
1.7 Anti-Degradation 0% 0
SMB-5-02 111.9 59.0 53% 67.1
SMB-5-03 7.5 Anti-Degradation 0% 0
SMB-5-04 2.6 Anti-Degradation 0% 0
SMB-5-05 39.0 Anti-Degradation 0% 0
SMB-6-01 112.1 54.7 49% 51.2
SMB-6-02 16.2 Anti-Degradation 0% 0
SMB-6-03 10.0 CIMP data shows compliance with final allowable
exceedance days. No RAA required to demonstrate
compliance. SMB-6-04 4.1
SMB-6-05 15.3 Anti-Degradation 0% 0
SMB-6-06 1.2 Anti-Degradation 0% 0
For analysis regions with SMBBB TMDL compliance monitoring locations (CMLs) that have anti-
degradation-based allowable exceedance days for wet weather, a target load reduction of zero was
assumed, consistent with the TMDL’s approach that acknowledges that historic bacteria exceedance rates
for each of these analysis regions are lower than that of the reference beach, on average. This assumption
applies for seven of the 11 total SMBBB TMDL CMLs in Beach Cities SMB WMA – i.e., SMB-5-1,
SMB-5-3, SMB-5-4, SMB-5-5, SMB-6-2, SMB-6-5, and SMB-6-6. Historic wet weather monitoring data
at these sampling locations through TMDL Year 2019 confirm this understanding, as the long-term
exceedance rate at all seven sites varies between 7 and 24%, below the long-term wet weather exceedance
rate at the reference beach (26%).
Consistent with the original Beach Cities EWMP, a zero percent TLR was calculated in the analysis
region draining to SMB-6-3. Based on all SMBBB monitoring data collected at this CML through TMDL
Year 2019,8 the wet weather exceedance rate (21%) remained lower than the average wet weather
exceedance rate at the reference watershed (26%). Additionally, over the past ten years, this site only had
one year (TMDL Year 2017) that exhibited more measured wet weather exceedance days (4) than the
allowable exceedance days (3). This year had more rainfall and wet days than TMDL Year 2011, which is
the 90th percentile year.
Similarly, a zero percent TLR was also calculated in the analysis region draining to CML SMB-6-4.
Based on all SMBBB monitoring data collected at this CML through TMDL Year 2019, the wet weather
exceedance rate (20%) remained lower than the average wet weather exceedance rate at the reference
watershed (26%). Additionally, over the past ten years, this site only had one year (TMDL Year 2011)
8 TMDL Year 2019 is defined as November 1, 2018 through October 31, 2019. As of the drafting of the revised
EWMP, this was the latest TMDL Year for which a complete data set was available.
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that exhibited more measured wet weather exceedance days (5) than the allowable exceedance days (3).
This year was the 90th percentile year. Further, SMB-6-4 is an open beach CML with no major MS4
outfall at the sampling location.
3.3 BMP Summary
As discussed in Section 2 and Appendix D, BMPs were identified and accounted for in the RAA to
demonstrate attainment of applicable water quality targets. Because the RAA was calibrated using local
water quality and flow data through June 2020, only BMPs implemented or planned to be implemented
after this date were modeled in the RAA. A summary of these BMPs, including modeled programmatic
(i.e., redevelopment) and structural measures, are provided herein.
3.3.1 Redevelopment
The original Beach Cities EWMP assumed land-use specific redevelopment rates based on both literature
and local records. Since this time, the Beach Cities WMG has completed five years of implementation
and has quantified redevelopment projects triggering low impact development (LID) requirements each
year in the annual watershed report. Over the course of this five-year period, the WMG observed a total
annual redevelopment rate of 0.08% for applicable land uses (residential, commercial, industrial,
education, and transportation). Of the implemented LID projects, 95.6% implemented bioretention,
infiltration, or otherwise full capture of the 85th percentile, 24-hour design storm, in accordance with local
LID ordinances. The remaining 4.4% of projects used flow-through treatment BMPs to treat a volume
equivalent to 1.5 times the 85th percentile, 24-hour design storm.
LID was assumed to be implemented at a rate of 0.08% for all applicable land uses, assuming
implementation from July 2020 until the end of the compliance schedule. All LID BMPs constructed
through June 2020 were assumed to be accounted for in the model via the calibration process.
An example of a LID redevelopment project in the SMB WMA is the Beach Cities Health District
redevelopment project. The redevelopment project will include sufficient stormwater retention BMPs to
fully capture and retain the 85th percentile, 24-hour design storm from a total of 10.5 acres of on-site
drainage. Projects such as these will further increase the stormwater runoff managed within the SMB
WMA.
3.3.2 Analysis Region SMB-5-2
Analysis Region SMB-5-2, which discharges at 28th Street in Manhattan Beach, is one of two priority
watersheds for the Beach Cities in the SMB WMA. In addition to existing projects and LID
implementation, a single, large-scale regional project near the watershed outfall has been identified for
implementation, along with a green street project that is currently in design.
3.3.2.1 28th Street Storm Drain Infiltration Project
The City of Manhattan Beach is implementing the 28th Street Storm Drain Infiltration Project to capture
stormwater flows within the 28th Street storm drain system. The project will capture and infiltrate runoff
from approximately 1,520 acres and includes two phases.
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• Phase 1 project concept includes 48 infiltration drywells at the 26th Street Parking Facility, which
is opportunely located downstream in the 28th Street storm drain system, 200 feet from the beach
and outfall. A diversion structure installed in the 28th Street storm drain will direct flows through
a pretreatment unit and into drywells for infiltration under the parking facility. Additional
improvements at the parking facility will include permeable pavement and trees for surface
greening.
• Phase 2 project concept includes an infiltration trench along the beach at 28th Street and will only
be constructed if additional pollutant load reduction is needed following performance evaluation
of Phase 1.
According to RAA modeling, the project is estimated to provide 81.9 acre-feet of 24-hour management
volume capacity during the critical condition (90th percentile wet year). The project is currently in the
design stage and has submitted a Safe Clean Water Regional Infrastructure application for design and
construction funding (Manhattan Beach, 2020). An overview plan of the project is provided in Figure 3,
and a concept factsheet of the project is provided in Appendix E.
Figure 3. Project Overview – 28th Street Storm Drain Infiltration Project
3.3.2.2 Beach Cities Green Streets 1 (Manhattan Beach 19th Street)
Following project identification in the original Beach Cities EWMP, the WMG initiated design of green
infrastructure elements in a targeted neighborhood in the SMB-5-2 watershed. Green street elements will
be installed along 19th Street between Sepulveda Boulevard and Pine Avenue in the City of Manhattan
Beach to address a 31-acre tributary area consisting of single-family residential and commercial land uses.
The project is currently in design with the design objective of achieving full capture of the 85th percentile,
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24-hr design storm from the tributary area. A map showing the project drainage area is provided in Figure
4.
Figure 4. Project Overview – Beach Cities Green Streets Project in SMB-5-2
Since the project is designed to fully capture the 85th percentile, 24-hour design storm from the tributary
area, the entire tributary area has been removed from the RAA model.
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3.3.3 Analysis Region SMB-6-1
Analysis Region SMB-6-1, which discharges to the beach via a storm drain that runs along Herondo
Avenue on the border of Hermosa Beach and Redondo Beach, is the second of two priority watersheds for
the Beach Cities in the SMB Watershed. In addition to LID implementation, a selection of green street
projects are currently in design; Torrance is enhancing and expanding three existing stormwater detention
basins to fully capture the 85th percentile, 24-hour storm event from their combined tributary area; and
three additional projects have been identified for implementation.
3.3.3.1 Beach Cities Green Streets Project
Following project identification in the original Beach Cities EWMP, the WMG has initiated design of
distributed green infrastructure elements in six distinct areas of the SMB-6-1 watershed. In total, the
Beach Cities Joint Green Streets Project will capture, treat, and/or infiltrate runoff from approximately
167 acres, including tributary areas from all four Beach Cities member cities. The project is intended to
be a multi-benefit project that will address multiple WBPCs, including trash, bacteria, and more. It will
also include neighborhood greening elements, where feasible. Locations and approximate drainage areas
of the Green Streets project sites in the SMB-6-1 analysis region are shown in Figure 5, with brief
descriptions of each provided below:
• Beach Cities Green Streets 2 (Manhattan Beach Artesia Blvd): The proposed green street project
will be located along the northern side of Artesia Blvd between S. Herrin Street and S. Redondo
Avenue. The project area consists of high-density residential land use totaling 7 acres.
• Beach Cities Green Streets 3 (Redondo Beach Anita Street): The proposed green street project
will be constructed in residential areas along Anita Street, between Flagler Lane and N. Lucia
Avenue and compose approximately 16 acres of drainage area.
• Beach Cities Green Streets 4 (Redondo Beach Ford Avenue): The project will be constructed in
high-density residential and commercial areas along Belmont Lane, Pullman Lane, Ford Avenue,
Goodman Avenue, and Steinhart Avenue, composing approximately 31 acres of total tributary
area.
• Beach Cities Green Streets 5 (Torrance 191st Street): Green street elements will be implemented
along 191st Street between Inglewood Avenue and Firmona Avenue, covering a drainage area of
15 acres of commercial corridor.
• Beach Cities Green Streets 6 (Torrance Northwest): Green street elements will be implemented
along Kingsdale, Mansel, Grevilea, and Burin Avenues between 182nd Street and 186th Street,
covering a drainage area of 51 acres of residential and commercial land uses.
• Beach Cities Green Streets 7 (Hermosa Beach): The project area consists of medium to high
density residential and commercial development, covering a total drainage area of 47.6 acres.
Improvements are proposed along Hermosa Avenue between 4th Street and Herondo Street, as
well as throughout the tributary watershed.
The Beach Cities Green Street Project is currently in design with the design objective of achieving full
capture of the 85th percentile, 24-hr design storm from each of the tributary areas.
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Since the project is designed to fully capture the 85th percentile, 24-hour design storm from each tributary
area, the respective tributary areas have been removed from the RAA model. Additional project design
information can be found in the Project Concept Report (Torrance, 2019)
Figure 5. Project Overview – Beach Cities Green Streets Project in SMB-6-1
3.3.3.2 Torrance Basins Enhancement & Expansion Project
Following initial enhancements to the Amie, Henrietta, and Entradero Flood Control Basin network
completed in 2015, the City of Torrance is moving forward with further improvements to expand the
capacity of these basins to fully retain the 85th percentile, 24-hour design storm from their combined
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1,407-acre tributary area, comprising approximately one half of the tributary area to the Herondo Storm
Drain system. The scope of this basin expansion project includes:
• Deepening of the existing Henrietta and Entradero Basins to increase storage capacity;
• Installation of drywells at Henrietta Basin to improve infiltration; and
• Adjustment of pumping levels at Amie Basin to ensure retention of the 85th percentile design
storm.
The project, which includes additional benefits such as walking trails and educational material, was
recently submitted for funding under the Safe Clean Water Program. Preliminary design of the project is
currently in process (City of Torrance, 2020a). A concept factsheet of the project is provided in Appendix
E.
Since the project is designed to fully capture the 85th percentile, 24-hour design storm from the tributary
area, the entire tributary area has been removed from the RAA model.
3.3.3.3 Hermosa Beach 8th Street Green Infrastructure Project
In 2020, Hermosa Beach completed a street improvement project along 8th Street, stretching from
Hermosa Avenue to Valley Drive. The street improvement project incorporated distributed Filterra®
biofiltration units that receive and treat surface runoff from 8.1-acres of area draining to the improved
street segment. The project treats runoff in both the SMB 5-5 and SMB 6-1 subwatersheds, but was only
quantified for the portion of the project that is tributary to analysis region SMB-6-1 (a total of 8.2 acres).
3.3.3.4 Fulton Playfield Infiltration Project
Fulton Playfield is an open green space in the City of Redondo Beach at the southeast intersection of
Ripley Avenue and Rindge Lane, located in the upper portion of the SMB-6-1 watershed. The playfield,
which is owned and operated by the City of Redondo Beach, is adjacent to an 8.5-foot by 10-foot
LACFCD storm drain (BI 6502 Line A) that runs under Ripley Avenue and connects directly to the
Herondo Storm Drain on 190th St. An underground flood control retention basin underlies the western half
of the playfield and provides approximately 6.4 acre-feet of passive storage to help relieve flooding
during storm events. Approximately 432 acres of the City of Redondo Beach and 25 acres of the City of
Manhattan Beach are tributary to the basin.
The Fulton Playfield Infiltration Project proposes to add infiltration elements to the existing flood control
basin in order to transform it into a multi-benefit regional project while maintaining its flood control
capacity and function. Infiltration will be accomplished via the addition of drywells to the eastern portion
of the playfield. The project will include a control system for the inlet-outlet structure of the basin to
manage and optimize the storage and infiltration capacity of the project. The total 24-hour management
volume provided by these distributed BMPs will be 26 acre-feet. The City of Redondo Beach will
coordinate with LACFCD to advance the design of this project as expeditiously as possible.
The Project will also incorporate a variety of other benefits. Parkway greening via the installation of rain
gardens is proposed along the east side of Ripley Avenue to capture and treat street flows that aren’t
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currently tributary to the Project. Park enhancements at the playfield, such as playground equipment or
outdoor exercise equipment, are being considered. Additionally, as Valor Christian Academy is directly
upstream of the Project, cooperation with the school will be prioritized.
The City of Redondo Beach is currently preparing a Feasibility Study for the project to apply for Safe
Clean Water regional project funding. An overview of the project is illustrated in Figure 6. A concept
plan of the project as envisioned is provided in Appendix E.
Figure 6. Project Overview – Fulton Playfield Infiltration Project
3.3.3.5 Redondo Beach Herondo Distributed Infiltration Project
The City of Redondo Beach is planning to implement a series of distributed infiltration BMPs (e.g.,
drywells, porous gutters, porous crosswalks, porous parking lanes, bioswales, etc.) within the Herondo
Storm Drain watershed. The total 24-hour management volume provided by these distributed BMPs will
be at least 17.6 acre-feet.
An overview of the project is illustrated in Figure 7. A concept plan showing a potential distribution of
drywells to achieve the required management volume is provided in Appendix E. Exact type and location
of each BMP is subject to change.
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Figure 7. Project Overview – Redondo Beach Herondo Distributed Infiltration Project
3.3.3.6 Hermosa Beach Distributed Drywells
The City of Hermosa Beach is planning to implement a series of drywells within the SMB-6-1 watershed.
Based on initial screening, drywells are proposed east of Pacific Coast Highway, between 1st Street and
10th Street.9 The total 24-hour management volume to be provided by these BMPs is estimated to be 7.7
acre-feet.
Project overview is illustrated in Figure 8. A concept plan showing a potential distribution of drywells to
achieve the required management volume is provided in Appendix E. Exact type and location of each
BMP is subject to change.
9 A drywell is a bored, drilled, or driven shaft or hole whose depth is greater than its width. A drywell may either be
a small excavated pit filled with aggregate or prefabricated storage chamber or pipe segment.
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Figure 8. Project Overview – Hermosa Beach Distributed Drywells
3.4 RAA Results – Load Reductions and Compliance Demonstration
Load reduction calculations for the Beach Cities SMB WMA are summarized in Table 5. Through the
RAA, the collective load reductions achieved by all existing and proposed BMPs achieved applicable
TLRs and TLR-equivalent 24-hour management volumes within each analysis region. As a result,
reasonable assurance is demonstrated for the Santa Monica Bay WMA. The 24-hour management volume
of each project is shown in Figure 9 both by project category and agency. To spatially represent the RAA
output, the 24-hour management volume is illustrated in Figure 10. As shown in the figure, analysis
regions with a zero calculated TLR (e.g., anti-degradation areas) were assigned a 0 acre-feet 24-hour
stormwater management volume. The 24-hour management volume of a regional project was spatially
represented by its drainage area. Drainage areas to 85th percentile, 24-hour design capture projects are
shown as hatched polygons, indicating these areas demonstrate compliance through the alternative
compliance path of full 85th percentile, 24-hour design stormwater capture.
Details on BMP load quantification and 24-hour management volume calculation for the Santa Monica
Bay WMA are provided in Appendix D.
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Table 5. Beach Cities Santa Monica Bay WMA RAA Summary
Analysis
Region
Fecal Coliform Target Load Reduction
(TLR) BMP Load Reduction (LR) Summary
10^12
MPN/yr
% of
Baseline
Load
TLR
Equivalent
24-Hour
Management
Volume
(ac-ft)
LID Redevelopment Regional Project Distributed Project Total Load Reduction RAA Achieved? % of
Baseline
Load
24-Hour
Volume
(ac-ft)
% of
Baseline
Load
24-Hour
Volume
(ac-ft)
% of
Baseline
Load
24-Hour
Volume
(ac-ft)
% of
Baseline
Load
24-Hour
Volume
(ac-ft)
SMB-5-01 Anti-
Degradation 0% 0 TLR = 0% for Anti-degradation site. No RAA needed n/a
SMB-5-02 60.5 53% 67.1 0.3% 0.4 64% 81.9 0% 0 64.3% 82.3 Yes
SMB-5-03 Anti-
Degradation 0% 0 TLR = 0% for Anti-degradation site. No RAA needed n/a
SMB-5-04 Anti-
Degradation 0% 0 TLR = 0% for Anti-degradation site. No RAA needed n/a
SMB-5-05 Anti-
Degradation 0% 0 TLR = 0% for Anti-degradation site. No RAA needed n/a
SMB-6-01 54.7 49% 51.2 0.3% 0.3 24.8% 25.9 24.1% 25.2 49.1% 51.4 Yes
SMB-6-02 Anti-
Degradation 0% 0 TLR = 0% for Anti-degradation site. No RAA needed n/a
SMB-6-03 0.0 0% 0 TLR = 0% based on historical monitoring data. No RAA needed n/a
SMB-6-04 0.0 0% 0 TLR = 0% based on historical monitoring data. No RAA needed n/a
SMB-6-05 Anti-
Degradation 0% 0 TLR = 0% for Anti-degradation site. No RAA needed n/a
SMB-6-06 Anti-
Degradation 0% 0 TLR = 0% for Anti-degradation site. No RAA needed n/a
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Figure 9 . Project-Specific 24-Hour Management Volume in Santa Monica Bay WMA
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Figure 10. 24-Hour Management Volume for the Santa Monica Bay WMA
As shown in Table 5, reasonable assurance of compliance is demonstrated for the two priority watersheds
within the Beach Cities SMB WMA based on full implementation of the suite of projects identified. A
schedule identifying implementation milestones for each project is provided in Section 7.1.
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3.5 RAA Results - Dry Weather Compliance Demonstration.
According to monitoring and observation data collected through the Beach Cities CIMP, low flow
diversions have proven effective at intercepting and diverting non-exempt dry weather flow from SMB.
Therefore, reasonable assurance of compliance during dry weather is demonstrated for the Beach Cities
SMB WMA.
4 DOMINGUEZ CHANNEL WATERSHED MANAGEMENT AREA
4.1 Identification of Water Quality Priorities
As part of the EWMP process, the Permit requires the Beach Cities WMG to identify water quality
priorities within their WMA. The list of WBPCs defined in the original Beach Cities EWMP has been
revised based on the most recent updates to applicable TMDLs and 303(d) listings, as well as CIMP
monitoring data collected through June 2020. The updated WBPC list for Dominguez Channel WMA is
summarized in Table 6.
Table 6. Water Body Pollutant Combinations – Dominguez Channela
Category Water Body Pollutant – Applicable
Condition Reason for Categorization
1: Highest
Priority
Dominguez Channel
Freshwater
Toxicityb – Wet Weather
Dominguez Channel and Greater Los
Angeles and Long Beach Harbors
Toxics TMDL (LARWQCB, 2011)
Total Copper – Wet Weather
Total Lead – Wet Weather
Total Zinc – Wet Weather
Dominguez Channel
Estuary (including
Torrance Carson
Channel)
Total Copper – Wet Weather
Total Lead – Wet Weather
Total Zinc – Wet Weather
Total Cadmium – Wet Weather
Total DDT – Year-Round
Total PAHs – Year-Round
Total PCBs – Year-Round
2: High
Priority
Dominguez Channel
(including Torrance
Carson Channel)
Indicator Bacteria 2014-2016 303(d) List
3. Medium
Priority
Dominguez Channel
Freshwater Benzo(a)pyrene – Wet Weather
Historical exceedance of applicable
receiving water limits (California Toxic
Rule Human Health Criteria) where
MS4 discharge may be causing or
contributing to the exceedance
a Does not include WBPCs applicable the Beach Cities WMA within the Machado Lake Watershed, which is addressed by the
separate Machado Lake Watershed EWMP developed by City of Torrance.
b Toxicity is not directly tied to any single pollutant or group of pollutants that can be readily modeled; rather, it is the result of a
wide-array of loading from multiple pollutants from various sources. As a result, toxicity will not be modeled as part of the
revised EWMP, consistent with the original EWMP. It is assumed that the implementation of various BMPs and resultant control
of other pollutants of concern will sufficiently address in-channel toxicity.
c EPA banned diazinon on December 31, 2005. Data from 2006-2010 show no diazinon exceedances in Dominguez Channel.
Based on these results, no diazinon TMDLs have been developed at this time.
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Details related to the identification, prioritization, and potential sources of each of the Dominguez
Channel WBPCs can be found in Appendix B. Unless otherwise noted, all WBPCs identified in Table 3
have been addressed as part of the revised RAA.
4.2 RAA Results – Baseline Loads and Target Load Reductions
Figure 11 illustrates the modeled analysis regions in the Dominguez Channel WMA. Analysis Regions
DC-N-MB, DC-N-RB, and DC-S represent the portions of the cities of Manhattan Beach, Redondo
Beach, and Torrance, respectively, draining to Dominguez Channel above Vermont Avenue (i.e.,
Dominguez Channel Freshwater). Analysis Region DC-TL is the portion of the City of Torrance that
drains to Torrance Lateral, which continues to the Dominguez Channel Estuary. Appendix D provides
additional details related to the analysis regions.
Figure 11. Dominguez Channel WMA Analysis Region Overview
The process for establishing pollutant TLRs necessary to meet water quality priorities for the modeled
WBPCs in Dominguez Channel is detailed in Appendix D. A summary of estimated baseline loads and
TLRs for each analysis region and WBPC in the Dominguez Channel WMA is provided in Table 7.
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Similar to the Santa Monica Bay WMA TLRs, a TLR-equivalent 24-hour management volume was
developed for each non-zero TLR. For each analysis region, the largest 24-hour management volume was
selected as the target compliance metric, since management of the largest volume will result in
management of all others.10 Both load-based TLRs and the equivalent 24-hour runoff management
volumes are considered eligible Beach Cities EWMP compliance metrics. Appendix D provides detailed
information on the process to calculate TLRs and 24-hour management volumes.
10 Total copper was not included in the assessment of the largest 24-hour management volume, since significant load
reductions will be achieved via the copper brake pad reduction (see Section 4.3.2). As a result, the management
volumes needed to meet applicable copper TLRs using structural BMPs are significantly reduced.
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Table 7. Dominguez Channel WMA Wet Weather TLRs
Analysis
Region
(Receiving
Water)
Pollutant Critical Condition Baseline Load
Target Load Reduction
Absolute
% of
Baseline
Load
TLR Equivalent 24-
Hour Management
Volume (ac-ft)
DC-N-MB
(Dominguez
Channel
Freshwater)
Total Copper 90th percentile daily load 1.3 lb/day 1.1 lb/day 82% 7.3
Total Lead CIMP data shows no exceedance in the past 5 years. No RAA needed to demonstrate compliance.
Total Zinc 90th percentile daily load 6.9 lb/day 5.3 lb/day 76% 6.7[1]
E. coli 90th percentile water year 46.1 1012 MPN/yr 19.0 1012 MPN/yr 41% 2.4
Benzo[a]pyrene 90th percentile daily load 2.6E-03 lb/day 1.8E-03 lb/day 70% 4.0
Toxicity CIMP data shows no exceedance in the past 5 years. No RAA needed to demonstrate compliance.
DC-N-RB
(Dominguez
Channel
Freshwater)
Total Copper 90th percentile daily load 4.1 lb/day 3.3 lb/day 81% 24.3
Total Lead CIMP data shows no exceedance in the past 5 years. No RAA needed to demonstrate compliance.
Total Zinc 90th percentile daily load 22.0 lb/day 16.3 lb/day 74% 22.3[1]
E. coli 90th percentile water year 149.8 1012 MPN/yr 53.0 1012 MPN/yr 35% 9.7
Benzo[a]pyrene 90th percentile daily load 7.7E-03 lb/day 5.2E-03 lb/day 67% 12.8
Toxicity CIMP data shows no exceedance in the past 5 years. No RAA needed to demonstrate compliance.
DC-S
(Dominguez
Channel
Freshwater)
Total Copper 90th percentile daily load 4.0 lb/day 3.0 lb/day 76% 27.1
Total Lead CIMP data shows no exceedance in the past 5 years. No RAA needed to demonstrate compliance.
Total Zinc 90th percentile daily load 18.4 lb/day 11.9 lb/day 65% 22.2[1]
E. coli 90th percentile water year 393.8 1012 MPN/yr 179.1 1012 MPN/yr 45% 15.3
Benzo[a]pyrene 90th percentile daily load 1.0E-02 lb/day 5.5E-03 lb/day 55% 18.7
Toxicity CIMP data shows no exceedance in the past 5 years. No RAA needed to demonstrate compliance
DC-TL
(Torrance
Lateral and
Dominguez
Channel
Estuary)
Total Copper 90th percentile daily load 11.5 lb/day 10.4 lb/day 91% 36.8
Total Lead CIMP data shows no exceedance in the past 5 years. No RAA needed to demonstrate compliance.
Total Zinc 90th percentile daily load 65.1 lb/day 57.4 lb/day 88% 35.8[1]
Total Cadmium 90th percentile daily load 0.15 lb/day 0.13 lb/day 87% 35.2
E. coli 90th percentile water year 360.8 1012 MPN/yr 175.3 1012 MPN/yr 49% 16.2
Benzo[a]pyrene 90th percentile daily load 2.0E-02 lb/day 1.3E-02 lb/day 67% 34.1
Total PAHs CIMP data shows no exceedance in the past 5 years. No RAA needed to demonstrate compliance.
Toxicity CIMP data shows no exceedance in the past 5 years. No RAA needed to demonstrate compliance.
Total PCBs CIMP data shows no exceedance in the past 5 years. No RAA needed to demonstrate compliance.
Total DDTs CIMP data shows no exceedance in the past 5 years. No RAA needed to demonstrate compliance.
[1]Bold value is the representative (“controlling”) 24-hour management runoff volume for each analysis region.
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4.3 BMP Summary
As discussed in Section 2 and Appendix D, BMPs were identified and accounted for in the RAA to
demonstrate attainment of applicable water quality targets. Because the RAA was calibrated using local
water quality and flow data through June 2020, only BMPs implemented or planned to be implemented
after this date were accounted for in the RAA. A summary of these BMPs, including programmatic and
structural measures, is provided herein.
4.3.1 Redevelopment
Redevelopment in the Dominguez Channel WMA was accounted for in the same manner as it was in the
SMB Watershed. See discussion in Section 3.3.1 and Appendix D.
An example of LID redevelopment project in the Dominguez Channel WMA is the Manhattan Village
Mall. The mall is undergoing significant renovations that include a rainwater harvesting and use system,
as well as a biofiltration system. The rainwater harvesting system is sized to fully capture the 85th
percentile, 24-hour design storm from a total of 13.7 acres of on-site drainage area. Projects such as these
will further increase the stormwater runoff managed within the Dominguez Channel WMA.
4.3.2 Copper Brake Pad Reduction
As was the case in the original Beach Cities EWMP, a load reduction was assumed for copper due to the
phased 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
technical study for the California Stormwater Quality Association (CASQA) describing the expected
percent reduction for copper as a result of the passage of SB 346 (TDC Environmental, 2013). The TDC
study identified three possible implementation scenarios, the least aggressive of which estimated that a
52% load reduction in copper will be achieved by 2032 due to the brake pad phase-out.
Since the referenced study assumed a 21.2% reduction in urban runoff copper by 2020, and the RAA
model was calibrated with local water quality data through June 2020, the load reduction accounted for in
the revised RAA was estimated as a weighted fraction of 52%. The difference in estimated total load
reduction between 2020 and 2032 (i.e., 52% - 21.2%, or 30.8%) was divided by the assumed remaining
load in 2020 (100% - 21.2%, or 78.8%) to estimate the remaining expected load reduction due to the
copper brake pad phase-out. Therefore, a 39.1% load reduction was assumed for copper in the Beach
Cities Dominguez Channel WMA.
To avoid double-counting load reductions, this reduction was applied to the copper load before
accounting for future BMP load reductions (i.e., 39.1% was applied to the baseline loads before all other
BMP load reductions were accounted for, since BMP performance is dependent on influent loads).
4.3.3 Analysis Region DC-N-MB & DC-N-RB
Analysis regions DC-N-MB and DC-N-RB include discharges from the cities of Manhattan Beach and
Redondo Beach to Dominguez Channel respectively. Both analysis regions also drain to the Alondra Park
Stormwater Capture Project.
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4.3.3.1 Alondra Park Stormwater Capture Project
The Alondra Park Stormwater Capture Project is a multi-benefit stormwater project proposed at Alondra
Park, a large park located in the unincorporated County area of EI Camino Village that consists of two
park areas and a golf course. The park is due east of Manhattan Beach and Redondo Beach, under the
jurisdiction of Los Angeles County Department of Parks and Recreation.
The proposed project has been strategically located in the 13.5-acre park space in the northwest corner of
the site. The Project provides the opportunity to capture dry weather flows and stormwater and improve
water quality by diverting flows from the LACFCD District Project No. 12 Drain in Manhattan Beach
Boulevard and the LACFCD Alondra Park Drain into underground storage galleries totaling 34-acre-feet
in total capacity.
The captured flows are proposed to be diverted from the galleries into an existing sewer system. During
storm events when flows are higher than sewer capacity, water will be treated before being diverted back
to the storm drain. The diversion structure and storage galleries will intercept and store dry weather flows
and approximately a 0.1-inch storm from the 4,945-acre watershed tributary to Alondra Park.
Two existing baseball fields will be restored to new condition and a brand-new soccer field will be
installed after the underground storage is constructed, providing enhanced active recreation spaces.
Bioswales with native plants will replace existing turf areas along Manhattan Beach Boulevard, providing
new habitat and a natural way to slow and treat stormwater and dry weather runoff. The parking lots will
be reconstructed with permeable pavement and bioswales. New trees will be planted throughout the park
to provide shade and bolster the performance of other green infrastructure.
The cities of Manhattan Beach and Redondo Beach collectively account for approximately 1,424 acres
(29%) of the tributary area to the Alondra Park Stormwater Capture Project. As project partners, they will
receive a portion of water quality benefits from the overall project, proportional to their drainage area and
additional funding that may be provided. At the time of this revised EWMP, Manhattan Beach was
estimated to receive 1.76-acre-feet of storage credit and Redondo Beach was estimated to receive 5.29-
acre-feet of storage credit. The project has been modeled in the Beach Cities RAA assuming these
proportional volumes for each city.
Additional information for the project can be found in the Alondra Park Regional Project Safe Clean
Water Feasibility Study Report (Los Angeles County, 2019). A high-level project concept is illustrated in
Figure 12.
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Figure 12. Project Overview – Alondra Park Stormwater Capture Project
4.3.3.2 Manhattan Beach Dominguez Channel Distributed Infiltration Project
The City of Manhattan Beach is planning to implement a series of distributed infiltration BMPs (e.g.,
drywells) within the DC-N-MB analysis region to meet the city’s allocation of the TLR. Based on initial
screening, infiltration BMPs are proposed on 33rd Street west of N. Aviation Boulevard, or on N. Aviation
Boulevard north of Marine Avenue. RAA results (see Section 4.4) show that the total 24-hour
management volume provided by these BMPs will be 5.1 acre-ft.
A project concept is illustrated in Figure 13. A concept plan showing a potential distribution of infiltration
BMPs to achieve the required management volume is provided in Appendix E. Exact type and location of
each BMP is subject to change.
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Figure 13. Project Overview – Manhattan Beach Dominguez Channel Distributed Infiltration
Project
4.3.3.3 Glen Anderson Park Regional Infiltration Project
Glen Anderson Park is multi-use park in the City of Redondo Beach, located adjacent to Lincoln
Elementary School between Rindge Lane, Farrell Avenue, and Vail Avenue. The park has significant
green space in addition to baseball fields, tennis courts, basketball courts, and a playground. The park,
which is owned and operated by the City of Redondo Beach, is adjacent to a 78-inch reinforced concrete
pipe storm drain (LACFCD BI 0729) that runs under Vaile Avenue. Approximately 480 acres of area
within the DC-N-RB analysis region is tributary to this storm drain at the point it flows past Glen
Anderson Park.
The Glen Anderson Park Regional Infiltration Project will provide infiltration via an underground
infiltration basin or a series of drywells, or a combination of both. Pretreatment will be provided
following diversion from the Vail Avenue storm drain.
A project concept is illustrated in Figure 14. A detailed concept plan of the project as envisioned is
provided in Appendix E.
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Figure 14. Project Overview – Glen Anderson Park Regional Infiltration Project
4.3.3.4 Redondo Beach Dominguez Channel Distributed Infiltration Project
The City of Redondo Beach is planning to implement a series of distributed infiltration BMPs (e.g.,
drywells, porous gutters, porous crosswalks, porous parking lanes, bioswales, etc.) within the DC-N-RB
analysis region to meet the remainder of the city’s allocation of the TLR. Based on RAA results (see
Section 4.4), the total 24-hour management volume provided by these BMPs will be 8.4 acre-ft.
A project concept is illustrated in Figure 15. A concept plan showing a potential distribution of infiltration
BMPs to achieve the required management volume is provided in Appendix E. Exact type and location of
each BMP is subject to change.
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Figure 15. Project Overview – Redondo Beach Dominguez Channel Distributed Infiltration Project
4.3.4 Analysis Region DC-S
This analysis region includes discharges from the City of Torrance to Dominguez Channel.
4.3.4.1 Torrance Parkway BMPs
As discussed in the original Beach Cities EWMP, the City of Torrance is committed to implementing
distributed green street BMPs within the watershed to meet RAA requirements. Specific BMP
technologies are currently being evaluated, but may include catch basin inlet filters (media filtration
devices with a variety of media types and configurations such as cartridge filters, vertical bed filters, etc.),
bioretention units, or drywells, where deemed feasible.
The City of Torrance has applied for Safe Clean Water funding under the Technical Resources Program
to prioritize catch basins for implementation (City of Torrance, 2020b).
Collectively, the Torrance Parkway BMPs will be implemented by the City of Torrance at a level that
meets the EWMP compliance management volume determined in the RAA (see Section 4.4). A concept
factsheet for the proposed Torrance Parkway BMPs is provided in Appendix E.
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4.3.5 Analysis Region DC-TL
This analysis region includes discharges from the City of Torrance to Torrance Lateral (i.e., Torrance
Carson Channel).
4.3.5.1 Torrance Parkway BMPs
The City of Torrance will implement the same distributed parkway BMP approach in the DC-TL analysis
region as is being applied to the DC-S analysis region.
4.4 RAA Results – Load Reductions and Compliance Demonstration
Load reduction calculations for the Beach Cities Dominguez Channel WMA are summarized in Table 8.
Reasonable assurance has been demonstrated in all analysis regions. The 24-hour management volumes
of the projects are shown in Figure 16 as stacked columns. The figure also breaks down the 24-hour
management volume by agency. To spatially represent the RAA output, the 24-hour management volume
is illustrated in Figure 17. Drainage areas to 85th percentile, 24-hour design capture projects are shown as
hatched polygons, indicating these areas achieve compliance through the alternative compliance path of
full 85th percentile, 24-hour design stormwater capture. In addition, areas covered under separate
stormwater permits (e.g. Caltrans right-of-way, Torrance Refinery) are shown as hatched polygons, as
they were not included in the RAA.
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Table 8. Beach Cities Dominguez Channel WMA RAA Summary Analysis Region Pollutant
Final Target Load
Reduction
BMP Load Reduction Summary
Non-Structural BMP LID Redevelopment Regional Project Distributed Projects Total Load Reduction Assurance Achieved? Absolute % Absolute % Absolute % Absolute % Absolute % Absolute % DC-N-MB (DC Freshwater) Total Copper 1.1 lb/day 82% 0.5 lb/day 39% 0.01 lb/day 0.9% 0.2 lb/day 16% 0.4 lb/day 33% 1.1 lb/day 89% Yes
Total Lead CIMP data shows no exceedance in the past 5 years. No RAA needed n/a
Total Zinc 5.3 lb/day 76% 0 lb/day 0% 0.1 lb/day 0.9% 1.6 lb/day 23% 3.7 lb/day 54% 5.4 lb/day 78% Yes
E. coli 19.0 1012
MPN/yr 41% 0 1012
MPN/y 0% 0.3 1012
MPN/y 0.7% 8.7 1012
MPN/yr 19% 19.5 1012
MPN/yr 42% 28.5 1012
MPN/yr 62% Yes
Benzo[a]
pyrene
1.8
E-03 lb/day 70% 0 lb/day 0% 2.4
E-05 lb/day 0.9% 4.9
E-04 lb/day 19% 1.4
E-03 lb/day 56% 2.0
E-03 lb/day 76% Yes
24-Hour
Management
Need
6.7 ac-ft 100% 0 ac-ft 0% 0.1 ac-ft 0.9% 1.9 ac-ft 29% 5.2 ac-ft 77% 7.2 ac-ft 100% Yes DC-N-RB (DC Freshwater) Total Copper 3.3 lb/day 81% 1.6 lb/day 39% 0.04 lb/day 0.9% 0.5 lb/day 13% 1.3 lb/day 32% 3.4 lb/day 85% Yes
Total Lead CIMP data shows no exceedance in the past 5 years. No RAA needed n/a
Total Zinc 16.3 lb/day 74% 0 lb/day 0% 0.2 lb/day 1.0% 4.1 lb/day 19% 12.4 lb/day 56% 16.7 lb/day 76% Yes
E. coli 53.0 1012
MPN/ 35% 0 1012
MPN/y 0% 1.1 1012
MPN/y 0.7% 49.5 1012
MPN/yr 33% 19.1 1012
MPN/yr 13% 69.7 1012
MPN/yr 47% Yes
Benzo[a]pyre
ne
5.2
E-03 lb/day 67% 0 lb/day 0% 7E-05 lb/day 1.0% 2E-
03 lb/day 25% 4E-03 lb/day 48% 6E-03 lb/day 73% Yes
24-Hour
Management
Need
22.3 ac-ft 100% 0 ac-ft 0% 0.2 ac-ft/ 1.0% 15.5 ac-ft 69% 8.3 ac-ft 37% 24.0 ac-ft 100% Yes DC-S (DC Freshwater) Total Copper 3.0 lb/day 76% 1.5 lb/day 39% 0.1 lb/day 0.9% 0 lb/day 0% 1.4 lb/day 36% 3.0 lb/day 76% Yes
Total Lead CIMP data shows no exceedance in the past 5 years. No RAA needed n/a
Total Zinc 11.9 lb/day 65% 0 lb/day 0% 0.2 lb/day 1.0% 0 lb/day 0% 11.7 lb/day 64% 11.9 lb/day 65% Yes
E. coli 179.1 1012
MPN/y 45% 0 10^12
MPN/yr 0% 2.2 1012
MPN/yr 0.6% 0 10^12
MPN/yr 0% 176.9 10^12
MPN/yr 45% 179.1 1012
MPN/yr 45% Yes
Benzo[a]pyre
ne
5.5
E-03 lb/day 55% 0 lb/day 0% 9.4
E-05 lb/day 0.9% 0 lb/day 0% 5.5
E-03 lb/day 54% 5.5
E-03 lb/day 55% Yes
24-Hour
Management
Need
22.2 ac-ft 100% 0 ac-ft 0% 0.3 ac-ft 1.1% 0 ac-ft 0% 21.9 ac-ft 99% 22.2 ac-ft 100% Yes
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Analysis Region Pollutant
Final Target Load
Reduction
BMP Load Reduction Summary
Non-Structural BMP LID Redevelopment Regional Project Distributed Projects Total Load Reduction Assurance Achieved? Absolute % Absolute % Absolute % Absolute % Absolute % Absolute % DC-TL (DC Estuary and Torrance Lateral) Total Copper 10.4 lb/day 91% 4.5 lb/day 39% 0.1 lb/day 1.0% 0 lb/day 0% 5.8 lb/day 51% 10.4 lb/day 91% Yes
Total Lead CIMP data shows no exceedance in the past 5 years. No RAA needed n/a
Total Zinc 57.4 lb/day 88% 0 lb/day 0% 0.6 lb/day 1.0% 0 lb/day 0% 56.8 lb/day 87% 57.4 lb/day 88% Yes
Total
Cadmium 0.13 lb/day 87% 0 lb/day 0% 1.0
E-3 lb/day 0.7% 0 lb/day 0% 0.13 lb/day 87% 0.13 lb/day 87% Yes
E. coli 175.3 1012
MPN/yr 49% 0 1012
MPN/y 0% 2.1 1012
MPN/yr 0.6% 0 1012
MPN/yr 0% 173.2 1012
MPN/yr 49% 175.3 1012
MPN/yr 49% Yes
Benzo[a]pyre
ne
1.3
E-02 lb/day 67% 0 lb/day 0% 2E-04 lb/day 0.9% 0 lb/day 0% 1.3
E-02 lb/day 66% 1.3
E-02 lb/day 67% Yes
Total PAHs CIMP data shows no exceedance in the past 5 years. No RAA needed n/a
24-Hour
Management
Need
35.8 ac-ft 100% 0 ac-ft 0% 0.3 ac-ft 1.0% 0 ac-ft 0% 35.5 ac-ft 99% 35.8 ac-ft 100% Yes
Total DDT CIMP data shows no exceedance in the past 5 years. No RAA needed n/a
Total PCB CIMP data shows no exceedance in the past 5 years. No RAA needed n/a
[2] Please see Table 13 on how the representative 24-hour management volume was selected for each analysis region.
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Figure 16. Project Specific 24-Hour Management Volume in Dominguez Channel WMA
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Figure 17. 24-Hour Management Volume Mapping in Dominguez Channel WMA
As shown in Table 8, reasonable assurance of compliance is demonstrated for the Beach Cities
Dominguez Channel WMA based on full implementation of the suite of projects identified. A schedule
identifying implementation milestones for each project is provided in Section 7.2.
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4.5 RAA Results – Dry Weather Compliance Demonstration
The Beach Cities WMG has attempted to eliminate non-exempt dry weather MS4 discharges using a suite
of structural BMPs and non-structural source controls (e.g., water conservation incentives, enhanced
IDDE efforts, enhanced education/outreach, and inspection/enforcement to prevent sources of non-
stormwater flow). To date, monitoring has shown that the WMG has been successful at this endeavor, and
although dry weather flows do still exist in some outfalls draining to the DC, particularly within Torrance
Lateral, the WMG has successfully demonstrated through source investigations that these discharges may
be considered conditionally exempt.
In parallel to the ongoing effort of eliminating dry weather MS4 discharges, the Beach Cities WMG has
also planned to utilize structural BMPs to intercept dry weather runoff. In both the Manhattan Beach
portion and Redondo Beach portion of the Dominguez Channel WMA, monitoring data has demonstrated
a lack of persistent dry weather flows. In addition, the Alondra Park Regional Stormwater Capture Project
is anticipated to intercept and fully treat all tributary intermittent non-stormwater flows, including those
from Manhattan Beach and Redondo Beach. Within the City of Torrance’s portion of the Dominguez
Channel WMA, significant dry weather source investigations were complete and revealed that persistent
non-stormwater discharges were the result of exempt and conditionally exempt sources. The City of
Torrance is also committed to targeting non-stormwater discharge sources when implementing the
Torrance Parkway BMP distributed projects, thereby treating non-stormwater sources that may be causing
or contributing to downstream impairments. A summary of these results is provided in Table 9. Therefore,
reasonable assurance of compliance during dry weather is demonstrated for the Beach Cities Dominguez
Channel (including Torrance Lateral) WMA.
Table 9.Dry Weather RAA Results – Dominguez Channel WMA
Analysis
Region
Is dry weather flow
currently non-
existent and/or
sufficiently treated or
diverted?
Are sufficient
structural BMP
proposed to intercept,
treat or divert 100% of
dry weather runoff?
Is dry weather
reasonable
assurance
demonstrated?
DC-N-MB Yes Proposed Yes
DC-N-RB Yes Proposed Yes
DC-S No Proposed Yes
DC-TL No Proposed Yes
5 COST ESTIMATE
This section provides estimates of the financial resources that may be required to attain compliance with
the MS4 Permit’s RWLs and WQBELs. Planning-level cost estimates associated with implementation of
the proposed structural BMPs within the Beach Cities WMG area are provided based on RAA results.
Cost estimates 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
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budget forecasts 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 provided in Appendix G.
These funding sources and programs may be utilized depending on applicability and feasibility.
5.1 BMP Cost Methodology and Assumptions
5.1.1 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 BMP
storage/treatment volumes and typical design configurations. Unit costs were derived from past projects
based in Southern California, recent construction cost/bid information, and vendors. 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.
5.1.2 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.
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Estimated soft costs as percent of total project capital costs are presented in Table 10. These percentages
were based on literature, best professional judgment, and data from past projects (Brown and Schueler,
1997; International Cost Engineering Council, 2014).
Table 10.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 14% 40%
Construction Management 8% 15%
1 $2,000 minimum fee
5.1.3 Operations and Maintenance
Based on past projects completed in Southern California, recent construction cost/bid information, and
information from vendors, annual Operations and Maintenance (O&M) costs were assumed to be 2%
percent of the capital cost for all proposed structural BMPs. Annual Monitoring costs were assumed to be
1.5% of capital costs, but were only assumed to apply for three full years.
O&M opinions for drywells and infiltration basins include cleaning and removal of debris from inlet and
drainage pipes, removal of sediment and trash from intake and debris shields, cleanout of trash and
accumulated sediment from primary settling chambers, and removal of standing water when observed
during dry weather. 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 annual costs, though all activities are not necessarily performed every year of
operation.
Additional maintenance will be necessary after the estimated project lifecycle, assumed to be 20 years.
Extended maintenance for drywells and other subsurface infiltration systems 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. 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 are
recommended after major storm events, or storms with a rainfall intensity of greater than one inch in 12
hours.
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5.1.4 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.
5.2 Summary of Cost Estimates
Table 11 summarizes the total cost estimates for each proposed structural BMP, which are composed of
the cost to construct or implement each structural BMP plus the associated annual O&M and monitoring
costs, with 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 11, it is clear that projected
costs of implementing the EWMP are substantial and that availability of funds will be critical for the
implementation of the EWMP.
The Beach Cities agencies are relying heavily on funding of projects through LA County’s Safe Clean
Water Program (SCW Program). The SCW Program is designed to prioritize multi-benefit water quality
improvement projects identified in regional EWMPs or related watershed plans, including the structural
BMPs proposed in the Beach Cities EWMP. Funding applications are reviewed annually for partial or full
funding. Additional information is provided in Appendix G.
In addition, the Beach Cities WMG individually and collaboratively are committed to pursue funding
sources at a State, regional, and local level. These potential sources of funding are discussed in greater
detail in Appendix G.
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Table 11.Cost Estimates for Proposed Structural BMPs by Analysis Region
Analysis
Region Project Capital Cost Annual
O&M Cost4
Monitoring
Cost5 Low High
SMB-6-1
Fulton Playfield Infiltration Project $1,995,000 $2,625,000 $45,000 $35,000
Hermosa Beach Distributed Drywells $1,615,000 $2,125,000 $35,000 $30,000
Redondo Beach Herondo Distributed
Infiltration Project $3,230,000 $4,250,000 $70,000 $55,000
Beach Cities Green Streets Project1 $4,900,000 $4,900,000 $20,000 $55,000
Torrance Basins Enhancement &
Expansion Project1 $5,300,000 $5,300,000 $30,000 $80,000
SMB-6-1 Total $17,040,000 $19,200,000 $200,000 $255,000
SMB-5-2 28th Street Storm Drain Infiltration
Project1 $17,800,000 $17,800,000 $155,000 $50,000
DC-N-MB
Manhattan Beach Dominguez Channel
Distributed Infiltration Project $1,615,000 $2,125,000 $35,000 $30,000
Alondra Park Stormwater Capture
Project- Manhattan Beach Portion2 $2,240,000 $2,240,000 $14,800 -
DC-N-MB Total $3,855,000 $4,365,000 $49,800 $30,000
DC-N-RB
Glen Anderson Park Regional
Infiltration Project $3,135,000 $4,125,000 $65,000 $50,000
Redondo Beach Dominguez Channel
Distributed Infiltration Project $2,090,000 $2,750,000 $45,000 $35,000
Alondra Park Stormwater Capture
Project- Redondo Beach Portion2 $6,730,000 $6,730,000 $44,500 -
DC-N-RB Total $11,955,000 $13,605,000 $154,500 $85,000
DC-S Torrance Parkway BMPs3 $5,200,000 $6,900,000 $115,000 $95,000
DC-TL Torrance Parkway BMPs3 $8,500,000 $11,100,000 $180,000 $155,000
EWMP Total $64,350,000 $72,970,000 $854,300 $670,000
1 Cost estimates taken from SCW Program Feasibility Study. As a result, no range is estimated. For the Beach Cities Green
Streets Project, costs are not broken down by project sit and therefore cannot be allocated by analysis region. Since the majority
of project sites are within the SMB-6-1 analysis region, the project cost has been accounted for here.
2 Cost estimate based on SCW Program cost allocation by contributing agency as of March 2021.
3 Cost estimate based on per acre-foot cost for other distributed infiltration projects within the Beach Cities EWMP.
4 Assumed to apply annually for the duration of the project life cycle.
5 Assumed to apply annually for the first three years of the project life cycle.
6 ASSESSMENT AND ADAPTIVE MANAGEMENT FRAMEWORK
Adaptive management is a critical component of the EWMP implementation process, and regular EWMP
updates are required by the Permit. The CIMP will continue to gather additional data on receiving water
conditions and stormwater/non-stormwater quality and flow. These data will continue to 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.
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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 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 previously outlined, the schedule and milestones for the EWMP have been designed around meeting
the interim and final TMDL requirements for applicable WBPCs. 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.
Monitoring data will be utilized to measure progress towards achieving RWLs and WQBELs. An
evaluation of monitoring data will be carried out periodically 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). Modifications that are warranted because insufficient progress is being
made will be noted in the annual report and an updated schedule for implementation will be provided.
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 herein 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 Beach Cities WMG will need to receive an
extension of the compliance deadlines.
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7 COMPLIANCE SCHEDULE
The following sections present the proposed compliance schedules and project sequencing necessary to
meet the final compliance deadlines for the Beach Cities EWMP WPBCs.
7.1 Santa Monica Bay WMA
Within the Beach Cities SMB WMA, bacteria is the only WBPC for which a RAA was performed. All
other WBPCs are not currently causing or contributing to receiving water exceedances based on an
evaluation of outfall and receiving water data.
The Beach Cities WMG is currently meeting all applicable interim WLAs in the Santa Monica Bay
WMA. Therefore, no interim compliance milestones are necessary.
The final wet weather WLA defined in the SMBBB TMDL officially goes into effect in July 2021;
however, a Basin Plan Amendment extending the TMDL for three years until July 2024 has been
approved by the Regional Board and is pending approval by the State Water Resources Control Board and
the State Office of Administrative Law. As discussed by the Beach Cities representatives, other
permittees, Regional Board staff, and many other stakeholders during the Regional Board hearing and in
comments letters submitted on the TMDL schedule extension, additional time beyond the July 2024
extension will be necessary to complete all of the projects needed to meet the final TLRs. Once the Beach
Cities WMG has demonstrated further implementation progress, the WMG anticipates submitting a
request via one or more regulatory mechanisms to extend this deadline further.
In light of these assumptions and observations, a project implementation schedule expressed in terms of
the 24-hour runoff management volume and project completion date was developed to reasonably assure
the Beach Cities WMG will meet final TLRs for bacteria during wet weather in the Santa Monica Bay
WMA. The schedule is provided in Table 12.
Table 12. Project Completion Date and 24-Hour Runoff Management Capacity in SMB WMA
Project Name Responsible
Agencies
Milestone
Completion
Description
Milestone
Completion
(Year)
24-Hour Runoff
Management
Capacity (ac-ft)
28th Street Storm Drain
Infiltration Project Phase 1 Manhattan Beach
Design 2022
81.9
Construction 2024
Torrance Basins Expansion
Project Torrance
Design 2022 85th percentile, 24-
hour storm capture
(32.2 ac-ft) Construction 2024
Joint Beach Cities Green
Streets Project
Hermosa Beach
Manhattan Beach
Redondo Beach
Torrance
Design 2023 85th percentile, 24-
hour storm capture Construction 2026
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Project Name Responsible
Agencies
Milestone
Completion
Description
Milestone
Completion
(Year)
24-Hour Runoff
Management
Capacity (ac-ft)
Fulton Playfield Infiltration
Project
Redondo Beach
and LACFCD
Feasibility Study 2022
26.0 Design 2025
Construction 2028
Hermosa Beach Distributed
Drywells Hermosa Beach
Siting and feasibility
study 2025
7.7
Construction 2028
Redondo Beach Herondo
Distributed Infiltration
Project
Redondo Beach
Siting and feasibility
Study 2025
17.6
Construction 2028
7.2 Dominguez Channel WMA
The Beach Cities WMG has been implementing the Beach Cities CIMP program since October 2016 and
have been analyzing outfall monitoring data in the Dominguez Channel WMA against applicable interim
MS4 WLA WQBELs. No exceedances of interim WQBELs have occurred to date. As a result, and as
demonstrated by the RAA, no additional stormwater control measures are required to address interim
WQBELs. Furthermore, distributed projects collectively addressing 110 acres of target land use out of a
total of 1448.5 acres of target land use in the DC-N-MB & DC-N-RB analysis regions have been
completed to meet both previous interim milestones of addressing 3% of target land use by 2021 and
addressing 7% of target land use by 2026. Additionally, catch basin inserts have been installed in 30 high-
priority catch basins within the DC-S & DC-L analysis regions to meet the first interim 2021milestone in
those analysis regions.
The final applicable WLAs defined in the Dominguez Channel Toxics TMDL will be in effect in 2032.
As a result, all proposed stormwater control measures must be implemented by 2032 in order to meet the
final TLRs.
A project implementation schedule expressed in terms of the 24-hour runoff management volume was
developed to reasonably assure the Beach Cities WMG will meet final TLRs for all WBPCs in the
Dominguez Channel WMA.
The estimated project completion time and 24-hour runoff management capacity of proposed projects is
summarized in Table 13. The 85th percentile, 24-hour capture projects in the Dominguez Channel WMA
are included in Table 13 for informational purposes.
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Table 13. Project Completion Date and 24-Hour Runoff Management Capacity in DC WMA
Project Name Responsible
Agencies
Milestone
Completion
Description
Milestone
Completion
(Year)
24-Hour Runoff
Management
Capacity (ac-ft)
Alondra Park Stormwater
Capture Project
LACFCD
Redondo Beach
Manhattan Beach
Design 2022
7.05[1]
Construction 2023
Manhattan Beach Dominguez
Channel Distributed
Infiltration Project
Manhattan Beach
Feasibility Study 2024
5.2 Design 2026
Construction 2028
Glen Anderson Park Regional
Infiltration Project Redondo Beach
Feasibility Study 2024
9.4 Design 2026
Construction 2028
Redondo Beach Dominguez
Channel Distributed
Infiltration Project
Redondo Beach
Feasibility Study 2027
8.3 Design 2029
Construction 2032
Torrance Parkway BMPs
Phase 1 Dominguez Channel
above Vermont
Torrance
Siting and feasibility
study 2024
21.9 Design 2026
Construction 2028
Torrance Parkway BMPs
Phase 2 Torrance Lateral Torrance
Siting and feasibility
study 2027
35.4 Design 2029
Construction 2032
1 Represents the total volume allocation to Manhattan Beach and Redondo Beach, collectively, since the full project
will be shared among numerous agencies.
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Management Group
Revised EWMP
Appendix A:
History and
Regulatory
Background
JUNE 2021
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HISTORY AND REGULATORY BACKGROUND OF THE BEACH CITIES EWMP BEACH CITIES EWMP HISTORY Following adoption of the 2012 Los Angeles Municipal Separate Storm Sewer System (MS4) National Pollutant Discharge Elimination System (NPDES) Permit1 (Permit), the Cities of Hermosa Beach, Manhattan Beach, Redondo Beach, and Torrance, together with the Los Angeles County Flood Control District (LACFCD), collectively referred to as the Beach Cities Watershed Management Group (Beach Cities WMG) agreed to collaborate on the development of an Enhanced Watershed Management Program (EWMP) for the Santa Monica Bay (SMB) and Dominguez Channel areas within their jurisdictions (referred to herein as the Beach Cities EWMP Area). This EWMP is intended to facilitate effective, watershed-specific Permit implementation strategies in accordance with the Permit and summarizes the SMB and Dominguez Channel-specific water quality priorities identified jointly by the Beach Cities WMG, outlines the program plan, including specific strategies, control measures and best management practices (BMPs)2, necessary to achieve water quality targets (Water Quality-Based Effluent Limitations [WQBELs] and Receiving Water Limitations [RWLs]), and describes the quantitative analyses completed to support target achievement and Permit compliance. In compliance with the Permit, the Beach Cities WMG submitted to the Los Angeles Regional Water Quality Control Board (LARWQCB) a Notice of Intent (NOI) to develop an EWMP on June 28, 2013 with a revised NOI submitted December 17, 2013. On March 27, 2014, the Beach Cities WMG received a letter from the Executive Officer of the LARWQCB approving the revised NOI submittal. In compliance with the Permit, the Beach Cities WMG then submitted a draft EWMP Work Plan to the LARWQCB on June 26, 2014. Comments were not received. Consistent with the draft EWMP Work Plan and in accordance with the Permit, the Beach Cities WMG submitted a draft EWMP to LARWQCB on June 26, 2015. Following public review and comment, as well as review by LARWQCB, the Beach Cities WMG submitted a revised EWMP on January 20, 2016. After the Group’s submittal of the revised EWMP, additional comments were provided by LARWQCB and modifications were requested. The WMG submitted a second revised EWMP on February 9, 2016 for LARWQCB review and approval. On April 18, 2016 the Beach Cities second revised EWMP was approved by LARWQCB. The Beach Cities WMG immediately began implementation of the approved EWMP.
1 Order No. R4-2012-0175 NPDES Permit No. CAS004001 Waste Discharge Requirements for Municipal Separate Storm Sewer System (MS4) Discharges within the Coastal Watersheds of Los Angeles County, except those Discharges Originating from the City of Long Beach MS4. 2 For simplification, the term “BMP” will be used to collectively refer to strategies, control measures, and/or best management practices. The Permit also refers to these measures as Watershed Control Measures.
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ADAPTIVE MANAGEMENT As outlined in the Permit, the Beach Cities WMG is required to implement an adaptive management process periodically. The adaptive management process serves as a means to comprehensively evaluate the EWMP and evaluate progress toward achieving:
• Applicable WQBELs/RWLs;
• Improved water quality in MS4 discharges and receiving waters;
• Interim milestones; and
• Multi-year efforts that were not completed in the current year and will continue into the subsequent year(s), among other requirements. Based on the adaptive management process, as well as other relevant changes within the Beach Cities Area, multiple updates to the Beach Cities EWMP have occurred since its original approval in April 2016:
March 2018. In order to investigate the use of centralized high-flow capacity trash device technologies and other approved equivalent systems certified by the State Water Resources Control Board to meet the final Santa Monica Bay Nearshore and Offshore Debris TMDL RWL for trash, the Beach Cities WMG requested an update to the EWMP implementation schedule. The schedule modification only affected interim compliance milestones; no changes to final compliance deadlines occurred. Three tables in the EWMP were updated to reflect the revised interim schedules.
August 2019. Following submittal of an Adaptive Management Report in December 2018, the Beach Cities WMG received a letter from the LARWQCB on July 23, 2019, which approved proposed modifications to the Group’s EWMP as set forth in the Adaptive Management Report. Modifications to the EWMP included:
• Changes to Control Measures. The City of Torrance originally proposed to install approximately 200 catch basin inlet filters throughout the Dominguez Channel Watershed portion of their city. Upon further evaluation, the City of Torrance found that the use of modular wetlands, drywells, and other similar BMPs may be feasible in some portions of the watershed. As a result, language throughout the EWMP was revised to allow for the use of a larger suite of BMPs in these cases. The EWMP was also revised to discuss the source tracking investigation that the Group initiated in the Santa Monica Bay Watershed
• Changes to Minimum Control Measures. The EWMP was modified to customize the Group’s Public Information and Participation Program to better address watershed priorities by means of direct, targeted outreach to residents .
• Changes to Water Body Pollutant Combinations Based on the 303(d) List. The Group revised its EWMP to reflect changes incorporated into the 2014-2016 303(d) list. These changes included the addition of mercury and arsenic to the Category 2 Water Body
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Pollutant Combination (WBPC) list within the Santa Monica Bay Watershed, and removal of ammonia from the Category 2 WBPC list in the Dominguez Channel Watershed.
• Changes to the Final Target Date for Hermosa Beach Trash TMDL. The Santa Monica Bay Marine Debris TMDL allows municipalities that have adopted smoking, polystyrene, and plastic bag ban ordinances an additional three years (until March 20, 2023) to meet the final TMDL compliance deadline. While the City of Hermosa Beach had passed smoking and polystyrene bans within three years of the original adoption date of the TMDL (by March 20, 2015), the final plastic bag ban ordinance was not adopted until September 1, 2015. During the recent reconsideration of the Santa Monica Bay Debris TMDL, the City of Hermosa Beach requested to be granted the additional 3 years. After being open for public comment and receiving no objections, this extension was approved by the Regional Board.
EWMP REVISION AND RESUBMITTAL In addition to periodically adapting the EWMP , Permittees are required to submit an updated EWMP with an updated Reasonable Assurance Analysis (RAA) by June 30, 2021 for review and approval by the Regional Water Board Executive Officer. The updated RAA is required to incorporate both water quality data and control measure performance data, and any other information informing the adaptive management process, gathered through December 31, 2020. The latest version of the Beach Cities EWMP (June 2021) has been drafted to meet these requirements, as set forth in the Permit. REGULATORY FRAMEWORK Watershed Management Programs (WMPs) are a voluntary opportunity afforded by the Permit for Permittees to collaboratively or individually develop comprehensive watershed-specific control plans and are intended to facilitate Permit compliance and water quality target achievement. WMPs and EWMPs also comprehensively evaluate opportunities for collaboration on multi-benefit regional projects that retain all non-stormwater runoff and runoff from the 85th percentile, 24-hour storm event while also achieving benefits associated with issues such as flood control and water supply. Additional details on the regulatory background for NPDES Permit and Water Quality Standards and the Permit specifics of WMPs and EWMPs are provided below.
NPDES PERMIT The 1972 Clean Water Act (CWA) established the NPDES Program to regulate the discharge of pollutants from point sources to waters of the United States. In 1990, the United States Environmental Protection Agency (USEPA) developed Phase I of the NPDES Stormwater Permitting Program, which established a framework for regulating municipal and industrial discharges of stormwater and non-stormwater that had the greatest potential to negatively impact water quality within waters of the United States. In particular, under Phase I, USEPA required NPDES Permit coverage for discharges from medium and large MS4 servicing populations greater than 100,000 persons. Operators of MS4s regulated under the Phase I NPDES Stormwater Program were required
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to obtain permit coverage for municipal discharges of stormwater and non-stormwater to waters of the United States. The LARWQCB designated the MS4s owned and/or operated by the incorporated cities and Los Angeles County unincorporated areas within the Coastal Watersheds of Los Angeles County as a large MS4 due to the total population of Los Angeles County. All MS4s within the Coastal Watersheds of Los Angeles County are subject to the waste discharge requirements set forth in the Permit. General permit requirements, which are relevant to and must be ensured by WMPs, include (i) a requirement to effectively prohibit non-stormwater discharges through the MS4, (ii) requirements to implement controls to reduce the discharge of pollutants to the maximum extent practicable, and (iii) other provisions the LARWQCB has determined appropriate for the control of such pollutants.
WATER QUALITY STANDARDS AND TOTAL MAXIMUM DAILY LOADS (TMDLS) The CWA also required that the LARWQCB establish water quality standards for each water body in its region. Water quality standards include beneficial uses, water quality objectives and criteria that are established at levels sufficient to protect those beneficial uses, and an anti-degradation policy to prevent degrading waters. The LARWQCB adopted a Water Quality Control Plan - Los Angeles Region (hereinafter Basin Plan) on June 13, 1994 addressing this portion of the CWA which designates beneficial uses, establishes water quality objectives, and contains implementation programs and policies to achieve those objectives for all waters in the Los Angeles Region. Pursuant to California Water Code section 13263(a), the requirements of the Permit implement the Basin Plan. The State Water Resources Control Board (State Water Board) adopted the Water Quality Control Plan for Ocean Waters in California, California Ocean Plan (hereinafter Ocean Plan) in 1972 and adopted the most recent amended Ocean Plan on February 4, 2019. The Ocean Plan also establishes water quality objectives and a program of implementation to protect beneficial uses at all MS4 discharge points within Los Angeles County coastal watersheds with the exception of Long Beach. CWA Section 303(d)(1) requires each state to identify the waters within its boundaries that do not meet water quality standards. Water bodies that do not meet water quality standards are considered impaired and are placed on the state’s “CWA Section 303(d) List”. For each listed water body, the state is required to establish a TMDL for each pollutant impairing the water quality standards in that water body. TMDLs establish the allowable pollutant loadings for a water body and provide the basis upon which to establish water quality-based controls (required by NPDES Permits). The 2014-2016 CWA Integrated Report and updated 303(d) list were approved by the State Water Resources Control Board (SWRCB) on October 3, 2017 and by the USEPA on April 6, 2018. Provisions regarding TMDLs are included in NPDES Permits once they have been developed and adopted.
STATE ORDER WQ 2020-0038 Order WQ 2020-0038, issued by the State Water Resources Control Board (State Board) on November 17, 2020, evaluated nine WMPs and one EWMP to determine whether they satisfied the standards of rigor, accountability, and transparency that were established in the MS4 Permit. Where deemed insufficient in those regards, the Order subsequently ordered the implementation of changes to appropriately satisfy those standards within an assigned schedule. Permittees were required to submit an updated Reasonable Assurance Analysis and EWMP for review and approval
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by the LARWQCB Executive Officer, including updates to bring the plans into conformance with Order WQ 2020-0038 (SWRCB, 2020). Among other requirements, Order WQ 2020-0038 required all Los Angeles area EWMPs to be updated to address the following:
• EWMPs must be clear as to which components constitute definite, enforceable benchmarks, such that failure to achieve those components means that Permittees are not fully implementing the program and must instead comply immediately with receiving water limitations and WQBELs and other TMDL-specific limitations.
• For model calibration purposes, the (E)WMPs and associated RAAs must clearly identify the information considered and how that information was used or why it was not used.
• With respect to “limiting pollutants,” Groups must justify their use of certain limiting pollutants to ensure that the use of a limiting pollutant can be reasonably expected to result in attainment of water quality standards for all the water body-pollutant combinations addressed.
• Load reductions associated with “non-modeled” controls must be justified. Permittees must not only meet the dates and requirements for implementation of non-modeled controls (to the extent that Permittees rely on them to form milestones), they must also demonstrate that they have actually achieved the assumed load reduction by the milestone date when that milestone is based entirely off non-modeled controls.
• With respect to compliance milestones and scheduling, where anticipated water quality improvements have not occurred despite implementation of the scheduled control measures, the EWMP must be updated to respond. Order WQ 2020-0038 requires these updates to be incorporated into EWMPs no later than June 30, 2021. The Revised Beach Cities EWMP has been updated to reflect these requirements.
WMPS AND ENHANCED WMPS The voluntary WMPs and EWMPs allow Permittees to collaboratively or individually develop comprehensive watershed-specific control plans which a) prioritize water quality issues, b) identify and implement focused strategies, control measures and BMPs, c) execute an integrated monitoring and assessment program, and d) allow for modification over time. In general, WMPs and EWMPs are intended to facilitate Permit compliance and water quality target achievement with the goals that: 1) discharges from covered MS4s achieve applicable WQBELs and RWLs and do not include prohibited non-stormwater discharges; and 2) control measures are implemented to reduce the discharge of pollutants to the maximum extent practicable (MEP). WMPs and EWMPs are to be developed based on the LARWQCB’s Watershed Management Areas (WMAs) or subwatersheds thereof. Permittees within a WMA may elect to prepare an EWMP, which is defined in the Permit as a WMP that comprehensively evaluates opportunities for collaboration amongst Permittees and other partners on multi-benefit regional projects that, wherever feasible, retain, 1) all non-stormwater runoff, and 2) all stormwater runoff from the 85th percentile 24 hour storm event while also achieving
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benefits associated with issues such as flood control and water supply. Where regional projects cannot achieve these standards, the EWMP must demonstrate through a Reasonable Assurance Analysis (RAA), that applicable water quality targets are achieved. The Permit specifies that an EWMP shall: 1. Be consistent with Permit provisions, 2. Incorporate applicable State agency input on priorities and key implementation factors, 3. Provide for meeting water quality standards and other CWA obligations, 4. Include multi-benefit3 regional projects which retain stormwater from the 85th percentile, 24-hour storm 5. Include watershed control measures which achieve compliance with all interim and final WQBELs in drainage areas where retention of the 85th percentile, 24-hour storm is infeasible with reasonable assurance, 6. Maximize the effectiveness of funding, 7. Incorporate effective innovative technologies, 8. Ensure existing requirements to comply with technology based effluent limitations and core requirements are not delayed, and 9. Ensure a financial strategy is in place. APPLICABILITY OF EWMP The agencies of the Beach Cities WMG have been working together since 2004 to implement the previously developed Jurisdictional Groups 5 and 6 Implementation Plan for the Santa Monica Bay Beaches Bacteria (SMBBB) TMDLs, including a BMP Siting Study (Geosyntec, 2011a) and Dry Weather Source Characterization and Control Study (Geosyntec, 2011b) for two high priority subwatersheds, along with joint implementation of programmatic solutions. Since 2004, the Beach Cities have also been jointly funding receiving water monitoring consistent with the Coordinated Shoreline Monitoring Plan for the SMBBB TMDLs along the shoreline of the Beach Cities WMG EWMP Area. These ongoing efforts by the Beach Cities WMG to comply with the SMBBB TMDLs have been an effective facilitator for the development and implementation of the EWMP. This EWMP is applicable to the Beach Cities EWMP Area, which consists of all of the incorporated MS4 areas of the cities of Redondo Beach, Manhattan Beach, Hermosa Beach, and Torrance and includes the infrastructure of the LACFCD within those jurisdictions, with the exception of the Machado Lake Watershed, which is being addressed separately by the City of Torrance, and is not addressed in this EWMP. A small portion of the City of Redondo Beach is located within the Machado Lake Watershed boundary but has successfully requested to be removed from the Machado Lake Implementation Plan and other compliance requirements pertaining to the Machado Lake Watershed.
3 Potential multiple benefits include neighborhood greening, water conservation and/or supply, groundwater recharge, public education and/or awareness, etc.
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The beach areas within the geographic area of the Beach Cities WMG do not have any storm drain infrastructure that collect and discharges beach runoff directly to the receiving water and are therefore considered non-point sources and not subject to the MS4 Permit or EWMP requirements. Similarly, the Hermosa Beach and Manhattan Beach piers are not part of the MS4; they are non-point sources excluded from the MS4 Permit scope and therefore the EWMP. The Redondo Beach Pier including the King Harbor Marina are included in the geographic scope of the Beach Cities WMG EWMP as these areas are equipped with MS4 infrastructure. The Wylie Sump is a retention basin with no outlet and capacity significantly larger than the 85th percentile, 24-hour storm event. Therefore, its drainage area has been excluded from the EWMP, with no analyses required. EWMP DEVELOPMENT PROCESS The Permit requires a stakeholder process for collaboration on EWMP development. The development process must:
• Provide appropriate opportunity for stakeholder input;
• Include participation in the Permit-wide Technical Advisory Committee (TAC); and
• Incorporate applicable State agency input on priority setting and other key implementation issues. The Beach Cities WMG has conducted outreach to engage the public, LARWQCB staff, and other interested parties to support EWMP development. Input has been incorporated, as appropriate. These efforts are described in more detail below.
Public Workshops – Original EWMP. For development of the original EWMP, public workshops were held on May 21, 2014 at the Joslyn Center in Manhattan Beach and on May 27, 2015 at the Redondo Beach Public Library. An informational presentation was provided followed by a question and answer period to encourage stakeholder input. Concerns were noted and considered during EWMP development by the Beach Cities WMG.
Technical Advisory Committee (TAC). The Beach Cities WMG actively participated in the Los Angeles region TAC and applicable subcommittees throughout the EWMP process.
LARWQCB Presentations. The Beach Cities WMG presented the proposed RAA approach to LARWQCB staff on April 9 and June 6, 2014. LARWQCB staff provided feedback during these meetings and in general they were supportive of the proposed approach. One additional meeting was held on July 31, 2014 to discuss Torrance-specific matters. In addition, the Beach Cities WMG presented the EWMP and progress on implementation to the LARWQCB in July 2018.
Public Website – Revised EWMP. As part of the revision process for the Beach Cities EWMP in 2021, the Beach Cities WMG created a website that highlighted the EWMP update process; provided details for each proposed project; and allowed for public comment to be submitted. The website was launched in May 2021.
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Public Virtual Webinar – Revised EWMP. The Beach Cities WMG held a public virtual webinar on May 19, 2021 to present the draft Revised EWMP to the Beach Cities communities and receive public input. The webinar was publicized in advance by each of the four Beach Cities.
City Council Review and Adoption. The cities of Hermosa Beach, Manhattan Beach, Redondo Beach, and Torrance each presented the draft Beach Cities EWMP (2015) and draft revised Beach Cities EWMP (2021) to their respective city councils for review and adoption. This process is open to the public, and residents are encouraged and invited to share comments related to the EWMP at these council meetings. Voiced concerns and recommendations were noted and considered for inclusion in the final EWMP and final Revised EWMP. The EWMP also addresses other State agency priorities, including the following:
California Water Action Plan (2016 Update). The California Water Action Plan proposes several statewide actions that are well aligned with the expected benefits of the proposed projects in this EWMP, including:
• Expand Water Storage Capacity and Improve Groundwater Management (infiltration BMPs): This action aims to address the need to expand the state’s storage capacity, whether in surface or groundwater to provide widespread public and environmental benefits. The California Water Action Plan states that “state agencies will work with tribes and federal, regional and local agencies on other actions related to promoting groundwater recharge and increasing storage, including improving interagency coordination, aligning land use planning with groundwater recharge...” The regional and distributed BMP projects proposed in the Beach Cities EWMP may contribute to groundwater recharge and expanding storage capacity throughout the Beach Cities WMG.
• Increase Operational and Regulatory Efficiency: Monitoring data collected under the CIMP to measure progress toward achieving RWLs and WQBELs and to determine if modifications to the Beach Cities EWMP are necessary may provide the benefit of increased operational and regulatory efficiency. Improving data availability may also improve coordination of operations of all major water supply, flood control, hatchery facilities, and habitat restoration projects.
2014 Greater Los Angeles County Integrated Regional Water Management Plan (GLAC
IRWM Plan). The goal of the GLAC IRWM Plan is to achieve sustainable management of water resources in the Greater Los Angeles County. The plan lists several regional objectives to achieve this goal. The Beach Cities EWMP contributes to some of the objectives outlined in the plan, including the following:
• Water Quality: This objective aims to comply with water quality regulations by improving the quality of urban runoff, stormwater, and wastewater. The Beach Cities EWMP contributes to this objective by proposing new distributed and regional stormwater capture opportunities in areas prioritized by statewide and regional regulations and water quality conditions.
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• Open Space and Recreation: This objective aims to protect, restore, and enhance natural process and habitats. Several of the regional EWMP projects (i.e. 28th Street Storm Drain Infiltration Project, Beach Cities Green Streets Project) provide opportunity for expanded habitat and increased green space.
STORMS Storm Water Strategy (California Water Boards, 2016). The Storm Water Strategy assists in achieving the actions identified in the California Water Action Plan, including the aforementioned action of expanding water storage capacity and improving groundwater management. The Storm Water Strategy supports efforts to improve interagency coordination and identify needs for groundwater recharge opportunity. The Storm Water Strategy also lists six overarching objectives. The Beach Cities EWMP contributes to some of these objectives, including the following:
• Increase Stakeholder Collaboration on a Watershed Scale: The Beach Cities WMG agreed to collaborate on the development of this EWMP for the Santa Monica Bay and Dominguez Channel Watershed areas within their jurisdictions to facilitate effective, watershed-specific Permit implementation strategies.
• Establish Financially Sustainable Storm Water Programs: This EWMP provides an overview of potentially available funding sources for programs and projects proposed in the EWMP. The funding sources identified for consideration are the Safe, Clean Water Program, grants, interagency partnerships, bonds, State Revolving Funds, local funding opportunities, and public private partnerships.
• Increase Source Control and Pollution Prevention: This EWMP identifies non-modeled programmatic source control BMPs that target priority pollutants.
Final Storm Water Resource Plan Guidelines (Guidelines) (December 2015). The Guidelines establish guidance for public agencies to develop Storm Water Resource Plans (Plans) consistent with Water Code sections 10561 through 10565. The Water Code states that a Plan is required as a condition to receive funding for stormwater and dry weather runoff capture projects from any bond approved by voters after January 2014, which also applies to Proposition 1 funding. The Guidelines provide guidance such as clarification on the applicability of the Guidelines, appropriate geographic scale of watersheds for stormwater resource planning, guidance on agencies and organizations to be consulted during Plan development, methods for identifying and prioritizing stormwater and runoff capture projects, project scheduling and implementation strategies, and so forth. A Self-Certified Checklist provided in the Guidelines includes a complete list of the elements of a Stormwater Resource Plan that are considered mandatory per the California Water Code. Fulfilling the mandatory requirements would make the Beach Cities WMG eligible for Proposition 1 Stormwater Grant funding which would be applied toward the proposed Beach Cities EWMP projects. The mandatory required elements highlighted in the Checklist and Self-Certification are either entirely fulfilled by the Beach Cities EWMP (including appended documents) or will be fulfilled on a project-specific basis (See Appendix I for more details on
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the Beach Cities Plan). For example, maximizing flood control will be part of detailed design at the project level. REFERENCES Beach Cities Watershed Management Group, 2014. Enhanced Watershed Management Program (EWMP) Work Plan for the Beach Cities Watershed Management Group. June. California Natural Resources Agency, the California EPA, and the California Department of Food and Agriculture, 2016. California Water Action Plan 2016 Update California Water Boards, 2016. STORMS Storm Water Strategy: Strategy to Optimize Resource Management of Storm Water. January 6. Geosyntec Consultants, 2011a. Structural BMP Siting and Conceptual Design Study, Santa Monica Bay Beaches Bacteria TMDL Implementation. Produced for SMBBB TMDL Jurisdictional Groups 5 & 6. June. Geosyntec Consultants, 2011b. Dry Weather Source Characterization and Control Summary, Santa Monica Bay Beaches Bacteria TMDL Implementation. Produced for SMBBB TMDL Jurisdictional Groups 5 & 6. June. LARWQCB, 2012a. Order No. R4-2012-0175 NPDES Permit No. CAS004001 Waste Discharge Requirements for Municipal Separate Storm Sewer System (MS4) Discharges within the Coastal Watersheds of Los Angeles County, except those Discharges Originating from the City of Long Beach MS4. November 8. State Water Resources Control Board (SWRCB), 2020. Order WQ 2020-0038. In the Matter of Review of Approval of Watershed Management Programs and an Enhanced Watershed Management Program Submitted Pursuant to Los Angeles Regional Water Quality Control Board Order R4-20120-0175. SWRCB/OCC Files A-2386, A-2477, and A-2508. November.
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Appendix B:
Water Quality
Prioritization and
Source Assessment
JUNE 2021
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WATER QUALITY PRIORITIZATION FOR THE BEACH CITIES EWMP As part of the EWMP, the Permit requires the Beach Cities WMG to identify water quality priorities within their WMA. To accomplish this, the Beach Cities WMG conducted the following for the Beach Cities EWMP Area: 1. Characterized the water quality of stormwater and non-stormwater discharges from the MS4 as well as receiving water bodies; 2. Prioritized water body-pollutant combinations (WBPCs); and 3. Assessed sources for WBPCs. This appendix summarizes the above process for the two watersheds comprising the Beach Cities EWMP Area: Santa Monica Bay (SMB) Watershed and Dominguez Channel Watershed. SANTA MONICA BAY WATERSHED The western portion of the Beach Cities EWMP Area consists of approximately 7,800 acres of land that drains to SMB. This accounts for 53% of the total Beach Cities WMG area, and includes portions of the cities of Manhattan Beach, Redondo Beach, and Torrance, and the entirety of the City of Hermosa Beach. The majority of the SMB Watershed consists of residential land uses. Table B-1 provides a land use breakdown of the Beach Cities EWMP Area by city. Land uses for this watershed are shown on Figure B-1.
Table B-1. Beach Cities EWMP Area - SMB Watershed Land Use Distribution
Agency Agriculture Commercial Education Industrial MF Residential SF Residential Vacant Total (ac) Total (%) Hermosa Beach (ac) - 130.0 16.3 13.3 254.5 380.4 51.7 846.1 10.8% Manhattan Beach (ac) - 210.6 120.5 12.8 209.4 1425.9 109.3 2088.6 26.8% Redondo Beach (ac) 25.3 312.2 150.2 99.0 717.6 1184.3 103.7 2592.3 33.2% Torrance (ac) 28.1 246.9 91.6 87.4 335.0 1359.3 125.8 2274.1 29.2% Total (ac) 53.4 899.8 378.6 212.5 1516.4 4349.9 390.5 7801.1 100% Total (%) 0.7% 11.5% 4.9% 2.7% 19.4% 55.8% 5.0% 100% -
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Figure B-1. Beach Cities WMG Land Uses within the Santa Monica Bay Watershed
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WATER QUALITY CHARACTERIZATION
Beneficial Uses The Basin Plan (LARWQCB, accessed 2021) identifies receiving waters within the Los Angeles region and sets regulatory objectives for these receiving waters. Within the SMB Watershed, identified receiving water bodies include SMB itself as well as coastal beaches within the Beach Cities WMG Area. Regulations set forth in the California Ocean Plan (SWRCB, 2019) are therefore also applicable to the SMB Watershed. Both the Basin Plan and Ocean Plan regulate 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 include:
Municipal and Domestic Supply (MUN): Uses of water for community, military, or individual water supply systems including, but not limited to, drinking water supply.
Industrial Service Supply (IND): Uses of water for industrial activities that do not depend primarily on water quality including, but not limited to, mining, cooling water supply, hydraulic conveyance, gravel washing, fire protection, or oil well re-pressurization.
Navigation (NAV): Uses of water for shipping, travel, or other transportation by private, military, or commercial vessels.
Water Contact Recreation (REC-1): Uses of water for recreational activities involving body contact with water, where ingestion of water is reasonably possible. These include, but are not limited to, swimming, wading, water-skiing, skin and scuba diving, surfing, what water activities, fishing, or use of natural hot springs.
Non-Contact Water Recreation (REC-2): Uses of water for recreational activities involving proximity to water, but not normally involving body contact with water, where ingestion of water is reasonably possible. These uses include, but are not limited to, picnicking, sunbathing, hiking, beachcombing, camping, boating, tide pool and marine life study, hunting, sightseeing, or aesthetic enjoyment in conjunction with the above activities.
High Flow Suspension (HFS): Applies to water contact recreational activities associated with the swimmable goal regulated under the REC-1 use, non-contact water recreation involving incidental water contact regulated under the REC-2 use, and the associated bacteriological objectives set to protect those activities.
Commercial and Sport Fishing (COMM): Uses of water for commercial or recreational collection of fish, shellfish, or other organisms including, but not limited to, uses involving organisms intended for human consumption or bait purposes.
Warm Freshwater Habitat (WARM): Uses of water that support warm water ecosystems including, but not limited to, preservation or enhancement of aquatic habitats, vegetation, fish, or wildlife, including invertebrates.
Marine Habitat (MAR): Uses of water that support marine ecosystems including, but not limited to, preservation or enhancement of marine habitats, vegetation such as kelp, fish, shellfish, or wildlife (e.g., marine mammals, shorebirds).
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Wildlife Habitat (WILD): Uses of water that support terrestrial ecosystems including, but not limited to, preservation and enhancement of terrestrial habitats, vegetation, wildlife (e.g., mammals, birds, reptiles, amphibians, invertebrates), or wildlife water and food sources.
Rare, Threatened, or Endangered Species (RARE): Uses of water that support habitats necessary, at least in part, for the survival and successful maintenance of plant or animal species established under state or federal law as rare, threatened, or endangered.
Migration of Aquatic Organisms (MIGR): Uses of water that support habitats necessary for migration, acclimatization between fresh and saltwater, or other temporary activities by aquatic organisms, such as anadromous fish.
Spawning, Reproduction, and/or Early Development (SPWN): Uses of water that support high quality aquatic habitats suitable for reproduction and early development of fish.
Shellfish Harvesting (SHELL): Uses of water that support habitats suitable for the collection of filter-feeding shellfish (e.g., clams, oysters, and mussels) for human consumption, commercial, or sports purposes.
Wetland Habitat (WET): Uses of water that support wetland ecosystems, including, but not limited to, preservation or enhancement of wetland habitats, vegetation, fish, shellfish, or wildlife, and other unique wetland functions which enhance water quality, such as providing flood and erosion control, stream bank stabilization, and filtration and purification of naturally occurring contaminants. According to the Ocean Plan (SWRCB, 2019), “The beneficial uses of the ocean waters of the State that shall be protected include industrial water supply (IND); water contact recreation (REC-1) and non-contact recreation (REC-2), including aesthetic enjoyment; navigation (NAV); commercial and sport fishing (COMM); mariculture; preservation and enhancement of designated Areas of Special Biological Significance (ASBS); rare and endangered species (RARE); marine habitat (MAR); fish migration (MIGR); fish spawning (SPWN) and shellfish* harvesting (SHELL).” Additional beneficial uses are defined as follows:
Mariculture: The culture of plants and animals in marine waters independent of any pollution source.
ASBS: Those areas designated by the State Water Board as ocean areas requiring protection of species or biological communities to the extent that maintenance of natural water quality is assured. ASBS are also referred to as State Water Quality Protection Areas – Areas of Special Biological Significance (SWQPA-ASBS). Table B-2 summarizes the existing beneficial uses for the Santa Monica Bay water bodies in the Beach Cities WMG Area, as designated in the Basin Plan.
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Table B-2. Beach Cities EWMP Area - SMB Water Bodies and Beneficial Uses
Water Body MUN IND NAV REC1 REC2 HFS COMM WARM MAR WILD RARE MIGR SPWN SHELL WET2 Santa Monica Bay Nearshore + Offshore1 E E E E E E E E E E E Manhattan Beach E E E E E E P E Hermosa Beach E E E E E E E3 E King Harbor E E E E E E E E Redondo Beach E E E E E E E E E E3 E Torrance Beach E E E E E E E E3 E E = Existing beneficial use 1 The Preservation of Biological Habitats (BIOL) beneficial use is not included since no Areas of Special Biological Significance are present within the Beach Cities WMG Area. 2 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. 3 Most frequently used grunion spawning beaches. Other beaches may be used as well.
SMB Watershed Data Analysis An evaluation of existing water quality conditions, including characterization of stormwater discharges from the MS4 as well as receiving water quality, was carried out as part of this EWMP revision to support identification and prioritization/sequencing of management actions, to the extent possible based on available data. To evaluate water-quality conditions within the SMB Watershed, a review of previous studies was conducted to characterize receiving water bodies within the Beach Cities WMG Area. Monitoring data analyzed were limited to water quality and flow data collected per the Beach Cities Coordinated Integrated Monitoring Program (CIMP); and bacteria data collected as part of the SMB Beaches Bacteria TMDL Coordinated Shoreline Monitoring Program (CSMP). A summary of this analysis is provided below.
WATER BODY-POLLUTANT CLASSIFICATION Receiving waters (and paired outfalls) from the Santa Monica Bay Watershed portion of the Beach Cities EWMP Area were screened for water quality priorities by reviewing TMDLs, the State’s 303(d) list, and additional water quality data. Each identified water quality priority for a given receiving water body was categorized as a waterbody pollutant combination (WBPC). WBPCs were classified into one of three categories, in accordance with the Permit.
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.” These WBPCs include: SMB beaches for bacteria (wet and dry weather): These are considered Category 1 due to the SMBBB TMDL. Although the TMDL remains in effect, both Manhattan Beach and Hermosa Beach (all Jurisdiction 5 sites) were removed from the 2014-2016 303(d) list because applicable water quality standards for the pollutant are not being exceeded.
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SMB offshore/nearshore for dichloro-diphenyl-trichloroethanes (DDTs) and polychlorinated biphenyls (PCBs): These are considered Category 1 due to the USEPA TMDL for DDT and PCBs for SMB Offshore/Nearshore. However, the TMDL relied on a limited dataset to establish stormwater load allocations, relying on a single study (Curren et al., 2011) from a single creek (Ballona Creek, which is outside the Beach Cities watershed area) to establish MS4 WLAs throughout the entire SMB Watershed. It does not present sufficient data to assign MS4 contributions to the DDT and PCB concentrations observed in SMB; therefore, direct RAA modeling for these pollutants cannot reasonably be conducted at this time without the use of a surrogate (e.g., TSS). Despite the lack of data for RAA modeling purposes, the load-based WQBELs for DDT and PCBs established by the TMDL were set to be the existing stormwater loads (i.e., based on data used in the TMDL, no MS4 load reduction is expected to be required to achieve TMDL compliance).1 Therefore, it is assumed that no reductions in DDT and PCB loading from the Beach Cities WMG MS4s are required to meet the TMDL and reasonable assurance of compliance is assumed to be demonstrated without modeling. As discussed below, monitoring data conducted to-date per the Beach Cities CIMP confirms this assumption, as 27 discrete outfall sample events have resulted in no exceedances of either the DDT or total PCBs numeric targets. SMB Offshore/Nearshore is 303(d)-listed for fish consumption advisory due to DDT and PCBs. Therefore, the fish consumption advisory will be assumed to be addressed by the DDT and PCB categorization. SMB Offshore/Nearshore was previously 303(d) listed for toxicity, but USEPA's data evaluation showed only 3 out of 116 samples exhibited toxicity (USEPA, 2012). The WBPC was removed from the 2014-2016 303(d) list. SMB offshore/nearshore for debris: This is considered Category 1 due to the TMDL for Debris for SMB Offshore/Nearshore. The Permit states, “Pursuant to California Water Code section 13360(a), Permittees may comply with the trash [debris] effluent limitations using any lawful means. Such compliance options are broadly classified as full capture, partial capture, institutional controls, or minimum frequency of assessment and collection… and any combination of these may be employed to achieve compliance.” While trash was not modeled as part of the RAA, the RAA qualitatively described how the Beach Cities WMG Agencies will comply with the SMB Debris TMDL WQBELs by stating the following: “Compliance with the SMB Debris TMDL will be met through a phased retrofit of full-capture or partial capture systems throughout Beach Cities Santa Monica Bay WMA in combination with institutional measures, e.g., street sweeping with posted no-parking on street sweeping days, to meet each interim and
1 The TMDL states, “Because existing stormwater loads from the watersheds are lower than the calculated total allowable loads to achieve sediment targets, the waste load allocations for stormwater in this TMDL are based on existing load estimates of 28 g/yr for DDT and 145 g/yr for PCBs.” These WLAs are further divided among Los Angeles County MS4, CalTrans, the Construction General Permit, and the Industrial General Permit. The assigned WLAs for the entire LA County MS4 within the Santa Monica Bay Watershed is 27.08 g/yr for DDT and 140.25 g/yr for PCBs, which are equivalent to the TMDL-estimated existing MS4 stormwater loads.
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final compliance deadline. Hence, these constituents do not require a TLR to be calculated and were not modeled as part of the revised RAA” (Beach Cities EWMP, 2021). “Highest Priority” WBPCs have been assigned based strictly on the Permit definition. Not all of these pollutants (e.g., DDT and PCBs) have been definitively linked to MS4 sources. As a result, this categorization and prioritization will continue to be reevaluated based on results from the water quality monitoring efforts conducted under the CIMP.
Category 2 – High Priority WBPCs under Category 2 (high priority) are defined in the Permit 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, 2015) and for which MS4 discharges may be causing or contributing to the impairment.” The following Category 2 WBPCs have been identified in the SMB Watershed portion of the Beach Cities EWMP Area based on the 2016 303(d) list: SMB offshore/nearshore for Mercury: Although listed on the 2016 303(d) list, no data is available linking MS4 discharges from the Beach Cities EWMP Area with mercury exceedances in Santa Monica Bay. Rather, the listing was based on a limited set of fish tissue and sediment sampling data collected under the City of Los Angeles Hyperion Wastewater Treatment Plant NPDES permit. Two (2) of thirty-two (32) sediment samples exceeded the Basin Plan narrative objective for mercury based on the effects range median for saline waters (predictive of sediment toxicity) for mercury of 0.71 mg/Kg dry weight (Long et. al., 1995). In addition, two (2) of nineteen (19) fish tissue samples exceeded the OEHHA fish contaminant goal of 0.22ppm (Klasing et. al., 2008). This data was collected during 2006 and 2007, more than ten years ago. Since the listing was finalized, mercury has been added to the Beach Cities CIMP suite of analytes for Santa Monica Bay. To-date, mercury has been analyzed through the Beach Cities CIMP during the past three years, comprising a total of 15 wet weather outfall samples and 18 wet weather receiving water samples. No exceedances of the Ocean Plan Target (0.4 ug/L) have occurred. Therefore, it is assumed that no reductions in mercury loading from the Beach Cities WMG MS4s is required to meet the Ocean Plan target and reasonable assurance of compliance is assumed to be demonstrated without modeling. The Beach Cities WMG will continue to monitor for mercury in accordance with their CIMP and will revise their WBPC list, as applicable, based on evaluation of the data. SMB offshore/nearshore for Arsenic: Although listed on the 2016 303(d) list, no data is available linking MS4 discharges from the Beach Cities EWMP Area with arsenic exceedances in Santa Monica Bay. Rather, the listing was based on a limited set of fish tissue sampling data collected under the City of Los Angeles Hyperion Wastewater Treatment Plant NPDES permit. Nineteen (19) of 19 fish tissue samples collected in the Santa Monica Bay exceeded the USEPA Guidance for Assessing Chemical Contaminant Data for Use in Fish Advisories Volume 1: Fish Sampling and Analysis for arsenic in fish tissue of 0.0034 ppm (USEPA, 2000). This data was collected during 2006 and 2007, more than ten years ago. Since the listing was finalized, arsenic has been added to the Beach Cities CIMP suite of analytes for Santa Monica Bay. To-date, arsenic has been analyzed through the Beach Cities CIMP during the past three years, comprising a total of 15
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wet weather outfall samples and 18 wet weather receiving water samples. No exceedances of the Ocean Plan Target (80 ug/L) have occurred. Therefore, it is assumed that no reductions in arsenic loading from the Beach Cities WMG MS4s is required to meet the Ocean Plan target and reasonable assurance of compliance is assumed to be demonstrated without modeling. The Beach Cities WMG will continue to monitor for arsenic in accordance with their CIMP and will revise their WBPC list, as applicable, based on evaluation of the data.
Category 3 – Medium Priority WBPCs under Category 3 (medium priority) are defined in the Permit as, ”Pollutants for which there are insufficient data to indicate water quality impairment in the receiving water according to the State’s Listing Policy, but which exceed applicable RWLs contained in this Order and for which MS4 discharges may be causing or contributing to the exceedance.” The Beach Cities WMG has been collecting outfall and paired receiving water data in the SMB Watershed per their approved CIMP since 2016. Implementation of the CIMP has resulted in the successful monitoring of 15 wet weather events to-date, with two outfall sites and two receiving water sites monitored per event. Through June 2020, no water quality impairments (besides those discussed above) have been identified. As a result, there are no Category 3 WBPCs in the SMB Watershed portion of the Beach Cities EWMP Area. The Beach Cities agencies understand that additional data collected as part of their approved CIMP may result in modifications to WBPCs and water quality priorities. Under these conditions, the Beach Cities EWMP will be updated. Figure B-2 provides a brief conceptual overview of the process used to identify and categorize the WBPCs within the Beach Cities EWMP Area.
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Figure B-2. Process for Categorizing Water Body-Pollutant Combinations
S OURCE ASSESSMENT The following data sources were reviewed as part of the updated source assessment for the WBPCs listed previously:
• Findings from the Permittees’ Illicit Connections and Illicit Discharge Elimination Programs (IC/ID);
• Findings from the Permittees’ Industrial/Commercial Facilities Programs;
• Findings from the Permittees’ Development Construction Programs;
• Findings from the Permittees’ Public Agency Activities Programs;
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• TMDL source investigations;
• Watershed model results;
• Findings from the Permittees’ monitoring programs, including but not limited to, CIMP and TMDL compliance monitoring; and
• Any other pertinent data, information, or studies related to pollutant sources and conditions that contribute to the highest water quality priorities. The following source assessment is broken down by pollutants applicable to the SMB Watershed.
Indicator Bacteria The Santa Monica Bay Beaches Bacteria (SMBBB) TMDLs for dry and wet weather were the first bacteria TMDLs adopted by the LARWQCB. The SMBBB TMDLs were opened for reconsideration in 2012 and recently in 2021, although the source assessment was not part of these updates. As a result, the general findings from the original source assessment remain unchanged. These findings are summarized in the 2012 Basin Plan Amendment for the reopened SMBBB TMDL (Attachment A to Resolution No. R12-007): “With the exception of isolated sewage spills, dry weather urban runoff and stormwater runoff conveyed by storm drains and creeks is the primary source of elevated bacterial indicator densities to SMB beaches” (LARWQCB, 2012b). The SMBBB TMDL source assessment (LARWQCB, 2002) maintained that dry weather urban runoff and stormwater runoff were the primary sources of elevated bacteria concentrations at SMB beaches at the time of the TMDL. Although definitive information regarding the specific sources of bacteria within the watershed was not presented, speculation provided in the dry weather staff report provided some insight into possible sources at the time: “Urban runoff from the storm drain system may have elevated levels of bacterial indicators due to sanitary sewer leaks and spills, illicit connections of sanitary lines to the storm drain system, runoff from homeless encampments, illegal discharges from recreational vehicle holding tanks, and malfunctioning septic tanks among other things. Swimmers can also be a direct source of bacteria to recreational waters. The bacteria indicators used to assess water quality are not specific to human sewage; therefore, fecal matter from animals and birds can also be a source of elevated levels of bacteria, and vegetation and food waste can be a source of elevated levels of total coliform bacteria, specifically” (LARWQCB, 2002). Information on non-MS4 sources of surf zone bacteria along specific SMB beaches was provided by the City of Malibu in its comment letter on the SMBBB TMDL reconsideration, based on a comprehensive review of local and Southern California source identification studies (City of Malibu, 2012): “A number of recent Santa Monica Bay studies have further identified and confirmed natural (non-anthropogenic) sources of fecal indicator bacteria including plants, algae, decaying organic matter, beach wrack and bird feces – implicating these as potentially significant contributors to exceedances (Imamura et al 2011, Izbicki 2012b). Beach sands, sediments and
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beach wrack have been shown to be capable of serving as reservoirs of bacteria, possibly by providing shelter from UV inactivation and predation by allowing for regrowth (Imamura et al 2011, Izbicki et al 2012b, Lee et al 2006, Ferguson et al 2005, Grant et al 2001, Griffith 2012, Litton et al 2010, Phillips et al 2011, Jiang et al 2004, Sabino et al 2011, and Weston Solutions 2010). In fact, enterococci include non-fecal or “natural” strains that live and grow in water, soil, plants and insects (Griffith, 2012). Thus, elevated levels of enterococci in water could be related to input from natural sources. The phenomenon of regrowth of bacteria from either anthropogenic or natural sources has been suggested by several studies as a possible source of beach bacteria exceedances (Griffith 2012, Litton et al 2010, Weston Solutions 2010, Izbicki
et al 2012b, Weisberg et al 2009).” To address the identification of dry weather bacteria sources within or to the MS4s, the Beach Cities WMG agencies have implemented measures to divert dry weather flows from all storm drains discharging at point zero shoreline monitoring locations. A total of eight low flow diversions are operational within the Beach Cities EWMP area, and have proven to be effective at diverting dry weather flows from reaching the wave wash. Wet weather bacteria sources are believed to be derived from the entire watershed, and potentially include a mixture of human sources, non-human anthropogenic sources (e.g., pet waste), and non-anthropogenic sources (e.g., birds and other urban wildlife, storm drain biofilms/regrowth, beach sands and wrack). A wet weather stormwater monitoring study by the Southern California Coastal Water Research Project (SCCWRP) investigated bacteria concentrations in stormwater runoff from various land uses in the Los Angeles region (Stein et al, 2007). Results showed that wet weather runoff event mean concentrations (EMCs) for fecal coliform bacteria were highest for agricultural land uses, followed by commercial and educational, single family residential, multi-family residential, open space, industrial, and transportation. In this study, results showed that bacteria concentrations in stormwater are highly variable, with concentrations often varying by one to two orders of magnitude during a single storm, and by up to five orders of magnitude on seasonal and inter-annual scales. CIMP data collected by the Beach Cities at various outfalls over the past five years confirms that FIB concentrations within MS4 discharges during wet weather are higher than applicable objectives. However, these results do not distinguish between sources or human health risk. In 2019, the Beach Cities WMG initiated a screening-level microbial source tracking (MST) investigation at targeted outfalls to determine if human, dog, and bird waste was a source of fecal indicator bacteria (FIB) in MS4 discharges, and therefore potentially of FIB in the surf zone during discharge events. The investigation was focused on two Santa Monica Bay Beaches Bacteria TMDL (SMBBB TMDL) shoreline monitoring locations (antidegradation sites SMB 6-2 and SMB 6-5), including the storm drain network tributary to these locations. Preliminary results from these investigations, which include both dry and wet weather sample events, indicate that both dogs and illicit connections/discharges may be two significant sources of bacteria to the MS4 outfalls. As a result of these findings, programmatic controls such as a robust illicit connection and discharge
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detection and elimination program as well as dog waste outreach programs may have a significant impact on FIB loads within Santa Monica Bay.
DDT and PCBs The Palos Verdes Shelf portion of Santa Monica Bay is an active EPA Superfund site that is subject to Superfund Remedial Action Objectives which include institutional controls, natural recovery, capping, and monitored attenuation, and are expected to result in improved water quality (USEPA, 2012). From 1947 to 1971, large quantities of DDT were discharged from the Montrose Chemical plant in Los Angeles to the Los Angeles County Joint Water Pollution Control Plant (JWPCP), which discharges to the Palos Verdes Shelf. PCBs also entered the JWPCP from several industrial sources in the Los Angeles area. These DDT and PCBs discharges passed through the JWPCP and were deposited on the Palos Verdes Shelf. There have also been reports of recently discovered illegal offshore dumping of waste barrels containing DDT acid sludge between Catalina Island and the Palos Verdes coast.2 There is also concern that the rate of erosion on the southwest portion of the Palos Verdes Shelf could bring previously buried deposits to the surface. Concentrations of DDT and PCBs deposited in the surface sediments of the Santa Monica Bay have decreased substantially since the early 1970s and during this time period the benthic communities in the Palos Verdes shelf and Santa Monica Bay have improved substantially to the point where impairments to benthic communities are not seen; however, DDT and PCBs are still present at levels of concern for bioaccumulation and human health (USEPA, 2012). This contamination of DDT and PCBs in the sediments of Santa Monica Bay, largely centered on the Palos Verdes shelf, has led to a large number of fish advisories for much of Santa Monica Bay and a commercial fishing ban in the area around the Palos Verdes Shelf. As a result, the USEPA issued the Santa Monica Bay DDT and PCBs TMDL in 2012 and the TMDL objectives were established to meet fish concentrations for human consumption. With respect to stormwater, the TMDL does not specifically characterize MS4 loadings, though it does recognize that “DDT and PCBs are no longer detected in routine stormwater sampling from Ballona Creek or Malibu Creek.” Since initiation of implementation of the Beach Cities CIMP in 2016, 15 total storm events have been monitored at a combination of different outfall and receiving water sites across the Beach Cities Area in the Santa Monica Bay Watershed. In total, 27 outfall-specific sample events have taken place over that time.3 During no event has an exceedance of either the DDT or total PCBs numeric targets occurred.
2 https://www.latimes.com/projects/la-coast-ddt-dumping-ground/#nt=1col-7030col1-mainnt=00000173-4a29-dafc-a977-dabb7b330001-liA9promoSmall-1col-7030col1-main
3 The Beach Cities CIMP requires a rotation of outfalls to be utilized for water quality monitoring. Additionally,
prior to the 2019-2020 monitoring year, two outfall sites were combined into a single outfall monitoring site. As a
result, some years now include monitoring at two outfalls, while other years include monitoring at only one outfall.
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Trash Source information for trash within SMB is provided by the SMB Nearshore Debris TMDL. A detailed source breakdown is not provided, but other debris TMDLs attribute trash to general areas such as “litter from adjacent land areas, roadways, and direct dumping and deposition” (LARWQCB, 2008) while also attributing trash inputs to point sources such as storm drains. The plastic pellet portion of the SMB Debris TMDL is not applicable to the Beach Cities WMG, as the respective Agencies have applied and have gained approval to be exempt from this portion of the TMDL.
Arsenic and Mercury As stated previously, Santa Monica Bay was recently added to the State’s 2014/16 and draft 2018 303(d) list as being impaired by arsenic and mercury based on sediment and fish tissue data. There is currently no data tying these impairments to MS4 discharges from the Beach Cities WMG. Since these listings were first finalized, mercury and arsenic have been added to the Beach Cities CIMP suite of analytes for Santa Monica Bay. To-date, both constituents have been analyzed during nine wet weather sample events at two receiving water monitoring locations and a total of three (rotating) outfalls. No exceedances of the Ocean Plan Target for mercury (0.4 ug/L) or arsenic (80 ug/L) have occurred across these events in either the outfall discharges (15 discrete samples) or receiving water samples (18 discrete samples).
WBPC PRIORITIZATION Based on the water quality characterization above, the WBPCs have been classified into one of three categories, in accordance with the Permit: highest priority, high priority, and medium priority. This categorization is intended to prioritize WBPCs in order to guide the implementation of structural and institutional BMPs. Table B-3 presents the prioritized WBPCs within the SMB Watershed portion of the Beach Cities EWMP Area. WBPCs categorized below are subject to change based on future data collected as part of the CIMP or other monitoring program.
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Table B-3. Water Body-Pollutant Combination Prioritization and Pollutant Interim and Final Compliance Targets for Santa
Monica Bay Watershed Portion of the Beach Cities EWMP Area
Category Water
Body Pollutant Reason for Categorization WLA/Target Basis Interim TMDL WLA Final TMDL WLA or Other
Target
1: Highest Priority
Santa Monica Bay Beaches
Dry Weather Bacteria SMB Beaches Dry Weather Bacteria TMDL Daily and Weekly Sampling Schedule N/A Summer-Dry Single Sample Allowable Exceedance Days (AED)1 met Winter-Dry period Single Sample AED1 met Wet Weather Bacteria SMB Beaches Wet Weather Bacteria TMDL Daily and Weekly Sampling Schedule 50% cumulative percentage reduction from total required exceedance day reduction2
Single Sample and Geometric Mean AED1 and GM target met
Santa Monica Bay
Trash/ Debris SMB Debris TMDL Annual monitoring Incremental reduction from baseline waste load allocation3 (6815.6 gals/year)
100% reduction from baseline waste load allocation3 (6815.6 gals/year) DDTs SMB PCBs and DDT TMDL 3-Year Average N/A 27.08 g/year4 PCBs SMB PCBs and DDT TMDL 3-Year Average N/A 140.25 g/year4 2: High Priority Santa Monica Bay Mercury 2016 303(d) list Single Sample Exceedance N/A 0.4 ug/L5 Arsenic 80 ug/L5 3: Medium Priority Analysis of monitoring data from outfalls and receiving waters do not currently result in the identification of any Category 3 WBPCs
1 Per the Basin Plan Objective REC1 Water Bodies Limit for Bacteria. Please refer to the latest version of the MS4 Permit for allowable exceedance day limits of each subwatershed. 2 Total required exceedance day reduction is defined as the difference between existing exceedance day and the allowable exceedance day for each subwatershed 3 Baseline WLA is the sum of baseline WLA from Manhattan Beach, Redondo Beach and Hermosa Beach 4 This limit is applicable to all of Santa Monica Bay. 5 Ocean Plan target.
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DOMINGUEZ CHANNEL WATERSHED The northeastern portion of the Beach Cities EWMP Area is tributary to Dominguez Channel 4 (including Torrance Carson Channel) and is comprised of approximately 7,024 acres of land, the majority of which is comprised of residential land uses (29.6% single family residential and 10.1% multi-family residential). Industrial land use is the second highest category in the watershed, accounting for 24.9% of all land uses in the watershed. This watershed accounts for 47% 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 the freshwater portion of Dominguez Channel. The City of Torrance’s MS4 discharges directly to Dominguez Channel (freshwater) and Torrance Carson Channel (Torrance Lateral). Collectively, this portion of the study area is referred to as the Dominguez Channel Watershed. Table B-4 provides a land use breakdown of the Beach Cities EWMP Area by city. Compared to the SMB Watershed within the Beach Cities Area, the Dominguez Channel Watershed has significantly lower residential land use (39.7% compared with 75.2% in the SMB Watershed) and significantly higher industrial land use (24.9% compared with 2.7%). Land uses for this watershed are shown on Figure B-3.
Table B-4. Beach Cities EWMP Area – Dominguez Channel Watershed Land Use Distribution
Agency Agriculture Commercial Education Industrial MF Residential SF Residential Transportation Vacant Total (ac) Total (%) Manhattan Beach (ac) - 109.3 - 77.5 51.0 68.5 - 56.8 363.0 4.7% Redondo Beach (ac) 11.3 225.6 15.7 199.5 458.2 259.6 22.2 59.7 1251.8 16.0% Torrance (ac) 94.8 763.4 243.6 1667.3 276.3 1978.4 96.6 288.4 5408.8 69.3% Total (ac) 106.1 1098.3 259.2 1944.3 785.5 2306.5 118.8 404.8 7023.6 100% Total (%) 1.4% 14.1% 3.3% 24.9% 10.1% 29.6% 1.5% 5.2% 100%
4 Other portions of the Dominguez Channel Watershed, including Los Angeles County Unincorporated areas, are addressed by separate EWMP groups.
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Figure B-3. Beach Cities WMG Land Uses within the Dominguez Channel Watershed
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WATER QUALITY CHARACTERIZATION
Beneficial Uses As discussed previously, the Basin Plan (LARWQCB, accessed 2021) 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 Dominguez Channel Watershed Area are summarized in Table B-5 below.
Table B-5. Beach Cities EWMP Area – Dominguez Channel Watershed Water Bodies and
Beneficial Uses
Water Body MUN NAV REC1 REC2 HFS COMM WARM EST MAR WILD RARE MIGR SPWN SHELL WET3 Dominguez Channel P1 P E E P P E Torrance Lateral2 P1 P E E P P E Dominguez Channel Estuary P E E E E E E E E 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.
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 Beach Cities CIMP and the Mass Emission Station monitoring program established by the Los Angeles County Department of Public Works (LACDPW). The Beach Cities WMG has been collecting outfall data in the Dominguez Channel Watershed per their approved CIMP since 2016. Implementation of the CIMP has resulted in the successful monitoring of 15 wet weather events to-date, with two outfall sites monitored per event. Paired
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receiving water data are collected and analyzed from two relevant monitoring stations by other agencies: 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.
WATER BODY-POLLUTANT CLASSIFICATION Receiving waters (and paired outfalls) 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 the Permit. Figure B-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.” These WBPCs include: Dominguez Channel (above Vermont Avenue) 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 is not directly tied to any single pollutant or group of pollutants that can be readily modeled; rather, it is the result of a wide-array of loading from multiple pollutants from various sources. Additionally, toxicity monitoring since 2016 has shown no exceedances of applicable water standards at Dominguez Channel Mass Emissions Station or within Torrance Lateral. As a result, toxicity was not modeled as part of the revised EWMP RAA, consistent with the original EWMP. It is assumed that the implementation of various BMPs and resultant control of other pollutants of concern will sufficiently address in-channel toxicity. Dominguez Channel Estuary (Dominguez Channel below Vermont Ave) for copper, lead, zinc, cadmium, DDT, PAHs, and PCBs: These WBPCs are considered Category 1 due to the Dominguez Channel Toxics TMDL (LARWQCB, 2011). Copper, lead, and zinc were modeled in the latest iteration of the RAA utilizing calibrated pollutant runoff concentrations in WMMS 2.0. Other pollutants (cadmium, DDT, PAHs, and PCBs) were modeled using TSS as a surrogate, based on collected water quality data at the upstream Beach Cities outfalls.
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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, 2015) 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 Estuary for indicator bacteria. This qualifies as a Category 2 WBPC based on the 303(d) listing for indicator bacteria.
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. As mentioned previously, the Beach Cities WMG has been collecting outfall data in the Dominguez Channel Watershed per their approved CIMP since 2016, with paired downstream receiving water data collected by other agencies. Implementation of the CIMP has resulted in the successful monitoring of 15 wet weather events to-date, with two outfall sites and two receiving water sites monitored per event. Through June 2021, only a single water quality impairment (besides those discussed above) has been identified: Dominguez Channel Freshwater (not including Torrance Lateral) for Benzo(a)pyrene. This qualifies as a Category 3 WBPC based on historical exceedance of applicable receiving water limits (California Toxic Rule Human Health Criteria) where MS4 discharges may be causing or contributing to the exceedance. The Beach Cities agencies understand that additional data collected as part of their approved CIMP may result in modifications to WBPCs and/or water quality priorities. Under these conditions, the Beach Cities EWMP will be updated. Figure B-2 provides a brief conceptual overview of the process used to identify and categorize the WBPCs within the Beach Cities EWMP Area.
S OURCE 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;
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• Findings from the Permittees’ Industrial/Commercial Facilities Programs;
• Findings from the Permittees’ Development Construction Programs;
• Findings from the Permittees’ Public Agency Activities Programs;
• TMDL source investigations;
• Watershed model results;
• Findings from the Permittees’ monitoring programs, including but not limited to, CIMP monitoring and TMDL compliance monitoring; and
• Any other pertinent data, information, or studies related to pollutant sources and conditions that contribute to the highest water quality priorities. As stated earlier, the Dominguez Channel Watershed has significantly more industrial land use than the Santa Monica Bay Watershed (1,944 acres in Dominguez Channel vs 212 acres in SMB), and as a result, has some notably different pollutant sources when compared to the Santa Monica Bay Watershed. The following source assessment is broken down by pollutants applicable only to the Dominguez Channel Watershed.
Copper, Lead, Zinc, and Cadmium The Dominguez Channel Toxics TMDL (which applies to wet weather only) provides general information on sources of metals within the Dominguez Channel Watershed but does not provide a detailed source assessment. The TMDL states that “the major pollutant sources of metals into Dominguez Channel and Torrance Lateral freshwaters are stormwater and urban runoff discharges. Nonpoint sources include atmospheric deposition” (LARWQCB and USEPA, 2011). SCCWRP conducted a detailed study of various wet weather pollutants throughout the Los Angeles region, including Dominguez Channel (Stein et al., 2007). They found that industrial land use sites contributed a substantially higher flux of copper and zinc compared to other land uses evaluated, followed by agriculture, recreational, transportation (for copper), and high density residential (for zinc). Wet weather EMCs for copper and zinc, based on the Los Angeles County land use EMC dataset (Geosyntec Consultants, 2012) were similar to SCCWRP’s findings, showing that the highest runoff concentrations are expected from industrial, transportation, and commercial land uses, excluding agriculture. With respect to copper, research has shown that brake pads are a significant source of copper in urban stormwater (TDC Environmental, 2013). Copper and other pollutants are deposited on roads and other impervious surfaces and then transported to aquatic habitats via stormwater runoff. Pollutant loads of copper from urban land uses is expected to decrease due to Senate Bill (SB) 346 which was signed into law on September 25, 2010. This legislation phases out copper in vehicle brake pads over a period of years; milestones include the following dates:
• January 1, 2021: Limits the use of copper in motor vehicle brake pads to no more than five percent by weight; and
• January 1, 2025: Limits the use of copper in motor vehicle brake pads to no more than 0.5 percent by weight.
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A separate study focusing on zinc showed that the major sources of zinc in urban runoff are outdoor zinc surfaces (including galvanized surfaces) and tire wear debris (TDC Environmental, 2013). Cadmium has similar sources, including tires and engine parts, as well as gasoline, antifreeze, and diesel oil. One study found that tire wear accounts for over 50 percent of the total cadmium and zinc loads in urban runoff (David et. al., 2001). For lead, SCCWRP found that the greatest land use contributors were agricultural (minimal in Dominguez Channel Watershed), high density residential, and recreational (horse) land uses (Stein et al., 2007). Based on the Los Angeles County land use EMC dataset (Geosyntec Consultants, 2012), the highest lead contributing land uses are agriculture, industrial, commercial, and single family residential. Lead was also formerly used as an additive in gasoline and is still used in general aviation gasoline (Avgas) for small piston-engine aircraft. According to Federal Aviation Administration (FAA), Avgas emissions are the largest contribution to relatively low levels of lead emission in the U.S. (FAA, 2015). This has contributed to the contamination of some soils near highways and streets and in drainage ways in urban areas. Exhaust particulates, fluid losses, drips, spills, and mechanical wear products continue to contribute lead to street dust. For both copper and lead, the SCCWRP and Los Angeles County datasets indicate that average EMCs exceed applicable CTR continuous concentration criteria for each land use sampled. For zinc, some land uses (single family residential, education, and vacant) have average EMCs below the CTR continuous concentration criterion, while others (commercial, industrial, transportation, multi-family residential, and agriculture) exceed this criterion. These land use EMC datasets were used to support BMP placement as part of the RAA. Significantly, monitoring results collected as part of the Beach Cities CIMP demonstrate that lead levels within Beach Cities discharges are meeting final TMDL limits.
Toxicity As is the case with metals, the Dominguez Channel Toxics TMDL does not provide a detailed source assessment for toxicity within the Dominguez Channel Watershed, nor is a linkage provided to other specific surrogate pollutants, such as total suspended solids or dissolved metals. The source assessment simply states that “the major sources of organo-chlorine pesticides [and] PCBs…into Dominguez Channel are stormwater and urban runoff discharges. Nonpoint sources include atmospheric deposition and fluxes from contaminated sediments into the overlying water” (LARWQCB and USEPA, 2011). Pesticides are used in urban settings for structural pest control, landscape maintenance (parks, golf courses, cemeteries, and rights-of-way), vector control, and public health pest control. Two specific pesticides, diazinon and chlorpyrifos, were banned by the USEPA on December 31, 2005. As a result, mass emission monitoring at S28 has resulted in no measured exceedance of the 1 toxicity unit criteria for chlorpyrifos or diazinon in Dominguez Channel since 2006. Similarly, both DDT and PCBs were banned from general production and use in the 1970s, resulting in the elimination of active discharges of these chemicals to Dominguez Channel, SMB, and other local surface water bodies, except from residuals present from legacy sources.
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Toxicity monitoring has been conducted by other agencies in the Dominguez Channel to help assess if MS4 discharges are causing or contributing toxicity exceedances in Dominguez Channel. To date, no toxicity exceedances have occurred within Dominguez Channel or Torrance Lateral receiving waters. As a result, a toxicity identification evaluation (TIE) has not been necessary for the Beach Cities WMG.
Indicator Bacteria Although the Dominguez Channel is 303(d) listed for indicator bacteria, a bacteria TMDL has not yet been developed for the watershed. E. coli data collected at outfalls as part of the Beach Cities CIMP indicates that bacteria levels are consistently higher than applicable standards during storm events. The source assessment for indicator bacteria within the Santa Monica Bay watershed portion of the Beach Cities EWMP area is provided above, and many of these urban anthropogenic and non-anthropogenic sources apply to the Dominguez Channel portion of the Beach Cities EWMP Area as well.
Organochlorine Pesticides (DDT) Organochlorine pesticides (OC pesticides) are a large group of legacy pesticides, including DDT, that were previously used widely throughout the United States. Even though they have been banned from use for many years, they are slow to degrade and continue to persist in the environment. Because of their chemical and physical properties, these pollutants tend to partition and bind preferentially to the surfaces of soil particles. When transported in stormwater-borne sediment to local receiving waters, OC pesticides have been shown to accumulate in the fatty tissue of fish and wildlife and bio-magnify in the food-web. DDT was used widely in the U.S. between 1939 and 1970 as a pesticide. In 1963, DDT was declared a restricted material in California. The last year that substantial amounts of DDT were applied in California was 1970 when 1.2 million pounds of DDT were applied primarily to agricultural areas (LARWQCB, 2010). Considering the ubiquitous use of DDT from 1939 through 1970 and understanding the history of land use and development within the Dominguez Channel Watershed, it is reasonable to expect that DDT was used in residential applications and that DDT and its breakdown products, DDE and DDD, may remain in soils within the watershed. However, outfall sampling data conducted to-date under the Beach Cities CIMP has not led to any detectable quantities of DDT in stormwater runoff.
Polychlorinated Biphenyls (PCBs) Polychlorinated biphenyls (PCBs) are mixtures of synthetic organic chemicals that were commonly used for various applications from approximately 1929 until 1979 when the U.S. banned PCB manufacturing, processing, distribution, and use. PCBs may be present in products that were made before 1977 but are still in use today, such as transformers, fluorescent lighting fixtures, household caulking, paints and waxes (USEPA, 2012). U.S. EPA identifies the following list of products and materials that, if produced and installed prior to the 1979 ban, may still contain PCBs:5
5 https://www.epa.gov/pcbs/learn-about-polychlorinated-biphenyls-pcbs#commercial
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• Transformers and capacitors
• Electrical equipment including voltage regulators, switches, re-closers, bushings, and electromagnets
• Oil used in motors and hydraulic systems
• Old electrical devices or appliances containing PCB capacitors
• Fluorescent light ballasts
• Cable insulation
• Thermal insulation material including fiberglass, felt, foam and cork
• Adhesives and tapes
• Oil-based paint
• Caulking
• Plastics
• Carbonless copy paper
• Floor finish The industrial nature of a significant portion of the Dominguez Channel Watershed implies that most of these may continue to be sources of PCBs in stormwater, with the most significant contributions likely coming from external building materials such as caulk or paint or in utility transformers. However, outfall sampling data conducted to-date under the Beach Cities CIMP has not led to any detectable quantities of PCBs in stormwater runoff.
Polycyclic Aromatic Hydrocarbons (PAHs) Including Benzo(a)pyrene Polycyclic aromatic hydrocarbons (PAHs) are a group of organic contaminants that are associated with the release of petroleum products (petrogenic sources) or form from the incomplete combustion of hydrocarbons (pyrogenic sources). PAHs are an environmental concern because they are toxic to aquatic life and because several of the individual PAH compounds are suspected human carcinogens. Research has shown that the dominant source of origin is pyrogenic (combustion of organic matter) in the Los Angeles Region, and PAHs are often deposited through atmospheric deposition and delivered to waterbodies in stormwater runoff (Sabin et al., 2009). Other non-point sources may include leaking motor oil, tire wear, and vehicular exhaust.
PRIORITIZATION Based on the water quality characterization above, the WBPCs have been classified into one of three categories, in accordance with the Permit: highest priority, high priority, and medium priority. This categorization is intended to prioritize WBPCs in order to guide the implementation of structural and institutional BMPs. An RAA was performed on the WBPCs in Categories 1, 2, and 3. Table B-6 summarizes the prioritized WBPCs within the Dominguez Channel Watershed portion of the Beach Cities EWMP Area.
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Table B-6. WBPC Prioritization and Pollutant Interim and Final Compliance Targets for Dominguez Channel Watershed
Category Water Body Pollutant Reason for
Categorization WLA/Target Basis Interim TMDL WLA Final TMDL WLA or
Other Target
1: Highest Priority
Dominguez Channel Freshwater[1]
Toxicity
Dominguez Channel Toxics TMDL
Monthly Average 2 TUc [2] 1 TUc Total Copper Wet Weather Single Event 207.51 ug/L[2] 9.7 ug/L[3] Total Lead Wet Weather Single Event 122.88 ug/L[2] 42.7 ug/L[3] Total Zinc Wet Weather Single Event 898.87 ug/L[2] 69.7 ug/L[3]
Dominguez Channel Estuary (including Torrance Lateral)
Total Copper Annual Average 220 mg/kg sediment[2] 31.6 mg/kg sediment 22.4 kg/yr[4] Total Lead Annual Average 510.0 mg/kg sediment[2] 35.8 mg/kg sediment 54.2 kg/yr [4] Total Zinc Annual Average 789.0 mg/kg sediment[2] 121 mg/kg sediment 271.8 kg/yr[4] Cadmium Daily Maximum n/a 1.2 mg/kg sediment DDT Annual Average 1.727 mg/kg sediment[2] 0.25 g/yr[4] Total PAHs Annual Average 31.60 mg/kg sediment[2] 0.134 kg/yr[4] PCBs Annual Average 1.490 mg/kg sediment[2] 0.207 g/yr [4]
2: High Priority
Dominguez Channel (including Torrance Lateral) and Dominguez Channel Estuary
Indicator Bacteria 303(d) List Exceedance Rate over 30-day Period n/a See Footnote 5
3: Medium Priority Dominguez Channel Freshwater Benzo(a)pyrene CIMP Monitoring California Toxics Rule Human Health Standard n/a 0.049 ug/L[6]
[1] Wet weather only, based on the Dominguez Channel Toxics TMDL [2] The interim deadline for Dominguez Channel Toxic TMDL is 3/23/2012. [3] Also applicable to Torrance Lateral as an alternative compliance target. [4] Annual MS4 WLA to the entire Dominguez Channel estuary drainage area. [5] Per the Basin Plan Objective REC1 Water Bodies Limit for Indicator Bacteria, the statistical threshold value of E. coli (320/100 mL) is not to be exceeded by more than 10 percent of the samples collected in a calendar month. [6] The CTR Human Health numeric target is not directly applicable at outfalls, but has been utilized as an evaluative metric in this case.
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REFERENCES City of Malibu, 2012. Comment Letter – Bacteria TMDL Revisions for Santa Monica Bay Beaches. May 7. Curren, J., S. Bush, S. Ha, M.K. Stenstrom, S. Lau, I.H.M. Suffet, 2011. Identification of subwatershed sources for chlorinated pesticides and polychlorinated biphenyls in the Ballona Creek watershed. Science of the Total Environment, Vol. 409, Issue 13, pp. 2525-2533. 1 June 2011. Davis A.P., M. Shokouhian, and S. Ni. 2001. Loading estimates of lead, copper, cadmium, and zinc in urban runoff from specific sources. Chemosphere. Federal Aviation Administration (FAA), 2015. Aviation Gasoline, about Aviation Gasoline. (http://www.faa.gov/about/initiatives/avgas/) Geosyntec Consultants, 2011a. Structural BMP Siting and Conceptual Design Study, Santa Monica Bay Beaches Bacteria TMDL Implementation. Produced for SMBBB TMDL Jurisdictional Groups 5 & 6. June. Geosyntec Consultants, 2011b. Dry Weather Source Characterization and Control Summary, Santa Monica Bay Beaches Bacteria TMDL Implementation. Produced for SMBBB TMDL Jurisdictional Groups 5 & 6. June. Geosyntec Consultants, 2012. A User’s Guide for the Structural BMP Prioritization and Analysis Tool (OCTA-SBPAT v1.0). Prepared for Orange County Transportation Authority. November 2012. Klasing, S. and Brodberg, R., 2008. Development of Fish Contaminant Goals and Advisory Tissue Levels for Common Contaminants in California Sport Fish: Chlordane, DDTs, Dieldrin, Methylmercury, PCBs, Selenium, and Toxaphene. Pesticide and Environmental Toxicology Branch Office of Environmental Health Hazard Assessment California Environmental Protection Agency. June 2008. Los Angeles County Sanitation District (LACSD), 2009. Model Program for Bacterial Source Identification and Abatement Plan – Redondo Beach Pier Pilot Program. Final Report and Abatement Plan. December 1. Los Angeles Regional Water Quality Control Board (LARWQCB), accessed 2021. Water Quality Control Plan (Basin Plan). https://www.waterboards.ca.gov/losangeles/water_issues/programs/basin_plan/basin_plan_documentation.html LARWQCB, 2010. Machado Lake Pesticides and PCBs TMDL. Staff Report - September 2, 2010. LARWQCB and USEPA, 2011. Dominguez Channel and Greater Los Angeles and Long Beach Harbor Waters Toxic Pollutants TMDL. May 5. LARWQCB, 2012a. Order No. R4-2012-0175 NPDES Permit No. CAS004001 Waste Discharge Requirements for Municipal Separate Storm Sewer System (MS4) Discharges within the Coastal Watersheds of Los Angeles County, except those Discharges Originating from the City of Long Beach MS4. November 8.
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LARWQCB, 2012b. Attachment A to Resolution No. R12-007, Proposed Amendment to the Water Quality Control Plan – Los Angeles Region to revise the Santa Monica Bay Beaches Bacteria TMDL. June 7. Long, E.R., D.D. MacDonald, S.L. Smith, and F.D. Calder, 1995. Incidence of adverse biological effects within ranges of chemical concentrations in marine and estuary sediments. Environmental Management. 19, (1): 81-97. Sabin, L.D., K.A. Maruya, W. Lao, D. Diehl, D. Tsukada, K.D. Stolzenbach, and K.C. Schiff 2009. Exchange of Polycyclic Aromatic Hydrocarbons among the Atmosphere, Water, and Sediment in Coastal Embayments of Southern California, U.S.A. Environmental Toxicology and Chemistry, Vol. 29, No. 2, pp. 265-274. Southern California Coastal Water Research Project (SCCWRP), 2007. Technical Report 510 Sources, Patterns, and Mechanisms of Storm Water Pollutant Loading from Watersheds and Land Uses of the Greater Los Angeles Area, California, USA. Written by E.D. Stein, L.L. Tiefenthaler, and K.C. Schiff. March 2007. State Water Resources Control Board (SWRCB), 2015. Water Quality Control Policy for Developing California’s Clean Water Act Section 303(d) List. February 3. SWRCB, 2019. Water Quality Control Plan – Ocean Waters of California (Ocean Plan). February 4. Stein, E.D., Tiefenthaler, L.L., and Schiff, K.C., 2007. “Sources, Patterns and Mechanisms of Storm Water Pollutant Loading From Watersheds and Land Uses of the Greater Los Angeles Area, California, USA.” Southern California Research Project (SCCWRP), Technical Report 510, March. TDC Environmental, 2013. Estimate of Urban Runoff Copper Reduction in Los Angeles County from the Brake Pad Copper Reductions Mandated by SB 346. February. USEPA, 2000. Office of Science and Technology Office of Water. Guidance for Assessing Chemical Contaminant Data for Use in Fish Advisories Volume 1: Fish Sampling and Analysis. EPA 823-B-00-007 November. USEPA, 2012. Santa Monica Bay Total Maximum Daily Loads for DDTs and PCBs.
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Revised EWMP
Appendix C:
Minimum
Control Measure
Customization and
Summary
JUNE 2021
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MINIMUM CONTROL MEASURE SUMMARY AND CUSTOMIZATION Non-structural BMPs prevent or reduce the release of pollutants or transport of pollutants within the MS4 area but do not involve construction of physical facilities. Non-structural BMPs are often implemented as programs or strategies which seek to reduce runoff and/or pollution close to the source. Examples include but are not limited to: street sweeping, downspout disconnect programs, pet waste cleanup stations, irrigation ordinances, or illicit discharge elimination. Minimum control measures (MCMs) as set forth in the Permit are a subset of non-structural BMPs even though some MCMs include measures that require the implementation of structural BMPs. The Beach Cities WMG has assessed the MCMs defined in the Permit to identify opportunities for focusing resources on the high priority issues in each watershed. The Permit requires the permittees to implement prescribed MCMs in each of six categories/programs: Public Information & Participation Program (PIPP), Industrial/Commercial Facilities, Planning & Land Development, Development Construction, Public Agency Activities (PAA), and Illicit Connection & Illicit Discharges (IC/ID) Elimination. These measures include procedures such as outreach programs, inspections, and reporting requirements designed to reduce runoff-related pollution within each permittees’ MS4 area. As LACFCD has no land use authority, the requirements of Industrial/Commercial Facilities, Planning & Land Development, and Development Construction programs are not applicable to LACFCD outside its own facilities (see Appendix G). RECOMMENDED MCMS AND NON-STRUCTURAL BMPS The Permit allows permittees developing an EWMP the opportunity to customize the MCMs specified in the Permit to focus resources on high priority issues within their watersheds. Modifications to the MCMs must be appropriately justified and still be consistent with 40 CFR § 122.26(d)(2)(iv)(A)-(D). A control measure may only be eliminated based on the justification that it is not applicable to a particular permittee. Customized measures, once approved as part of the EWMP, will replace in part or in whole the prescribed MCMs in the Permit. The Planning & Land Development Program is not eligible for customization in that it may be no less stringent than the baseline requirements in the Permit. However, it can be enhanced over the baseline permit requirements if desired. MCMs in each of the six identified categories are being implemented by the Beach Cities WMG as prescribed under the Permit, and in some cases, MCM program enhancements have been implemented to address watershed priorities for TMDL implementation. A summary of MCM enhancements is provided in Table C-1. Additional modifications may also be made through the Adaptive Management Process.
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GENERAL FRAMEWORK FOR MCM CUSTOMIZATION An approach for evaluating existing institutional MCMs was developed as part of the Beach Cities original EWMP Work Plan and was used to evaluate existing MCMs and develop the customized MCMs. The following steps provide a general framework for MCM customization: 1. Identify MCMs for potential customization. This may include identifying: a. MCM requirements prescribed by the Permit which are not already being implemented by the permittee; b. Currently implemented MCMs which have been enhanced over the previous Permit as part of TMDL implementation, e.g., Enhanced Restaurant Inspection Program; c. Programmatic solutions/non-structural controls identified in TMDL implementation plans which may not yet have been implemented; and d. MCMs which are currently being implemented but which may be excessive in scope. For example, commercial inspections being conducted of retail gasoline facilities which are already heavily regulated through other environmental programs in areas that have no receiving water impairments for the pollutants of concern may be carried out less frequently, or discontinued indefinitely. 2. Identify MCMs which are not applicable. A control measure may be eliminated based on the justification that it is not applicable to a particular permittee. For example, if it is the policy of a permittee not to use pesticides in public agency activities, then there is no need for tracking of pesticide use and this MCM may be proposed for elimination. 3. Assess the effectiveness of the incremental baseline MCM requirements with respect to water quality priorities. The data necessary to quantify this will vary greatly by MCM, but may include information such as: receiving water quality, inspection and reporting records, number of qualifying projects (e.g., number of construction projects greater than 1 acre), number of pet station bags used, amount of material picked up by street sweeping activities, number of employees trained, and maintenance records. Additionally, the California Stormwater Quality Association (CASQA) provides a tool to estimate the effectiveness of stormwater management programs (CASQA, 2015). The tool recommends possible assessment metrics that can be used for various stormwater programs. 4. Quantify the additional resources required to implement the incremental baseline MCMs. This may include estimating additional staff resources in terms of full-time employees, consulting resources, and contracted services. 5. Assess the effectiveness and resources required to implement the customized MCM. The process to quantify these will be the same as the process used to quantify the baseline effectiveness of the existing MCM. 6. Compare the assessed effectiveness and resources required to implement the incremental baseline MCMs and the customized MCMs. Customization can be justified in several ways: a. If the customized MCM effectiveness is equal to or greater than the baseline MCM, customization can be justified.
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b. If an MCM requirement is not applicable, then elimination is justified. c. If the incremental MCM requires additional resources that are disproportionate to the increased effectiveness achieved, then retention of the existing MCM may be justified. 7. Document the customized MCM justification. MCMs were evaluated based on their effectiveness in addressing the WBPCs specific to the Beach Cities EWMP Area and based on the Beach Cities WMGs knowledge and experience with existing MCMs. In many ways, the WMG’s practical experience with MCM implementation over time provides the best insight as to what MCM modifications/enhancements will be most helpful to target the WBPCs of concern in the Beach Cities EWMP Area. Table C-1 summarizes the proposed MCM enhancements common to the Beach Cities WMG, which include promotion of existing regional programs as part of the residential outreach permit requirement; development and distribution of digital and print outreach materials targeted at pollutants of concern in the Beach Cites watersheds; establishment of South Bay Environmentally Friendly Gardening, Landscaping, and Pest Management webpages; and annual restaurant inspections as commercial pollutant sources. For the MCMs applicable to the LACFCD (namely the PIPP, the IC/ID, and the PAA), the LACFCD will continue to implement the requirements both individually and in collaboration with the WMG as identified in the MS4 Permit. In addition to the MCM modifications being implemented by the WMG as a group, the Beach Cities WMG has identified additional city-specific MCM enhancements, which include organization and promotion of educational and cleanup-oriented events, maintenance of pet waste collection stations as a part of the residential outreach requirement, bans on plastic bags and polystyrene food containers in Manhattan Beach and Hermosa Beach, and maintenance of environmentally-oriented city websites. City-specific MCMs enhanced beyond Permit requirements are specified in Table C-1. The MCM enhancements shown in this table are examples and are not comprehensive.
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Table C-1. Enhancements to MCMs
MS4 Permit MCM Requirements General Beach Cities MCM
Enhancement (all agencies)
City-Specific MCM Enhancement
City of
Manhattan Beach
City of
Redondo Beach
City of
Hermosa Beach City of Torrance
Public Information and Participation Program
(PIPP)1 Residential Outreach (individually or with group): Ongoing development and dissemination of targeted outreach promoting behavior change in activities among the DIY residential community that is a source of priority pollutants. Leveraging of successful existing statewide and regional outreach programs using print and digital distribution methods.
Manhattan Beach is implementing the “Plastic Free MB” campaign to reduce plastic use and waste. The City Council has passed several comprehensive ordinances targeted at plastic reduction: plastic bag ban, ban on polystyrene, prohibition on single-use plastic straws and utensils, and ban on polystyrene meat trays and mylar balloons.
The Hermosa Beach City Council has adopted ordinances to ban certain polystyrene and single-use plastic products in Hermosa Beach as well as plastic bags.
Dissemination of Public education materials on proper management, recycling and/or disposal of vehicle fluids, household hazardous waste, construction waste, green waste, animal waste, pesticides, fertilizers, and integrated pest management (IPM).
Each of the Beach Cities leverages its solid waste franchise contract to conduct outreach on proper waste management in the form of solid waste bill inserts or direct mailers.
Household hazardous waste collection is offered to single and multi-family residences. Free pharmaceutical drop off and battery recycling collection containers are located at city facilities. Project Pollution Prevention brochures are provided to residents and contractors via the City's website.
The City promotes and hosts annual household hazardous waste roundup events. Project Pollution Prevention brochures are available at the public counter. The City promotes and hosts annual household hazardous waste roundup events.
BMP brochures are made available at City outreach and environmental events and public counters.
Dissemination of public education information targeted at residential do-it-yourself auto activities Participation in the CalRecycle Used Oil Program. Development and distribution of a Mobile Business Tip Card targeting mobile auto detailers.
Dissemination of public education information targeted at residential do-it-yourself home improvement and maintenance activities Distribution of a Small Site (<1 acre) Construction brochure with information regarding material storage and handling as well as spill prevention and clean-up and disposal. Distribution of LA County Residential Pool and Spa Maintenance BMPs for the Environment flyer. Promotion of West Basin Municipal Water District (WBMWD) programs via SBESC e-blasts and City websites.
1 The Permittees will adapt the PIPP over time to address new information, water quality priorities and stormwater management program priorities – activities listed below provide examples of how the PIPP is currently being enhanced.
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MS4 Permit MCM Requirements General Beach Cities MCM
Enhancement (all agencies)
City-Specific MCM Enhancement
City of
Manhattan Beach
City of
Redondo Beach
City of
Hermosa Beach City of Torrance Dissemination of public education information targeted at residential do-it-yourself landscaping and gardening activities and integrated pest management.
Development and maintenance of Environmentally Friendly Landscaping, Gardening and Pest Control Webpages hosted by the South Bay Environmental Services Center. Development, distribution and promotion of South Bay Homeowner’s Guide to Rainwater Harvesting. Promotion of sustainable landscaping, gardening and water efficiency events and programming hosted by West Basin Municipal Water District.
The City provides resources on Ocean-Friendly Gardens and Sustainable Landscapes on its website, and continues to promote Sustainable Landscaping principles in its Green Code planning requirements for new projects or significant remodels. The City maintains a number of California Friendly demonstration gardens.
The City maintains a number of California Friendly demonstration gardens. The City created a “tip card” for residential notifications of excessive over irrigation into the streets that provides tips to control and reduce the overspray and ponding in the gutters.
The City maintains a number of California Friendly demonstration gardens. The City maintains a number of California Friendly demonstration gardens and hosts rain barrel distribution events.
Distribute public education information targeted at residential pet owners The City maintains pet waste collection stations in locations with high frequency of use by residents with dogs. The stations are equipped with disposable bags for collecting and disposing of pet waste.
All City parks and the Esplanade are equipped with pet waste collection stations. All City parks, The Strand and the linear greenbelt are equipped with pet waste collection stations. The City also conducts targeted outreach to pet owners to pick up after their pets and follow the City’s pet owner ordinances.
City Parks are equipped with pet waste collections stations. Dog waste BMP brochures are made available at City outreach and environmental events and public counters. Residents can also pick up a free pet waste dispenser with biodegradable bags at the One-Stop Permit Center. Maintain stormwater website Development and maintenance of Environmentally Friendly Landscaping, Gardening and Pest Control Webpages hosted by the South Bay Environmental Services Center.
The City maintains integrated Environmental Sustainability webpages which links to the Public Works Environmental Programs page that has information on several Public Works environmental programs such as the Solid Waste and Recycling Program, Hazardous Waste Disposal Program, Water Conservation Program, and Stormwater Pollution Prevention Program.
The City maintains water quality information on its website. The City has an Environmental Programs webpage, and a Water Conservation webpage which links to the South Bay Environmentally Friendly Landscaping, Gardening and Pest Control Webpages..
The City has an NPDES/Stormwater webpage. The Public Works website provides updates, information and links regarding environmental programs, household hazardous waste, water conservation efforts, and sustainable landscaping and gardening. Torrance also has a dedicated recycling and waste management website. Provide schools with materials to educate children (K-12); can use state produced materials The Beach Cities WMG agencies promote the Generation Earth Program delivered by Tree People through funding by Los Angeles County Department of Public Works.
Manhattan Beach K-12 schools participate in the Grades of Green. The Roundhouse Marine Studies Lab and Aquarium located at the end of the Manhattan Beach Pier provides outreach to thousands of students through hands-on pollution and ocean awareness classes.
City of Redondo Beach staff partners with local schools to help educate students regarding stormwater pollution prevention and recycling. The schools are invited to attend various City sponsored cleanup events.
Hermosa Beach elementary schools participate in the Grades of Green program.
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Beach Cities EWMP | Appendix C | MCM Enhancements
C-3 | Page 2 021
MS4 Permit MCM Requirements General Beach Cities MCM
Enhancement (all agencies)
City-Specific MCM Enhancement
City of
Manhattan Beach
City of
Redondo Beach
City of
Hermosa Beach City of Torrance
D.6 Industrial/ Commercial Implement a Business Assistance Program for select sectors or small businesses - technical assistance and distribute materials to specific sectors. Assistance is targeted to select business sectors based on information that activities may be contributing substantial amounts of pollutants of concern to the MS4 and will evolve over time based on new information and feedback from inspectors and the monitoring program. Examples of current targeted Business Assistance Programs are provided at right:
The Beach Cities WMG agencies each implement an annual restaurant inspection program where outreach is provided on proper waste management and stormwater pollution prevention.
The Green Business Program recognizes businesses that incorporate sustainability into their daily business practices with the objective of reducing waste. The City’s franchise solid waste hauler offers free commercial waste audits to assess areas of improvement for the reduction of waste. The City also offers a Green Business certification through the California Green Business Network for local businesses that meet certain criteria to reduce impacts on the environment.
The City of Redondo Beach staff periodically meet with various business association districts to help educate them on stormwater pollution prevention and recycling topics. In addition, City staff work with the Redondo Beach Chamber of Commerce on various water quality related issues affecting businesses within the City.
The City of Hermosa Beach offers a Green Business certification through the California Green Business Network for local businesses that meet certain criteria to reduce impacts on the environment.
Torrance distributes outreach to businesses on environmental practices and the City of Torrance has partnered with the Environmental Services Center of the South Bay Cities COG to administer a grant from the California Green Business Network to offer the Green Business Certification to its businesses.
Inspect Commercial Sources All restaurants are inspected annually instead of twice during 5-year permit.
Commercial facilities including nurseries and automotive facilities are inspected every other year instead of twice during 5-year permit. Inspect Industrial Sources Industrial facilities are inspected every other year instead of twice during 5-year permit.
D.7 Planning and Land Development Update and Implement ordinance/design standards to conform with LID and Hydromodification requirements
Development in the Coastal Zone that requires a Coastal Development Permit is required to meet the LID standards. Hermosa LID ordinance requires all new development projects to implement LID with no minimum size threshold.
D.8 Development Construction Program Sites < 1 acre; inspect based upon water quality threat A building/grading site is inspected on average about 12 times and each time the inspector is on site, the condition of stormwater BMPs is noted by the inspector and, if necessary, corrections required.
Site < 1 acre; Require sites with soil disturbing activities to implement minimum BMPs Distribution of Small Site Construction brochure in English and Spanish for sites disturbing less than 1-acre that includes an example site schematic and information on each of the required minimum BMPs.
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MS4 Permit MCM Requirements General Beach Cities MCM
Enhancement (all agencies)
City-Specific MCM Enhancement
City of
Manhattan Beach
City of
Redondo Beach
City of
Hermosa Beach City of Torrance
D.9 Public Agency Activities Prevent vehicle/equipment washing discharges to the MS4, including firefighting and emergency response vehicles
City Yard includes designated area for washing vehicles equipped with clarifier and diversion. Additionally, the City Yard bulk storage area includes roof canopies and a dry weather diversion system.
The City Yard is retrofitted with a dry weather diversion to the sanitary sewer.
Implement IPM program The City has eliminated the use of non-organic pesticide products in parks and open spaces and City maintenance crews and contractors utilize a combination of organic pest control strategies and products to control invasive weeds, insects and rodents throughout city facilities.
The City has eliminated the use of non-organic herbicide products in post emergent applications at all parks. Hermosa Beach has designated all City parks pesticide-free zones, and thus uses no pesticides in maintaining these public recreational areas, which include the greenbelt that runs the length of the City.
Torrance’s pesticide free zones include around both community gardens, in most playgrounds, and around all picnic areas except for at Columbia and Wilson Park.
Required trash management at public events The City implements a tiered matrix of requirements for special events in the City to reduce waste and control litter. Place and maintain trash receptacles/capture devices at newly identified high trash generating areas
The City maintains more than 125 additional receptacles for recyclable glass, plastic and aluminum beverage containers.
The City has placed trash receptacles in high use area throughout the City, including all bus stops, parks and coastal areas.
The City has placed over 100 recycling bins for beverage containers throughout the City, at all bus stops, in heavily used pedestrian areas and parks.
Street sweeping - Priority A: 2x/mo.; B: 1x/mo.; C: as needed, not less than 1x/yr. Streets are swept weekly and posted with no parking signs on street sweeping days. Streets are swept weekly and posted with no parking signs on street sweeping days. Streets are swept weekly and posted with no parking signs on street sweeping days. Streets are swept weekly and posted with no parking signs on street sweeping days. Inspect and/or clean Permittee owned parking lots 2x/mo. City parking lots are swept weekly.
D.10 Illicit Connections and Illicit Discharges
Elimination
Continue IC/ID program Implementation of the model California Water Efficient Landscape Ordinance or equivalent city-specific ordinance for new landscapes.
The City has a water conservation ordinance as well as CalGreen Code provisions for landscaping and irrigation.
The City has Landscape Regulations included in the Municipal Code, including water conservation. The City has a Water Conservation and Drought Management Plan Ordinance. The City has a Water Conservation and Drought Management Program, under which City staff proactively identify irrigation overuse.
Facilitate public reporting via hotline The City’s “Go Hermosa!” app allows residents to report illicit discharges directly to the City via the app.
548
Beach Cities Watershed
Management Group
Revised EWMP
Appendix D:
RAA Report
JUNE 2021
549
DRAFT
Reasonable Assurance Analysis Report
Revised Beach Cities EWMP 2021
Prepared for
Beach Cities Watershed Management Group
(Cities of Hermosa Beach, Manhattan Beach, Redondo Beach, and Torrance and
the Los Angeles County Flood Control District)
Prepared by
Geosyntec Consultants, Inc.
6167 Bristol Parkway Ste 390
Culver City, CA. 90230
Project Number CWR0645
May 2021
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TABLE OF CONTENTS
1. Introduction ........................................................................................................... 1
2. Water Body Pollutant Combinations .................................................................... 2
3. Model Selection and Overview ............................................................................ 6
3.1. WMMS 2.0 LSPC........................................................................................ 6
3.1.1. Updating Weather Data .................................................................. 9
3.1.2. Adding Fecal Indicator Bacteria as a Modeled Constituent ........... 9
3.1.3. Use of Surrogate Pollutants .......................................................... 10
3.1.4. Model Calibration and Validation ................................................ 10
3.1.5. Revising LSPC Sub-Basin Boundaries ........................................ 10
3.2. WMMS 2.0 SUSTAIN .............................................................................. 11
4. RAA Approach ................................................................................................... 12
4.1. Wet Weather RAA Approach .................................................................... 13
4.2. Dry Weather RAA Approach .................................................................... 14
5. Model Calibration and Validation ...................................................................... 15
5.1. Hydrologic Calibration .............................................................................. 16
5.2. Water Quality Calibration ......................................................................... 22
6. Critical Condition Definition .............................................................................. 26
6.1. Santa Monica Bay WMA .......................................................................... 26
6.1.1. Bacteria (Fecal Coliform) ............................................................. 26
6.2. Dominguez Channel WMA ....................................................................... 26
6.2.1. Indicator Bacteria (E. coli) ........................................................... 26
6.2.2. Metals and Organic Pollutants ..................................................... 26
7. Target Load Reductions ...................................................................................... 28
7.1. Santa Monica Bay WMA .......................................................................... 28
7.1.1. Bacteria (Fecal Coliform) ............................................................. 28
7.1.2. Pesticides and PCBs ..................................................................... 30
7.1.3. Mercury and Arsenic .................................................................... 30
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7.1.4. Trash and Marine Debris .............................................................. 30
7.1.5. Final Wet Weather TLR Summary for Santa Monica Bay .......... 30
7.2. Dominguez Channel WMA ....................................................................... 31
7.2.1. Metals ........................................................................................... 31
7.2.2. Pesticides, Organics, and PCBs .................................................... 33
7.2.3. Indicator Bacteria (E. coli) ........................................................... 34
7.2.4. Toxicity ........................................................................................ 34
7.2.5. Final Wet Weather TLR Summary .............................................. 35
8. Stormwater Control Overview ............................................................................ 37
8.1. Methods to Select and Prioritize BMPs ..................................................... 37
8.2. Quantified Non-Structural BMPs .............................................................. 37
8.2.1. Copper Brake Pad Reduction ....................................................... 38
8.3. Modeling Structural BMPs ........................................................................ 38
8.3.1. Regional and Distributed Structural Projects ............................... 40
8.3.2. Low Impact Development Applied to Redevelopment ................ 43
9. Wet Weather RAA Results ................................................................................. 45
9.1. Santa Monica Bay WMA .......................................................................... 45
9.2. Dominguez Channel WMA ....................................................................... 49
10. Dry Weather RAA Result ................................................................................... 54
10.1. Santa Monica Bay WMA .......................................................................... 54
10.2. Dominguez Channel WMA ....................................................................... 54
11. Conclusions......................................................................................................... 56
12. References ........................................................................................................... 57
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LIST OF TABLES
Table 1. Updated Waterbody Pollutant Combinations – Santa Monica Bay ................... 3
Table 2. Updated Waterbody Pollutant Combinations – Dominguez Channel WMA ..... 4
Table 3. Default BMPs Modeled in SUSTAIN .............................................................. 11
Table 4. Calibration Metrics ........................................................................................... 16
Table 5. Summary of Calibrated Hydrology Modeling Parameters ............................... 17
Table 6. Model Performance Summary - Hydrology ..................................................... 18
Table 7. Summary of Calibrated FIB Modeling Parameters .......................................... 23
Table 8. Summary of Calibrated Sediment Loading Parameters ................................... 23
Table 9. Summary of Calibrated Pollutant Loading Parameters .................................... 24
Table 10. Water Quality Model Calibration Summary .................................................. 24
Table 11. Dominguez Channel WMA 90th Percentile Daily Load Summary ............... 27
Table 12. Santa Monica Bay WMA Wet Weather TLR ................................................. 31
Table 13. Dominguez Channel WMA Wet Weather TLRs ............................................ 36
Table 14. Summary of Full 85th-Percentile, 24-Hr Design Storm Capture Project ....... 39
Table 15. Summary of Modeled Projects ....................................................................... 42
Table 16. Redevelopment LID BMP Modeling Parameters ........................................... 44
Table 17. Beach Cities SMB WMA RAA Summary ..................................................... 46
Table 18. Beach Cities DC WMA RAA Summary ........................................................ 50
Table 19. Dry Weather RAA Summary for Dominguez Channel WMA....................... 54
LIST OF FIGURES
Figure 1. HRU Overview .................................................................................................. 7
Figure 2. Hydraulic Network, Drainage Delineation, and Weather Station Overview .... 8
Figure 3. Analysis Region Overview .............................................................................. 12
Figure 4. Dry Weather RAA Process ............................................................................. 14
Figure 5. Locations of Monitoring Stations Utilized for Calibration and Validation .... 15
Figure 6. Flow Comparison at OF-BCEG-03 ................................................................. 19
Figure 7. Flow Comparison at OF-BCEG-05 ................................................................. 20
Figure 8. Flow Comparison at OF-BCEG-07 ................................................................. 21
Figure 9. Example Concentration Comparison Plot (Total Zinc) ................................... 25
Figure 10. Overview of 85th-Percentile, 24-Hour Storm Capture Projects ................... 40
Figure 11. Modeled Regional and Distributed Projects .................................................. 41
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Figure 12. 24-Hour Management Volume Breakdown in Santa Monica Bay WMA .... 47
Figure 13. 24-Hour Management Mapping in Santa Monica Bay WMA. ..................... 48
Figure 14. 24-Hour Management Volume Breakdown in Dominguez Channel WMA . 52
Figure 15. 24-Hour Management Volume Mapping in Dominguez Channel WMA ..... 53
LIST OF ATTACHMENTS
Attachment D.1 Supplementary Calibration Exhibits
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1. INTRODUCTION
As specified in the 2012 Los Angeles Municipal Separate Storm Sewer System (MS4)
National Pollutant Discharge Elimination System (NPDES) Permit 1 (Permit), the Cities
of Hermosa Beach, Manhattan Beach, Redondo Beach, and Torrance, together with the
County of Los Angeles and the Los Angeles County Flood Control District (LACFCD),
collectively referred to as the Beach Cities Watershed Management Group (WMG),
developed an Enhanced Watershed Management Program (EWMP) for their drainage
areas within the Santa Monica Bay and Dominguez Channel watersheds. As a part of
demonstrating progress and adaptive management, the Beach Cities WMG is required to
submit a revised EWMP to the Los Angeles Regional Water Quality Control Board
(LARWQCB), including an updated Reasonable Assurance Analysis (RAA), by June 30,
2021.
This report has been prepared to summarize the approach and results of the revised RAA.
Building upon the original and revised updated plans in 2015 and 2018, the revised RAA
has been conducted to conform to the original RAA guidelines developed by the
LARWQCB (LARWQCB, 2014a). The revised RAA also provides updates to include
recent monitoring data, project planning and implementation, and modeling advances
over the past five years. Where appropriate, it also addresses issues and comments raised
by the State Water Resources Control Board (SWRCB, 2020), such as inclusion of
relevant data for model calibration, non-structural Best Management Practices (BMP)
credit, and application of the limiting pollutant approach.
The updated wet weather RAA was conducted using the Watershed Management
Modeling System 2.0 (WMMS 2.0), the latest modeling tool developed by LACFCD, to
determine a cost-effective implementation strategy to meet applicable water quality
standards (i.e., TMDL waste load allocations [WLA] and Basin Plan Objectives) and
targets. This modeling platform was approved and endorsed by the LARWQCB as an
acceptable regulatory approach for developing the RAA. WMMS 2.0 has the capability
of representing wet and dry weather flow discharges, although based on a variety of
factors, dry weather flows were not modeled using WMMS 2.0 as part of this effort. For
dry weather, a revised semi-quantitative approach was implemented to update the dry
weather portion of the revised RAA.
The RAA was completed for the full geographic domain of the Beach Cities EWMP area,
as described in the revised Beach Cities EWMP. Unless otherwise noted, all Water Body
1 Order No. R4-2012-0175 NPDES Permit No. CAS004001 Waste Discharge Requirements for Municipal
Separate Storm Sewer System (MS4) Discharges within the Coastal Watersheds of Los Angeles County,
except those Discharges Originating from the City of Long Beach MS4.
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Pollutant Combinations (WBPCs) identified in the EWMP have been addressed as part
of this revised RAA.
2. WATER BODY POLLUTANT COMBINATIONS
The WBPCs defined in the original Beach Cities EWMP were revised based on the most
recent updates to applicable TMDLs and 303(d) listings, as well as available Coordinated
Integrated Monitoring Program (CIMP) monitoring data.2 The updated WBPC list is
summarized in Table 1 and Table 2 for the Santa Monica Bay watershed management
area (WMA) and Dominguez Channel WMA, respectively. These tables include the
applicable water quality-based effluent limitations (WQBELs) and the receiving water
limitations (RWLs).
As with the original Beach Cities EWMP, the RAA was performed to address all
Category 1 WBPC interim and final MS4 waste load allocations (WLAs), and all
Category 2 and 3 WBPCs where the Beach Cities WMG may have caused or contributed
to historical exceedances. For Category 2 and 3 pollutants that do not have a TMDL
WLA, various water quality objectives extracted from California Toxic Rule,
LARWQCB Basin Plan Objective and California Ocean Plan Objective were selected
and utilized for analysis purposes.
The WQBELs and RWLs for Dominguez Channel Estuary are included in Table 2
because the City of Torrance portion of the Beach Cities EWMP WMA drains to
Dominguez Channel Estuary via Torrance Lateral. This conveyance connectivity makes
the City of Torrance a responsible permittee with discharges to the Dominguez Channel
Estuary as indicated in the MS4 Permit Attachment K.
It should be noted that the table does not imply that compliance can only be achieved and
demonstrated via strict attainment of the listed TMDL WLAs. Other compliance
pathways (e.g., full diversion or providing treatment of discharges for the 85th percentile
24-hour design storm capture) also are viable options.
2 “Available data” includes all data collected through June 30, 2020 by the Beach Cities WMG. As this
date marks the end of the 2019-2020 reporting year, it is the most recent complete year of CIMP monitoring
that includes data that has been analyzed, verified, and reported according to the Beach Cities standard for
quality assurance and quality control (QA/QC). Monitoring data collected after this time has not yet been
QA/QC’d in accordance with this protocol, and so has not been used in the revised RAA and EWMP.
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Table 1. Updated Waterbody Pollutant Combinations – Santa Monica Bay
Category Water Body Pollutant –
Applicable Condition
Reason for
Categorization Interim TMDL WLA Final TMDL WLA or Other Target
1: Highest
Priority Santa Monica
Bay (including
SMB Beaches)
Bacteria – Wet and
Dry Weather
SMB Beaches
Bacteria TMDL
50% cumulative
percentage reduction
from total required
exceedance day
reduction[2]
Summer-Dry: Single Sample Allowable
Exceedance Days (AEDs)
Winter-Dry: Single Sample AEDs
Wet - Single Sample AEDs[1] and
Geometric Mean targets
Trash/Debris – Wet
and Dry Weather
SMB Debris
TMDL
Incremental reduction
from baseline waste
load allocation[3]
(6815.6 gals/year)
100% reduction from baseline waste
load allocation[3] (6815.6 gals/year)
DDTs – Wet and Dry
Weather SMB PCBs and
DDT TMDL
n/a 0.88 g/yr[4]
PCBs – Wet and Dry
Weather
n/a 4.56 g/yr[4]
2: High
Priority
Mercury– Wet and Dry
Weather 303(d) list
n/a 0.4 ug/L[5]
Arsenic– Wet and Dry
Weather
n/a 80 ug/L[5]
3: Medium
Priority Analysis of monitoring data from outfalls and receiving waters do not currently result in the identification of any Category 3 WBPCs
[1] Per the LARWQCB Basin Plan Objective REC1 Water Bodies Limit for Bacteria. Please refer to Beach Cities EWMP Appendix B for allowable
exceedance day limits for each subwatershed.
[2] Total required exceedance day reduction is defined as the difference between historical exceedance day and the allowable exceedance day for each
subwatershed.
[3] Baseline WLA is the sum of baseline WLA from Manhattan Beach, Redondo Beach, Hermosa Beach, and Torrance.
[4] This mass-based WLA presented in the TMDL is applicable for all Los Angeles County MS4 permittees draining to Santa Monica Bay. WLA
applicable to Beach Cities WMG is apportioned based on Beach Cities WMG’s tributary area to Santa Monica Bay.
[5] California Ocean Plan target.
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Table 2. Updated Waterbody Pollutant Combinations – Dominguez Channel WMA
Category Water Body Pollutant Reason for
Categorization
WLA/Standard/Target
Basis Interim TMDL WLA Final TMDL WLA
or Other Target
1: Highest
Priority
Dominguez
Channel
Freshwater]
Toxicity
Dominguez
Channel and
Greater Los
Angeles and
Long Beach
Harbor Toxics
TMDL
Monthly Average 2 TUc 1 TUc
Total Copper Wet Weather Single Event 207.51 ug/L 9.7 ug/L
205.5 g/day[3]
Total Lead Wet Weather Single Event 122.88 ug/L 42.7 ug/L
906.3 g/day[3]
Total Zinc Wet Weather Single Event 898.87 ug/L 69.7 ug/L
1,478.6 g/day[3]
Dominguez
Channel Estuary
Total Copper Wet Weather Single Event[1]
Annual Average[2] 220 mg/kg sediment
3.73 ug/L
31.6 mg/kg sediment
2.1 kg/yr[4]
Total Lead Wet Weather Single Event[1]
Annual Average[2] 510.0 mg/kg sediment
8.52 ug/L
35.8 mg/kg sediment
5.1 kg/yr [4]
Total Zinc Wet Weather Single Event[1]
Annual Average[2] 789.0 mg/kg sediment
85.6 ug/L
121 mg/kg sediment
25.5 kg/yr[4]
Total Cadmium Wet Weather Single Event[1]
Annual Average[2] n/a 1.2 mg/kg sediment
Total DDTs Wet Weather Single Event[1]
Annual Average[2] 1.727 mg/kg sediment 0.00059 ug/L
0.02 g/yr[4]
Total PAHs Wet Weather Single Event[1]
Annual Average[2] 31.60 mg/kg sediment 0.049 ug/L
0.013 kg/yr[4]
Total PCBs Wet Weather Single Event[1]
Annual Average[2] 1.490 mg/kg sediment 0.00017 ug/L
0.019 g/yr [4]
Torrance Lateral
Total Copper Wet Weather Single Event 207.51 ug/L 9.7 ug/L
31.6 mg/kg sediment
Total Lead Wet Weather Single Event 122.88 ug/L 42.7 ug/L
35.8 mg/kg sediment
Total Zinc Wet Weather Single Event 898.87 ug/L 69.7 ug/L
121 mg/kg sediment
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Category Water Body Pollutant Reason for
Categorization
WLA/Standard/Target
Basis Interim TMDL WLA Final TMDL WLA
or Other Target
2: High
Priority
Dominguez
Channel
(including
Freshwater,
Estuary, and
Torrance Lateral)
Indicator
Bacteria 303(d) List Exceedance Rate over 30-
day Period n/a See Footnote 5
3:
Medium
Priority
Dominguez
Channel
Freshwater
Benzo(a)pyrene CIMP
Monitoring
California Toxics Rule
(CTR) Human Health
Standard
n/a 0.049 ug/L[6]
[1] Basis for water column- or sediment-based concentration target.
[2] Basis for mass-based target.
[3] Daily MS4 WLA apportioned to Beach Cities WMG draining to the Dominguez Channel Freshwater area.
[4] Annual MS4 WLA apportioned to Beach Cities WMG draining to the Dominguez Channel Estuary area.
[5] Per the LARWQCB Basin Plan Objective REC1 Water Bodies Limit for Indicator Bacteria, the statistical threshold value of E. coli (320/100 mL) is
not to be exceeded by more than 10 percent of the samples collected in a calendar month.
[6] The CTR Human Health numeric target is not directly applicable at outfalls but was utilized as an evaluative metric in this case.
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3. MODEL SELECTION AND OVERVIEW
While the original RAA leveraged the strengths of the Structural BMP Prioritization and
Analysis Tool (SBPAT) to perform the wet weather modeling analysis, the revised RAA
uses the newly-released WMMS 2.0 modeling platform to maintain consistency with the
majority of RAAs across Los Angeles County. Developed by LACFCD and publicly
released in May 2020, WMMS 2.0 utilizes remote sensing, water quality, and hydrology
data collected through 2018 to simulate contaminant loading, runoff volume, and flow
rate. WMMS 2.0 contains two major components: a Loading Simulation Program in C++
(LSPC) to determine hydrology and pollutant loading, and a System for Urban
Stormwater Treatment and Analysis Integration (SUSTAIN) to assist in BMP selection
and performance. Detailed descriptions of each model component are provided below.
An advantage of using the WMMS 2.0 model is the extensive regional calibration effort
that has gone into the recent update of the model.
3.1. WMMS 2.0 LSPC
WMMS 2.0 LSPC (version 6.0) is capable of simulating watershed hydrology, sediment
erosion and transport, and water quality processes from both upland contributing areas
and receiving streams. Long-term, hourly rainfall data and average monthly
evapotranspiration values are used along with land use-linked catchment imperviousness,
soil properties, and land use-specific pollutant buildup/wash off rates to estimate wet
weather runoff volumes and pollutant loading. LSPC utilizes the following spatial and
temporal data to conduct the simulation:
• Hydrologic response unit (HRU), which is a combination of:
o Soils
o Land cover
o Groundwater recharge potential
o Topography
o Land use
• Hydraulic network (dams, debris basins, spreading grounds, water reclamation
plants, storm drains, open channels)
• Subwatershed/subbasin
• Hourly and spatially interpolated precipitation and evapotranspiration data.
Figure 1 illustrates the HRU of the Beach Cities EWMP area, Figure 2 illustrates the
hydraulic network, and subwatershed boundary and the weather station coverage for the
Beach Cities EWMP area.
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Figure 1. HRU Overview
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Figure 2. Hydraulic Network, Drainage Delineation, and Weather Station
Overview
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The default 3 WMMS 2.0 LSPC model has been configured, calibrated, and validated
through a regional approach against flow and water quality monitoring data collected at
all Mass Emission Stations (MES) in Los Angeles County. The following pollutants are
included in the downloaded version of the WMMS 2.0 platform:
• Total Nitrogen
• Total Phosphorus
• Total Zinc
• Total Lead
• Total Copper
• Total Cadmium, and
• Total Suspended Solids (TSS)
The application of this model provides an estimate of the target load reduction (TLR), a
numerical expression of the Permit compliance metrics that serves as a basis for
confirming, with reasonable assurance, that implementation of the proposed BMPs will
result in attainment of the applicable TMDL WLA-based WQBELs in the Permit for
Category 1 pollutants, or the Water Quality Objectives for Category 2 and Category 3
pollutants.
The subsections below summarize the modifications to the default WMMS 2.0 LSPC
model that were used to conduct the revised RAA.
3.1.1. Updating Weather Data
The default WMMS 2.0 LSPC model database includes precipitation data up to
September 2018. Hourly rainfall data between September 2018 and June 2020 from Los
Angeles County operated Automatic Local Evaluation in Real Time (ALERT) rain
gauges were requested and amended to the model database in accordance with the default
WMMS 2.0 rain gauge coverage assignment.
3.1.2. Adding Fecal Indicator Bacteria as a Modeled Constituent
In the original Beach Cities EWMP RAA, fecal indicator bacteria (FIB) compliance
demonstration (where the TMDL permit limits are expressed in exceedance days) was
performed via using load reductions as the modeled surrogate compliance metric. To
maintain consistency with the LARWQCB Basin Plan, fecal coliform 4 was used as the
3 The term “default” refers to the “as-downloaded” model released in May 2020.
4 While the LARWQCB Basin Plan established water quality objectives of total coliform, fecal coliform
and enterococcus for marine water, historic monitoring data for a representative beach that demonstrated
fecal coliform loads (discharged from the watershed outlets) were significantly correlated with total
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representative FIB for marine waters, and E. coli was used as the FIB for freshwaters.
Because none of the default constituents in WMMS 2.0 LSPC model can be used as
surrogate pollutants for FIB, a representative FIB had to be added to the model. For the
Santa Monica Bay LSPC model, fecal coliform was used, with model input parameters
calibrated using fecal coliform monitoring data collected at Santa Monica Bay Beaches
Bacteria (SMBBB) TMDL Compliance Monitoring Locations (CMLs) within the Beach
Cities EWMP area. For the Beach Cities Dominguez Channel LSPC model, E. coli was
used, with model input parameters calibrated using E. coli monitoring data collected at
outfall monitoring locations draining to Dominguez Channel.
3.1.3. Use of Surrogate Pollutants
Pollutant load rate and concentration for WBPCs involving the seven default WMMS 2.0
LSPC model pollutants and the added FIB were obtained from the WMMS 2.0 LSPC
output files directly. A subset of the directly modeled pollutants was used as surrogate
pollutants to establish pollutant loading and concentration of pollutants not directly
modeled in the WMMS 2.0 LSPC model. Details on surrogate pollutant selection and
assignment in the Santa Monic Bay and Dominguez Channel watersheds are presented in
Section 6.1 and 6.2, respectively.
3.1.4. Model Calibration and Validation
The default WMMS 2.0 LSPC model is calibrated on a regional basis using data through
September 2018. This model was further calibrated and validated using Beach Cities
CIMP monitoring data collected up to June 30, 2020 to best reflect the baseline hydrology
and water quality conditions within the Beach Cities EWMP area. This date was selected
as it marks the most-recently complete CIMP annual reporting year, and therefore is
inclusive of the latest available data that have been properly QC’d by the Beach Cities
WMG. Detailed information on the model calibration can be found in Section 4.
3.1.5. Revising LSPC Sub-Basin Boundaries
Since the default LSPC subwatershed boundaries were developed at a regional scale and
covers the entire Los Angeles Basin, they were found to contain some minor inaccuracies
at the finer spatial resolution used for the RAA. As part of the revised RAA process, the
subwatershed boundaries were refined to more accurately reflect the drainage boundaries
of the Beach Cities EWMP WMA.
observed wet weather exceedance days for all FIBs for marine water. Hence, fecal coliform was selected
as the representative FIB for marine water.
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3.2. WMMS 2.0 SUSTAIN
Utilizing hourly hydrograph and pollutograph outputs from LSPC, SUSTAIN (version
2.1) provides estimates of water balance such as volumes: evapotranspired, diverted,
captured, treated, and/or released by various BMPs, as well as a conceptually optimal
spatial distribution based on cost effectiveness to achieve TLR goals. WMMS 2.0
SUSTAIN also includes a batch-processing framework to inform selection,
configuration, and placement of BMPs throughout a watershed based on defined
evaluation criteria, such as cost and TLR. The default WMMS 2.0 SUSTAIN model
supports estimated performance of BMPs summarized in Table 3.
Table 3. Default BMPs Modeled in SUSTAIN
BMP Type Performance Type
Distributed BMP
Bioretention/biofiltration (with
optional underdrain) Volume reduction and flow through treatment
Pervious pavement Volume reduction and flow through treatment
Cistern/Rain barrel Volume reduction
Drywell Volume reduction
Proprietary treatment unit Flow through treatment
Regional BMP
Infiltration gallery Volume reduction
Retention/detention basin Volume reduction and flow through treatment
Constructed wetland Volume reduction and flow through treatment
Sewer diversion Volume reduction
Regional treatment facility Flow through treatment
For the revised RAA, WMMS 2.0 SUSTAIN was used to estimate the performance of
existing and proposed distributed and regional BMPs, thereby assuring that an effective
and suitable suite of stormwater management BMPs is implemented to meet applicable
interim and final TLR goals. This approach is therefore used to demonstrate a reasonable
assurance of compliance for all modeled WBPCs. Details on modeled BMPs in the Beach
Cities EWMPs are presented in Section 8.3.
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4. RAA APPROACH
Consistent with the original Beach Cities EWMP RAA, the revised RAA was performed
per analysis region. An analysis region is defined by one of the following conditions:
1. A subwatershed tributary to a shoreline CML (e.g. SMB-5-01)
2. A subwatershed tributary to the open beach between two CMLs (SMB-03_04)
3. A subwatershed tributary to an EWMP area outlet (e.g. DC-N-MB)
4. A subwatershed to an existing flood control basin or sump (e.g. Wylie Basin)
As shown in Figure 3, there are 20 analysis regions in the Santa Monica Bay WMA and
four in the Dominguez Channel WMA. Among the four Dominguez Channel WMA
analysis regions, DC-N-MB, DC-N-RB and DC-S are tributary to Dominguez
Freshwater. DC-TL is tributary to Dominguez Channel Estuary via Torrance Lateral. The
Machado Lake Watershed is being addressed in a separate EWMP/RAA by the City of
Torrance.
Figure 3. Analysis Region Overview
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4.1. Wet Weather RAA Approach
The approach for representing wet weather flows and pollutant management for the RAA,
including model determination and calibration, data inputs, critical condition selection,
calibration performance criteria, and output types, have all been selected for consistency
with the RAA Guidance Document (LARWQCB, 2014b), as well as functionality of
WMMS 2.0. The process for the wet weather RAA included the following steps and were
applied to the wet weather RAA for both Santa Monica Bay and Dominguez Channel
(including Torrance Lateral) WMA.
1. Identify current WBPC list, including all quantifiable parameters requiring model
simulation.
2. Revise, as needed, the contributing MS4 service areas to represent the WMA (e.g.,
remove lands or areas not required to be analyzed and adjust boundaries to match
at a more detailed scale). This includes various full 85th percentile 24-hour storm
capture basins under existing and proposed conditions (Wylie Basin, Torrance
Basins Enhancement and Expansion Project, Beach Cities Green Streets Project),
land owned and operated by Caltrans, and facilities operating under their own
NPDES permit (e.g., the Torrance Refinery).
3. For analysis regions draining to a CML, review the Beach Cities CIMP and
SMBBB TMDL monitoring data and assess if the analysis region is achieving
compliance based on water quality history. For these analysis regions, no RAA is
needed; compliance is already demonstrated based on monitoring data.
4. Perform hydrologic and water quality calibration on the LSPC model using Beach
Cities CIMP outfall monitoring data.
5. Identify WBPC-specific critical condition.
6. Develop interim and final TLRs for identified WBPCs during the respective
critical condition.
7. Identify the following with respect to structural and non-structural BMPs:
a. Significant variations to BMPs accounted for in the original Beach Cities
EWMP (e.g., differences in LID implementation levels)
b. New BMPs that have been implemented since 2014 and were not
accounted for in the original EWMP
c. New BMPs that are planned for implementation and were not accounted
for in the original EWMP.
8. Evaluate the pollutant load reductions of existing and proposed BMPs.
9. Compare these estimates with the final TLRs.
10. Revise the BMP implementation scenarios until all final TLRs are met, thereby
reasonably assuring compliance with wet weather permit goals.
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4.2. Dry Weather RAA Approach
Consistent with the original Beach Cities EWMP RAA, a semi-quantitative approach was
implemented to perform the dry weather RAA and demonstrate reasonable assurance of
meeting applicable permit goals.
Within the Santa Monica Bay WMA, low flow diversions (to the sanitary sewer) have
been implemented successfully along the coast to effectively divert significant non-
stormwater discharges away from discharging to the ocean. Additionally, for smaller
outfalls, due in part to setbacks from the shoreline, non-stormwater MS4 infiltrates at the
open beaches, preventing discharges from reaching the ocean. The effectiveness of these
measures and outfall conditions has been consistently confirmed through monitoring.
Therefore, compliance with TMDL objectives during dry weather is demonstrated for the
Beach Cities Santa Monica Bay WMA via the no discharge permit compliance pathway.
Within the Beach Cities Dominguez Channel WMA, the dry weather RAA is only
required for Category 2 and 3 WBPCs for the Dominguez Channel freshwater and
Torrance Lateral and for Category 1 WBPC for the Dominguez Channel estuary. The
approach outlined in Figure 4 was utilized to perform the dry weather RAA for the Beach
Cities Dominguez Channel WMA. In subwatersheds containing proposed BMPs that
address wet weather pollutants, it was assumed that dry weather flows would be
completely captured and retained by these projects as well and result in no dry weather
discharge to the Dominguez Channel.
Figure 4. Dry Weather RAA Process
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5. MODEL CALIBRATION AND VALIDATION
The default WMMS 2.0 LSPC watershed model has been configured, calibrated, and
validated by LACFCD through a regional approach against flow and water quality
monitoring data collected at all Los Angeles County Mass Emission Stations (MES)
between water years 2008 and 2018 (LACFCD, 2020a). Geosyntec further calibrated the
model using Beach Cities CIMP wet weather outfall flow and water quality data collected
through June 2020. The calibrated Beach Cities LSPC model is used as the foundation
for performing the wet weather RAA. Figure 5 shows CIMP monitoring locations utilized
for the Beach Cities LSPC watershed model calibration and validation.
Figure 5. Locations of Monitoring Stations Utilized for Calibration and Validation
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Calibrations were performed to meet specifications of the RAA Guidelines (LARWQCB,
2014b), which are summarized in Table 4 below. Consistent with the regional WMMS
2.0 calibration process, percent bias (PBIAS) is the primary statistic used to evaluate
agreement between modeled-predicted and observed data. PBIAS quantifies systematic
over- or under-prediction. Low values of PBIAS indicate better fit and predictive
capability of the model. The lower bound of the “Fair” threshold is considered the
minimum acceptable criteria for the model calibration process. If a “Fair” threshold is not
achieved during the model validation process, additional model adjustments are made to
attain the threshold at the validation site. If such effort is not successful, additional
investigations will be performed to examine the modeled and monitored data at the
validation site to justify the calibration effort.
Table 4. Calibration Metrics
Category Percent Difference Between Model-Predicated and Observed Data (PBIAS)
Very Good Good Fair
Hydrology /
Flow ±0 – 10% ≥ ±10% - 15% ≥ ±15% - 25%
Sediment ±0 – 20% ≥ ±20% - 30% ≥ ±30% - 40%
Water Quality ±0 – 15% ≥ ±15% - 25% ≥ ±25% - 35%
Pesticides /
Toxics ±0 – 20% ≥ ±20% - 30% ≥ ±30% - 40%
Details of the calibration and validation approach and results are presented in the
following subsections.
5.1. Hydrologic Calibration
The objective of hydrologic calibration is to compare observed and model-predicted wet
weather flow rates at monitoring sites and demonstrate a PBIAS of 25% or less. While
continuous flow data is collected at all outfall monitoring sites, the following outfall
monitoring sites were excluded from the hydrologic calibration. Reasons for exclusion
are also provided:
• OF-BCEG-01 and OF-BCEG-04a: Drainage areas to these monitoring sites
includes large, manually controlled flood control detention basins. Since the
objective of the hydrology calibration is to determine modeling parameters that
will be globally applied to the entire Beach Cities EWMP area, monitoring data
collected at monitoring sites with existing regional stormwater BMPs represent
controlled discharges and were therefore excluded.
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• OF-BCEG-02: the monitoring site is consistently influenced by tidal impacts,
such that the collected flow data do not accurately represent MS4 discharges
coming from the upstream drainage area. Therefore, this site was excluded from
calibration.
• OF-BCEG-06: Initial comparison between monitored and uncalibrated modeled
flow rates revealed that that the monitored flow was consistently less than the
modeled flow data by an order of magnitude. Such discrepancy was not observed
in other outfalls. The Beach Cities WMG plans to perform further investigation
to assess such discrepancy as part of the CIMP. Although there’s currently no
reason to believe the flow data collected at this site is inaccurate, data from the
outfall monitoring site was excluded from the current hydrologic analyses and
calibration to avoid overly reducing runoff generation in the LSPC model.
After screening out aberrant outfall monitoring and locations, a site in the Santa Monica
Bay WMA was determined to have acceptable flow monitoring data available for
hydrologic calibration. A combined hydrologic calibration effort was then conducted to
utilize wet weather flow monitoring data collected at OF-BCEG-03 and OF-BCEG-05 to
determine modeling parameters applicable to both the Beach Cities Santa Monica Bay
and Dominguez Channel LSPC models. Wet weather flow monitoring collected at OF-
BCEG-07 was used to validate the calibration effort.
In maintaining consistency with the WMMS 2.0 model regional calibration process, the
hydrologic calibration required the evaluation of subsurface storage, infiltration, and
groundwater recession modeling parameters. The calibration was performed by
iteratively applying multipliers to HRU specific modeling parameters. The resulting
hydrology parameters ranges are presented in Table 5 alongside with default value ranges
from the WMMS 2.0 LSPC model database and guidance.
Table 5. Summary of Calibrated Hydrology Modeling Parameters
Parameter[1] Description Unit Beach Cities
Model Values
INFILT Index to Infiltration Capacity in/hr 0.23-4.0
AGWRC Base groundwater recession none 0.95-0.99
CEPSC Interception storage capacity inches 0.2-0.75
[1] For hydrologic parameters not listed in the table, the default WMMS 2.0 LSPC model values were used without
modification.
Table 6 presents a summary of results for hydrology calibration. PBIAS calculations were
based on comparison of modeled and observed daily flow at each outfall monitoring site.
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For the PBIAS metric, modeled flows achieved “Very good” agreement with observed
data at OF-BCEG-05 and OF-BCEG-07, and achieved “Fair” agreement with observation
at OF-BCEG-03 according to the Regional Board RAA Guidance metric summarized in
Table 4.
Table 6. Model Performance Summary - Hydrology
Calibration Metrics
Comparison Locations
OF-
BCEG-03
OF-
BCEG-05
OF-
BCEG-07
PBIAS (%) 16.9 -0.2 2.6
To further evaluate the temporal trends of the hydrology calibration, comparisons
between modeled and observed monthly flows were evaluated by examining the time
series plots and the average monthly flows between November 2016 and June 2020. The
resultant plots were shown in Figure 6 through Figure 8.
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Figure 6. Flow Comparison at OF-BCEG-03
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Figure 7. Flow Comparison at OF-BCEG-05
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Figure 8. Flow Comparison at OF-BCEG-07
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5.2. Water Quality Calibration
The RAA Guidelines require water quality calibration based on available monitoring data
from each analysis region over the most recent 10 years (LARWQCB, 2014). The default
WMMS 2.0 LSPC watershed model has been regionally calibrated and validated using
data collected at Los Angeles County MES and CIMP receiving water monitoring stations
throughout the County between water year 2008 and 2018. Building upon the regional
calibration and validation efforts, Geosyntec further calibrated the LSPC model using
water quality data collected at the Beach Cities CIMP outfall monitoring locations shown
in Figure 5. Modeling was completed for the following constituents:
• Fecal Coliform (For the Santa Monica Bay model only)
• E. coli (For the Dominguez Channel model only)
• Total Suspended Solids (TSS), which served as a surrogate for numerous other
WBPCs
• Metals – Total copper, total lead, total zinc, and total cadmium
The results of the modeling are discussed in the following subsections.
As discussed in Section 3.1.2, FIB representation was added to the WMMS 2.0 LSPC
model to demonstrate compliance to TMDL permit limits that are expressed in
exceedance days. HRU-specific land use bacteria EMCs from WMMS 1.0 were adopted
as the starting point of the calibration. The next step in the calibration process was an
iterative application of multipliers to EMCs across all HRUs. For the Santa Monica Bay
watershed model, the EMCs were calibrated and validated against wet weather fecal
coliform monitoring data collected at the SMBBB CMLs SMB-5-02 and SMB-6-01,
respectively. These sites are typically sampled five days a week throughout the year,
including wet weather, providing the most wet weather data coverage. For the Dominguez
Channel model, the FIB modeling parameters were calibrated and validated against E.
coli monitoring data collected at outfall sites OF-BCEG-07 and OF-BCEG -05,
respectively. OF-BCEG-07 was used as the calibration site because it had more sampled
data points (12 events) compared to OF-BCEG-05 (6 events). The calibrated range of
parameters are summarized in Table 7.
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Table 7. Summary of Calibrated FIB Modeling Parameters
Parameter Description Units
Santa Monica
Bay Model
Values (Fecal
Coliform)
Dominguez
Channel Model
Values (E. coli)
SOQC
Concentration of
constituent in surface
outflow
MPN/
100mL 900 – 81,900 1,300 – 118,300
IOQC
Concentration of
constituent in interflow
outflow
MPN
/100mL 900 – 81,900 1,300 – 118,300
Although TSS is not a pollutant of concern for the Beach Cities WMG, it is an important
driver for sediment-associated pollutant simulation within LSPC. In addition, TSS loads
are used as a surrogate for organic pollutants of concern that are not modeled directly in
LSPC (e.g., benzo[a]pyrene, total chlordane). TSS calibration was performed by
iteratively applying multipliers to HRU-specific parameter associated with sediment load
buildup on the land surface. The range of calibrated buildup is summarized in Table 8.
TSS was not modeled (and hence not calibrated) in the Santa Monica Bay LSPC model
as there are no WBPCs that are sediment-associated in the watershed. For the Dominguez
Channel watershed model, the TSS modeling parameters were calibrated and validated
against TSS monitoring data collected at outfall sites OF-BCEG-07 and OF-BCEG-05,
respectively.
Table 8. Summary of Calibrated Sediment Loading Parameters
Parameter[1] Description Units Beach Cities
Model Values
ACCSDP
Rate at which solids
accumulate on the land
surface
lb/acre/day 0 – 0.002
Calibration for metals was performed by iteratively applying HRU specific multipliers to
LSPC model parameters associated with metal potency factors in order to maintain the
same relative ratios among HRUs determined in the regionally calibrated WMMS 2.0
LSPC model. The calibration results are summarized in
Table 9. No metals were modeled (and hence were not calibrated) in the Santa Monica
Bay model as monitoring data demonstrates that there are no significant MS4-generated
metal WBPCs. For the Dominguez Channel watershed model, metal-related modeling
parameters were calibrated and validated against monitoring data collected at outfalls OF-
BCEG-07 and OF-BCEG -05, respectively.
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Table 9. Summary of Calibrated Pollutant Loading Parameters
Pollutant Parameter
Name Description Units
Beach
Cities
Model
Values
Total
Copper
POTFW Pollutant wash-off potency
factor per mass of sediment lb/ton 0-1.5
POTFS Pollutant scour potency factor
per mass of sediment lb/ton 0-1.9
Total Lead
POTFW Pollutant wash-off potency
factor per mass of sediment lb/ton 0-0.28
POTFS Pollutant scour potency factor
per mass of sediment lb/ton 0-0.28
Total Zinc
POTFW Pollutant wash-off potency
factor per mass of sediment lb/ton 0-13.8
POTFS Pollutant scour potency factor
per mass of sediment lb/ton 0-13.8
Total
Cadmium
POTFW Pollutant wash-off potency
factor per mass of sediment lb/ton 0.001-
0.025
POTFS Pollutant scour potency factor
per mass of sediment lb/ton 0.001-
0.025
Table 10 presents a summary of results for water quality calibration for all WBPCs.
Calculations of PBIAS were based on a comparison of modeled and observed daily
average concentration at each outfall monitoring site. To further evaluate the temporal
trends of the water quality calibration, comparisons between modeled and observed
pollutant concentration were evaluated examining the time series plots. An example of
the time series plots for total zinc concentration was shown in Figure 9. The remaining
time series plots are included in Attachment D.1.
In reference to the RAA Guideline calibration metrics summarized in Table 4, modeled
pollutant concentrations achieved “Fair”, “Good”, or “Very Good” agreement with
observed data at all comparison sites. It should be noted that the TSS concentration
measured at OF-BCEG-05 on 1/9/2018 was deemed as an outlier due to noted laboratory
QA/QC flags and was therefore excluded from the model calibration process.
Table 10. Water Quality Model Calibration Summary
Calibration
Metric
Constituent
Group
Santa Monica Bay Model Dominguez Channel Model
SMB-5-2 SMB-6-1 OF-BCEG-
05
OF-BCEG-
07
PBIAS (%)
Indicator
Bacteria[2] 28.4 -24.3 -3 +7
TSS n/a[1] n/a[1] -25 +23
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Calibration
Metric
Constituent
Group
Santa Monica Bay Model Dominguez Channel Model
SMB-5-2 SMB-6-1 OF-BCEG-
05
OF-BCEG-
07
Total Copper n/a[1] n/a[1] -21 +35
Total Lead n/a[1] n/a[1] +23 +18
Total Zinc n/a[1] n/a[1] -11 +10
Total Cadmium n/a[1] n/a[1] +28 +35
[1] No WBPCs associated with this constituent in Santa Monica Bay watershed.
[2] Fecal coliform for the Santa Monica Bay model; E. coli for the Dominguez Channel model.
Figure 9. Example Concentration Comparison Plot (Total Zinc)
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6. CRITICAL CONDITION DEFINITION
6.1. Santa Monica Bay WMA
6.1.1. Bacteria (Fecal Coliform)
Consistent with the critical condition definition in the Wet Weather SMBBB TMDL and
the Regional Board RAA Guidance (LARWQCB, 2014b), the Santa Monica Bay RAA
for bacteria was completed utilizing the 90th percentile wet year. Water Year 2011 5 was
previously identified for all watersheds in Los Angeles County using WMMS 2.0
hydrologic analysis of the most recent 10-years of rainfall data to define the 90th
percentile representative “water year” (LACFCD, 2020c). Water Year 2011 then served
as the basis for determination of wet weather bacteria critical condition in the Beach Cities
Santa Monica Bay WMA.
6.2. Dominguez Channel WMA
6.2.1. Indicator Bacteria (E. coli)
Similar to all existing Los Angeles region bacteria TMDLs for rivers, as well as the
Regional Board RAA Guidance (LARWQCB, 2014b), the Dominguez Channel RAA for
bacteria used the 90th percentile wet year. As discussed in Section 6.1.1, the 90th percentile
wet year timeframe was identified to be Water Year 2011 for the Dominguez Channel
WMA (LACFCD, 2020c).
6.2.2. Metals and Organic Pollutants
According to the Dominguez Channel and Greater Los Angeles and Long Beach Harbor
Toxics TMDL (herein referred as the Dominguez Channel Toxics TMDL), the critical
condition for metals and organic pollutants discharging to Dominguez Channel and
Torrance Lateral were defined as the 90th percentile daily pollutant load. The calibrated
Beach Cities Dominguez Channel LSPC watershed model was used to compute the daily
metals and TSS loads 6 on wet days between 2008 and 2018. The daily loads were
calculated and ranked for each pollutant, with the 90th percentile daily load (summarized
in Table 11) selected as the defining condition representing the required TLR that must
be achieved.
5 October 2010 to September 2011
6 Since organic pollutants cannot be modeled directly in WMMS 2.0, TSS is used as a surrogate to calculate
the 90th pollutant load day for organic pollutants
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Table 11. Dominguez Channel WMA 90th Percentile Daily Load Summary
Analysis
Region
(Receiving
Water)
Pollutant
90th
Percentile
Load
Load
Unit
90th
Percentile
Load Day
Runoff
Volume
During the 90th
Percentile
Load Day
(ac-ft)
DC-N-MB
(Dominguez
Channel
Freshwater)
TSS 1,904 lb/day 3/17/2012 5.5
Total Copper 1.3 lb/day 12/12/2011 8.4
Total Lead 0.2 lb/day 12/12/2011 8.4
Total Zinc 6.9 lb/day 12/12/2011 8.4
DC-N-RB
(Dominguez
Channel
Freshwater)
TSS 5,936 lb/day 10/30/2010 19.2
Total Copper 4.1 lb/day 12/17/2010 30.1
Total Lead 0.6 lb/day 12/17/2010 30.1
Total Zinc 22.0 lb/day 12/17/2010 30.1
DC-S
(Dominguez
Channel
Freshwater)
TSS 7,706 lb/day 11/30/2012 34.3
Total Copper 4.0 lb/day 11/6/2011 35.4
Total Lead 0.5 lb/day 11/6/2011 35.4
Total Zinc 18.4 lb/day 11/30/2012 34.3
DC-TL
(Torrance
Lateral and
Dominguez
Channel
Estuary[1])
TSS 15,299 lb/day 4/11/2012 50.8
Total Cadmium[2] 0.15 lb/day 1/21/2012 40.6
Total Copper 11.5 lb/day 1/21/2012 40.6
Total Lead 1.6 lb/day 1/21/2012 40.6
Total Zinc 65.1 lb/day 1/21/2012 40.6
[1] DC-TL drains to Dominguez Channel Estuary via Torrance Lateral.
[1]Cadmium is a pollutant of concern for Dominguez Channel Estuary only. However analysis region DC-TL discharges
to the Dominguez Channel Estuary and is shown in the TMDL for this WMA.
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7. TARGET LOAD REDUCTIONS
The following subsection documents the development of wet weather TLRs for the Beach
Cities EWMP area. The dry weather RAA approach described in Section 4.2 does not
require TLRs. See Section 10 for the dry weather RAA result.
7.1. Santa Monica Bay WMA
Wet weather pollutants of concern for the Santa Monica Bay WMA include fecal
coliform, PCBs, DDT, mercury, arsenic, trash, and marine debris. The following sections
describe the TLR development for each pollutant, or the justifications on why a modeled
TLR is not required to demonstrate reasonable assurance of compliance.
7.1.1. Bacteria (Fecal Coliform)
Utilizing the calibrated Beach Cities Santa Monica Bay LSPC watershed model, the
bacteria TLR was established by following the same modeling approach developed in the
original Beach Cities EWMP, which accounted for site-specific monitoring data at each
shoreline CML. As discussed in Section 3.1.2, the modeling methodology correlates the
bacteria load to the expected annual bacteria exceedance days, which is the Permit’s
WQBEL expression for the SMBBB TMDL.
The fecal coliform TLR was estimated by modeling a hypothetical detention basin at each
analysis region outlet. As the first step in this process, the allowable discharge days for
each analysis region was calculated as the TMDL-specified allowable exceedance days,
divided by the 10-year wet weather exceedance rate at the shoreline CML. This approach
makes use of site specific wet weather beach bacteria monitoring data to determine the
number of discharge days that result in the number of allowable exceedance days at the
shoreline. For analysis regions with anti-degradation-based allowable exceedance days,
a target load reduction of zero is assumed. This approach is consistent with the SMBBB
TMDL which acknowledges that historic bacteria exceedance rates for each of these
analysis regions are lower than that of the reference beach, on average, and therefore no
additional load reduction is required. This assumption applies for seven of the 11 total
SMBBB TMDL CMLs in Beach Cities Santa Monica Bay WMA – i.e., SMB-5-1, SMB-
5-3, SMB-5-4, SMB-5-5, SMB-6-2, SMB-6-5, and SMB-6-6. Historic wet weather
monitoring data at these sampling locations through TMDL Year 2019 confirm this
understanding, as the long-term exceedance rate at all seven sites varies between 7% and
24%. This is below the long-term wet weather exceedance rate at the reference beach
(26%) allowing the conclusion that no additional load reduction is required at these
locations.
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For analysis regions without anti-degradation-based allowable exceedance days, a
hypothetical basin was iteratively sized until discharge frequency at the outfall is less than
or equal to the allowable exceedance days at that monitoring location. Each hypothetical
downstream retention BMP included a diversion with a calculated hydraulic capacity that
provides full capture of flows and results in a model-derived bypass frequency (or number
of discharge days) for Water Year 2011 that achieves the allowable exceedance day
criteria. Each diversion for these conceptual BMPs was separately modeled to determine
the hydraulic capacity that results in full capture of discharge. The net load reduction
resulting from this conceptual BMP scenario (i.e., baseline analysis region load minus the
analysis region load with the diversion system and full capture retention BMP in place)
for Water Year 2011 is the TLR. For the RAA, reasonable assurance of compliance is
achieved when modeled load reductions associated with proposed BMPs is greater than
or equal to the TLR for each analysis region.
In summary, the following approach was implemented to calculate a TLR for each SMB
modeled analysis region without anti-degradation-based allowable exceedance days:
1. Each analysis region that does not currently comply with applicable TMDL limits
was modeled in LSPC for the 90th percentile wet year (Water Year 2011).
2. The existing, baseline condition (i.e., without an outlet retention BMP) was
modeled for each analysis region, resulting in a determination of the baseline fecal
coliform load for the 90th percentile water year (baseline load).
3. The 10-year historical wet weather exceedance percentage was determined by
dividing the total number of wet weather exceedance days by the total number of
discharge days in which wet weather was sampled.
4. The allowable number of discharge days for each analysis region was calculated
by dividing the total number of allowable exceedance days (17, per the TMDL)
by the exceedance percentage calculated in Step 3.
5. An in-stream diversion to a large hypothetical retention BMP at the outlet of each
analysis region was iteratively sized to reduce the number of discharge days to be
less than or equal to the allowable discharge days determined in Step 4.
6. Each diversion and hypothetical retention BMP was then modeled to produce a
mean fecal coliform load for the 90th percentile year (allowed load).
7. For each analysis region, the difference between the baseline load (Step 2) and
the allowed load (Step 6) resulted in a TLR for the 90th percentile year, which was
the target load reduction required to meet the 17 allowable TMDL exceedance
days for wet weather.
8. A TLR-equivalent 24-hour runoff management volume was estimated as the
maximum daily diverted volume during the critical condition (i.e. throughout the
modeled year). Both load-based TLR and the equivalent 24-hour runoff
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management volume are considered eligible Beach Cities EWMP compliance
metrics.
7.1.2. Pesticides and PCBs
Consistent with the original EWMP as well as the SMB PCBs and DDT TMDL, the
WLAs for the entire Santa Monica Bay WMA were set equal to the existing estimates of
annual loads for DDT and PCBs. Monitoring data collected as part of the Beach Cities
CIMP demonstrate that discharges of PCBs and DDTs from the Beach Cities Beach Cities
EWMP area into Santa Monica Bay are below the TMDL limits (Beach Cities WMG,
2020). Therefore, the current required additional load reduction to meet TMDL WLAs is
zero for PCBs and DDTs, and no BMP modeling analysis is required to demonstrate
compliance. For more information, see the Source Assessment portion of the revised
Beach Cities EWMP, Appendix B.
7.1.3. Mercury and Arsenic
Mercury and arsenic were recently added to the 303(d) list for Santa Monica Bay WMA.
However, CIMP monitoring data collected by the Beach Cities to date demonstrate that
outfall concentrations were consistently below the Ocean Plan objectives for these
parameters. As a result, no modeling was conducted for mercury or arsenic as part of the
revised RAA. For more information, see the Source Assessment portion of the revised
Beach Cities EWMP, Appendix B.
7.1.4. Trash and Marine Debris
Compliance with the SMB Debris TMDL will be met through a phased retrofit of full-
capture or partial capture systems throughout the Beach Cities Santa Monica Bay WMA
in combination with institutional measures (e.g., street sweeping with posted no-parking
on street sweeping days) to meet each interim and final compliance deadline. Hence, these
constituents do not require a TLR to be calculated and were not modeled as part of the
revised RAA.
7.1.5. Final Wet Weather TLR Summary for Santa Monica Bay
TLRs for each analysis region draining to a Santa Monica Bay CML are listed in Table
12. Consistent with the original EWMP, non-zero TLRs were only identified in two SMB
analysis regions – SMB-5-02 and SMB-6-01. Based on the number of anti-degradation
sites within the Beach Cities Santa Monica Bay WMA, coupled with the water quality
history at the other sites, these results are appropriate.
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Table 12. Santa Monica Bay WMA Wet Weather TLR
Analysis
Region
Critical
Condition
Baseline Load
(1012 MPN/
year)
Final Target Load Reduction
Absolute
(1012 MPN/
year)
% of
Baseline
Load
TLR
Equivalent 24-
Hour
Management
Volume (ac-ft)
SMB-5-1
90th percentile
water year
1.7 Anti-Degradation 0% 0
SMB-5-2 111.9 59.0 53% 67.1
SMB-5-3 7.5 Anti-Degradation 0% 0
SMB-5-4 2.6 Anti-Degradation 0% 0
SMB-5-5 39.0 Anti-Degradation 0% 0
SMB-6-1 112.1 54.7 49% 51.2
SMB-6-2 16.2 Anti-Degradation 0% 0
SMB-6-3 10.0 CIMP data shows compliance with final allowable
exceedance days. Hence no RAA required to
demonstrate compliance. SMB-6-4 4.1
SMB-6-5 15.3 Anti-Degradation 0% 0
SMB-6-6 1.2 Anti-Degradation 0% 0
7.2. Dominguez Channel WMA
Wet weather pollutants of concern in the Dominguez Channel WMA include toxicity,
total copper, total lead, total zinc, indicator bacteria, and benzo(a)pyrene. Total PCBs,
total DDTs, total cadmium, and total PAHs are additional WBPCs for Beach Cities
EWMP area tributary to Torrance Lateral and Dominguez Channel Estuary 7. While the
default WMMS 2.0 LSPC model represents a subset of these WBPCs, TLRs and target
loads for the other WBPCs were established using surrogate pollutants in order to comply
with the State Board’s requirement to demonstrate reasonable assurance of attainment of
all applicable water quality targets (SWRCB, 2020).
7.2.1. Metals
Total copper, total lead, and total zinc are Category 1 WBPCs in the Dominguez Channel
WMA due to the Dominguez Channel Toxics TMDL . Total cadmium is an additional
Category 1 WBPCs in Dominguez Channel Estuary due to the Toxics TMDL. Zero TLRs
were set for total lead since monitoring data from contributing outfalls have consistently
met the respective numeric targets.
7 For the Beach Cities EWMP area, analysis region DC-TL drains to Dominguez Channel Estuary via
Torrance Lateral. No other Beach Cities EWMP area drains to the Dominguez Channel Estuary or the
Torrance Lateral.
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Per the MS4 Permit, permittees shall be deemed TMDL compliant with meeting total
copper, total lead and total zinc WLAs if loads are less than the allocation when using
one of the following calculations:
1. For analysis regions tributary to Dominguez Channel freshwater and Torrance
Lateral - Daily loading of pollutants calculated as the water-column WQBEL
concentration 8 multiplied by the daily flow volume during the 90th percentile
loading day. The TMDL water-column WQBELs in the TMDL are based on
California Toxics Rule (CTR) aquatic life criteria maximum concentration
criteria.
2. For analysis regions tributary to Dominguez Channel freshwater - Daily mass
based WLA calculated as the daily mass-based MS4 WLA to Dominguez Channel
freshwater apportioned to Beach Cities WMG tributary area.
3. For analysis region(s) tributary to Torrance Lateral - Daily loading of pollutants
calculated as the sediment-column WQBEL concentration multiplied by the daily
TSS load during the 90th percentile loading day.
As such, the method that resulted in the least restrictive daily loading of pollutants was
used to determine the allowable load in TLR calculations.
According to the Beach CIMP outfall data, the Beach Cities WMG has been meeting all
the applicable interim MS4 WLAs for total copper, total lead and total zinc. Hence, zero
interim TLRs were assumed.
For total cadmium, the final MS4 WLA in the TMDL is expressed as the daily loading of
pollutants calculated as the sediment based WQBEL multiplied by the daily sediment
load during the 90th percentile load day. The TMDL WQBEL is based on the sediment
numeric targets in the Screening Quick Reference Tables (SQuiRTs) developed by
National Oceanic and Atmospheric Administration (NOAA).
The following approach was implemented to calculate a TLR for each metal in the Beach
Cities Dominguez Channel WMA:
1. The analysis region was modeled in LSPC for the 90th percentile load day defined
in Table 11 to obtain the baseline pollutant load.
2. The allowable load was calculated using the applicable metal TMDL WLA. For
pollutants with multiple WLAs, the WLA that resulted in the least restrictive
allowable load was selected for calculation of the TLR.
8 The Dominguez Channel Toxics TMDL is currently being reconsidered and may introduce the concept
of site-specific water-effect ratios for copper and lead, which have been adopted in other freshwater metal
TMDLs in the Los Angeles Region. The adoption of site-specific water-effect ratios may result in
significant deviation from the current WQBELs, requiring an update to the Beach Cities EWMP.
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3. The difference between the baseline load (Step 1) and the allowable load (Step 2)
determined the absolute TLR for the 90th percentile load day, the load reduction
required to meet the TMDL WLA. A percentage TLR was also calculated by
dividing the absolute TLR by the baseline pollutant load.
4. The TLR equivalent 24-hour volume was calculated as the average daily runoff
volume multiplied by the percentage TLR.
7.2.2. Pesticides, Organics, and PCBs
Total DDTs, total PCBs, benzo[a]pyrene and total PAHs are Category 1 WBPCs in
Dominguez Channel Estuary due to the Dominguez Channel Toxics TMDL.
Benzo[a]pyrene is a Category 3 WBPC for Beach Cities WMA tributary to the
Dominguez Channel freshwater due to CIMP monitoring results indicating potential
contribution towards water quality standard exceedances in the estuary. Zero TLRs were
set for total DDTs, total PCBs and total PAHs since the Beach Cities WMG has
continuously met the respective numeric targets according to Beach Cities CIMP outfall
monitoring data.
When representing Benzo[a]pyrene and total PAHs for the Dominguez Channel Estuary
and Benzo[a]pyrene for the Dominguez Channel freshwater segments, these constituents
cannot be modeled directly in WMMS 2.0 LSPC. Instead, TSS was modeled and used as
a surrogate to compute TLR for these organic pollutants. For representing benzo[a]pyrene
contributions to the Dominguez Channel freshwater segments, daily loading was
calculated as the TMDL water-column WQBELs multiplied by the daily flow volume
during the 90th percentile TSS loading day. For representing Benzo[a]pyrene and total
PAH contributions to the Dominguez Channel Estuary, the final MS4 WLA in the Permit
were expressed as the daily loading of pollutants calculated as the marine sediment-based
WQBEL multiplied by the average daily sediment load.
The following approach was implemented to calculate a TLR for each pesticide or PCB
in the Dominguez Channel portion of the Beach Cities WMA:
1. The analysis region was modeled in LSPC for the 90th percentile TSS load day
as defined in Table 11 to obtain the baseline TSS load
2. Particulate strength (pollutant-to-TSS ratio) for Benzo[a]pyrene and total PAHs
were calculated using paired wet weather monitoring data (e.g. pollutant
concentration and TSS concentration from the same sample) collected at outfall
monitoring locations in the Dominguez Channel watershed (OF-BCEG-05, OF-
BCEG-06, and OF-BCEG-07).
3. The baseline pollutant load was computed by multiplying the baseline TSS load
and the organic pollutant particulate strength.
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4. The allowable load was calculated using applicable TMDL WLAs.
5. The difference between the baseline load and the allowable load resulted in a TLR
for the 90th percentile load day, the load reduction required to meet the applicable
water quality standard. A percentage TLR was also calculated by dividing the
absolute TLR by the baseline pollutant load.
6. The TLR equivalent 24-hour was calculated as the daily runoff volume multiplied
by the percentage TLR.
7.2.3. Indicator Bacteria (E. coli)
Within the Beach Cities Dominguez Channel WMA9, a TLR approach was developed
based on allowable exceedance days. Dominguez Channel is 303(d)-listed for bacteria
and its targets were developed consistent with the reference system allowable exceedance
approach implemented for other Los Angeles region freshwater TMDLs. The DC has a
REC-2 beneficial use designation and a High Flow Suspension (HFS) Day allowance.
The Dominguez Channel TLR calculations for bacteria followed a similar methodology
as the Santa Monica Bay TLR calculations for fecal coliform. It was assumed that 19%
of non-high flow suspension days could exceed 4000 MPN/100mL based on the historical
exceedance rates observed at other freshwater bodies in the Los Angeles region (Schiff,
Griffith & Lyon, 2005.). This approach is consistent with the Malibu Creek Watershed
Bacteria TMDL approach for developing waste load allocations expressed as allowable
exceedance days (LARWQCB, 2012b)
7.2.4. Toxicity
According to Beach Cities and Dominguez Channel CIMP data, receiving water
monitoring from within the Dominguez Channel has not exceeded the interim and final
toxicity WQBELs to date. Hence, reasonable assurance is demonstrated and a TLR was
not developed for toxicity for the Beach Cities WMG.
9 Includes area tributary to Dominguez Channel Freshwater, Torrance Lateral and Dominguez Channel
Estuary.
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7.2.5. Final Wet Weather TLR Summary
By implementing the steps described above, TLRs were developed for each modeled
pollutant. TLRs for each pollutant are listed in Table 13. A representative 24-hour
management volume was selected for each analysis region. For each analysis region, the
largest 24-hour management volume was selected as the target compliance metric, since
management of the largest volume will result in management of all others 10.
10 Total copper was not included in the assessment of the largest 24-hour management volume, since
significant load reductions will be achieved via the copper brake pad reduction (see Section 8.2.1). As a
result, the management volumes needed to meet applicable copper TLRs using structural BMPs are
significantly reduced
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Table 13. Dominguez Channel WMA Wet Weather TLRs
Analysis
Region
(Receiving
Water)
Pollutant Critical Condition Baseline Load
Target Load Reduction
Absolute
% of
Baseline
Load
TLR Equivalent 24-
Hour Management
Volume (ac-ft)
DC-N-MB
(Dominguez
Channel
Freshwater)
Total Copper 90th percentile daily load 1.3 lb/day 1.1 lb/day 82% 7.3
Total Lead CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance
Total Zinc 90th percentile daily load 6.9 lb/day 5.3 lb/day 76% 6.7[1]
E. coli 90th percentile water year 46.1 1012 MPN/yr 19.0 1012 MPN/yr 41% 2.4
Benzo[a]pyrene 90th percentile daily load 2.6E-03 lb/day 1.8E-03 lb/day 70% 4.0
Toxicity CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance
DC-N-RB
(Dominguez
Channel
Freshwater)
Total Copper 90th percentile daily load 4.1 lb/day 3.3 lb/day 81% 24.3
Total Lead CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance
Total Zinc 90th percentile daily load 22.0 lb/day 16.3 lb/day 74% 22.3[1]
E. coli 90th percentile water year 149.8 1012 MPN/yr 53.0 1012 MPN/yr 35% 9.7
Benzo[a]pyrene 90th percentile daily load 7.7E-03 lb/day 5.2E-03 lb/day 67% 12.8
Toxicity CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance
DC-S
(Dominguez
Channel
Freshwater)
Total Copper 90th percentile daily load 4.0 lb/day 3.0 lb/day 76% 27.1
Total Lead CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance
Total Zinc 90th percentile daily load 18.4 lb/day 11.9 lb/day 65% 22.2[1]
E. coli 90th percentile water year 393.8 1012 MPN/yr 179.1 1012 MPN/yr 45% 15.3
Benzo[a]pyrene 90th percentile daily load 1.0E-02 lb/day 5.5E-03 lb/day 55% 18.7
Toxicity CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance
DC-TL
(Torrance
Lateral and
Dominguez
Channel
Estuary)
Total Copper 90th percentile daily load 11.5 lb/day 10.4 lb/day 91% 36.8
Total Lead CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance
Total Zinc 90th percentile daily load 65.1 lb/day 57.4 lb/day 88% 35.8[1]
Total Cadmium 90th percentile daily load 0.15 lb/day 0.13 lb/day 87% 35.2
E. coli 90th percentile water year 360.8 1012 MPN/yr 175.3 1012 MPN/yr 49% 16.2
Benzo[a]pyrene 90th percentile daily load 2.0E-02 lb/day 1.3E-02 lb/day 67% 34.1
Total PAHs CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance
Toxicity CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance
Total PCBs CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance
Total DDTs CIMP data shows no exceedance in the past 5 years. Hence no RAA needed to demonstrate compliance
[1]Bold value is the representative 24-hour management runoff volume for each analysis region.
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8. STORMWATER CONTROL OVERVIEW
8.1. Methods to Select and Prioritize BMPs
To demonstrate reasonable assurance, BMPs were identified in a prioritized manner to
meet the TLRs. Prioritization was based on cost (lower cost BMPs were prioritized first);
BMP effectiveness for the pollutants of concern (BMPs that 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 WMG.
It was assumed that the baseline model calibration accounted for existing BMPs that are
universally implemented in the Beach Cities EWMP area (e.g., street sweeping, catch
basin and storm drain cleaning, low impact development prior to June 2020, etc.). As
discussed in Section 5.1, monitoring data from watersheds with existing regional
stormwater BMPs and green streets were not used for calibration. The effectiveness of
existing, location-specific regional BMPs outside the calibration areas has been
quantified in this revised RAA.
The RAA was performed according to the following steps:
1. Calculate load reductions associated with future, quantifiable non-structural
BMPs (e.g., copper reductions due to brake pad phase-out);
2. Calculate load reductions associated with existing structural BMPs.
3. Calculate load reductions for proposed regional and distributed BMPs that were
identified in existing plans; and
4. If necessary, identify new regional or distributed BMPs to meet any remaining
TLR.
8.2. Quantified Non-Structural BMPs
In accordance with the State Board Order (SWRCB, 2020), all non-structural BMP
credits are required to be adequately justified. Since data is quite limited with respect to
load reductions achieved by most non-structural BMPs, the Beach Cities RAA
incorporated the assumption that non-structural BMPs implemented prior to June 2020
(including enhanced minimal control measures [MCMs]) have been accounted for as part
of the data used in the calibrated baseline condition. As a result, no “blanket” non-
structural BMP load reduction credit has been incorporated into the revised RAA.
Source controls implemented by the Beach Cities WMG 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 including implementation of each
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agency’s Sanitary Sewer Management Plan consistent with Statewide WDRs, 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 the original EWMP. Although no pollutant load reductions were assumed in
the RAA for the implementation of these BMPs, the Beach Cities WMG will continue to
implement a variety of these source controls that have proven to be effective.
One specific non-structural regulatory BMP program was accounted for in the revised
Beach Cities EWMP RAA for which a load reduction could be quantified and forecasted
based on phased implementation – elimination of copper in brake pads.
8.2.1. Copper Brake Pad Reduction
As was the case in the original Beach Cities EWMP, a load reduction was assumed for
copper due to the phased 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 technical study for the California
Stormwater Quality Association (CASQA) describing the expected percent reduction for
copper as a result of the passage of SB 346 (TDC Environmental, 2013). The TDC study
identified three possible implementation scenarios, the least aggressive of which
estimated that a 52% load reduction in copper will be achieved by 2032 due to the brake
pad phase-out.
Since the referenced study assumed a 21.2% reduction in urban runoff copper by 2020,
and the RAA model was calibrated with local water quality data through June 2020, the
load reduction accounted for in the revised RAA was estimated as a weighted fraction of
52%. The difference in estimated total load reduction between 2032 and 2020 (i.e., 52%
- 21.2%, or 30.8%) was divided by the assumed remaining load in 2020 (100% - 21.2%,
or 78.8%) to estimate the remaining expected load reduction due to the copper brake pad
phase-out. Therefore, a 39.1% load reduction was assumed for copper in the Beach Cities
Dominguez Channel WMA.
To avoid double-counting load reductions, this reduction was applied to the copper load
before accounting for future BMP load reductions (i.e., 39.1% was applied to the baseline
loads before all other BMP load reductions were accounted for, since BMP performance
is dependent on influent loads).
8.3. Modeling Structural BMPs
To represent structural BMPs, WMMS 2.0 SUSTAIN was used to account for BMP
storage, infiltration, inflow, and outflow capacities using available BMP as-built
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drawings or conceptual drawings provided by the Beach Cities WMG. For structural
BMPs that provide flow-through treatment, the treatment efficacy was represented as
either fixed effluent concentration or as a percentage of influent concentration reduction
extracted from the following data sources:
• WMMS 2.0 Phase II Report: BMP Model and Optimization Framework
(LACFCD, 2020b), which includes effluent concentrations of BMPs included in
the default WMMS 2.0 SUSTAIN model.
• The International Stormwater Database (IBMPDB; www.bmpdatabase.org),
which is a comprehensive source of BMP performance information, comprised of
data from a peer-reviewed collection of studies that have monitored the
effectiveness of a variety of BMPs in treating water quality pollutants for a variety
of land use types.
Several existing regional projects were sized (or planned to be sized) to capture runoff
from at least the 85th percentile, 24-hour storm event. As controls that fully capture the
85th percentile, 24-hour storm are an alternative form of compliance, reasonable
assurance is assumed to be achieved in the project drainage areas. These projects and their
tributary drainage areas were excluded from this RAA analysis. Table 14 summarizes the
85th percentile 24-hour projects with their locations shown in Figure 10.
Table 14. Summary of Full 85th-Percentile, 24-Hr Design Storm Capture Project
Analysis Region Project Name
SMB-5-2
Wylie Basin
Beach Cities Green Streets 1 (Manhattan Beach 19th Street)
SMB-6-1
Torrance Basin Enhancement and Expansion Project (Henrietta, Amie, and
Entradero)
Beach Cities Green Streets 2 (Manhattan Beach Artesia Blvd.)
Beach Cities Green Streets 3 (Redondo Beach Anita Street)
Beach Cities Green Streets 4 (Redondo Beach Ford Ave.)
Beach Cities Green Streets 5 (Torrance 191st Street)
Beach Cities Green Streets 6 (Torrance Northwest)
Beach Cities Green Streets 7 (Hermosa Beach)
DC-N-MB Manhattan Village Mall LID
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Figure 10. Overview of 85th-Percentile, 24-Hour Storm Capture Projects
8.3.1. Regional and Distributed Structural Projects
Through the project screening and evaluation process, a total of eight projects, beyond
those capturing the 85th percentile, 24-hr storm and described above, are proposed in this
RAA. Table 15 summarizes the project types and key modeling parameters. The project
locations are shown in Figure 11. Project fact sheets are included in the EWMP within
Appendix E.
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Figure 11. Modeled Regional and Distributed Projects
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Table 15. Summary of Modeled Projects
Analysis
Region Project Lead WMG
Member BMP Type
Drainage
Area
(ac)
Static BMP
Volume
(ac-ft)
Infiltration
/Treatment Rate
(cfs)
SMB-5-2 28th Street Storm Drain Infiltration
Project
Manhattan
Beach
Subsurface Infiltration 1480 1.2 71.5
SMB-6-1
Fulton Playfield Infiltration Project Redondo
Beach
Subsurface Detention
Basin & Infiltration
Wells
457 7.4 13
Hermosa Beach Distributed Drywells Hermosa
Beach
Distributed Infiltration
Wells
118 0.1 11
Redondo Beach Herondo Distributed
Infiltration Project
Redondo
Beach
Distributed Infiltration
Wells[1]
342 0.3 22
Hermosa Beach 8th Street Green
Infrastructure Project
Hermosa
Beach
Bioretention 8 <0.01 <0.01
DC-N-MB Manhattan Beach Dominguez Channel
Distributed Infiltration Project
Manhattan
Beach
Distributed Infiltration
Wells[1]
255 0.1 11
DC-N-MB/
DC-N-RB
Alondra Park Stormwater Capture
Project
Los Angeles
County
Subsurface Detention
& Treatment
1445 7.1 0.9
DC-N-RB Glen Anderson Park Regional
Infiltration Project
Redondo
Beach
Subsurface Retention
and Infiltration
483 0.3 20
DC-N-RB Redondo Beach Dominguez Channel
Distributed Infiltration Project
Redondo
Beach
Distributed Infiltration
Wells[1]
292 0.2 14
DC-S
Torrance Parkway BMP Torrance
Bioretention,
Treatment, and
Infiltration Facilities
This project was not modeled due to uncertainty of
its future design and performance. TLRs for DC-S
and DC-TL will be used as performance metrics
during project siting and design. DC-TL
[1] Drywells were used as a representative BMP through the revised RAA. Equivalent infiltration BMPs with equivalent performance may be considered
at project design phase.
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8.3.2. Low Impact Development Applied to Redevelopment
The 2012 MS4 Permit established new criteria for redevelopment projects, requiring
certain sized projects to capture, retain, or infiltrate the 85th percentile, 24-hr design storm
or the 0.75-inch design storm, whichever is greater, or treat 150% of the peak stormwater
runoff rate resulting from a 1-year, 1-hour design storm, via the implementation of low
impact development (LID) BMPs. All LID BMPs constructed through June 2020 were
assumed to be accounted for in the model via the monitoring and calibration process.
Moving forward, LID was assumed to be implemented at the annual redevelopment rate
of 0.08% per year, assuming implementation from July 2020 until the applicable final
TMDL deadline.11 In accordance with this projected redevelopment rate, which was
summarized in the 2019-20 Beach Cities Annual Watershed Report (Beach Cities WMG,
2020), redevelopment that is subject to an LID ordinance was modeled assuming an
annual redevelopment of 0.08% per year across all Beach Cities agency jurisdictions for
residential, commercial, industrial, institutional, and transportation land uses. To estimate
load reductions associated with these redevelopment BMPs, the land use percentages
were multiplied by the respective land use areas in each analysis region. This resulted in
a calculated area that would be treated by LID BMPs each year. This area was multiplied
by the applicable number of years until the TMDL final deadlines, as LID BMPs will be
implemented each year at the assumed rate. The total land use area assumed to be
redeveloped for each analysis region was then modeled as being treated by assumed
required BMPs and the total load reduction was quantified.
To maintain consistency with the BMP types observed in redevelopment activities to-
date in the watershed, 96% of the redeveloped land is projected to implement bioretention
or similarly functioning systems that fully capture the 85th percentile, 24-hour storm
runoff. The remaining 4% of the redeveloped area will implement biofiltration systems
that treat 1.5 times the 85th percentile, 24-hour storm storm runoff.
Modeling parameters of the bioretention and biofiltration units are summarized in Table
16.
11 July 2026 was assumed to be the final wet weather deadline.
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Table 16. Redevelopment LID BMP Modeling Parameters
Bioretention Biofiltration
Max Years of
Redevelopment
Modeled
5 years[1] (Santa Monica Bay)
12 years[2] (Dominguez Channel)
Pond Depth 12 inches[3]
Infiltration Rate 5 in/hr[3] n/a
Soil Depth (in) 36
Effluent Concentration
Total Cadmium n/a 0.07 ug/L[3]c
Total Copper n/a 5.7 ug/L[3]c
Total Lead n/a 0.32 ug/L[3]c
Total Zinc n/a 12 ug/L[3]c
TSS n/a 10 mg/L[3]
Indicator Bacteria n/a See Footnote 4
[1] The Beach Cities WMG joined the County of Los Angeles’s request for a 5-year Time Schedule Order
(TSO) for the SMBBB Wet Weather TMDL. Hence, it is assumed that the Beach Cities WMG will have to
meet the final WLAs by July 2026.
[2] Based on the effect year of the final Dominguez Channel Toxics TMDL (2032).
[3] Default WMMS 2.0 SUSTAIN parameters for bioretention/biofiltration BMPs (LACFCD, 2020b)
[4] It is assumed that biofiltration BMP does not provide significant indicator bacteria treatment.
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9. WET WEATHER RAA RESULTS
9.1. Santa Monica Bay WMA
Load reduction calculations for the Beach Cities Santa Monica Bay WMA are
summarized in Table 17. Through the RAA, the collective load reductions achieved by
all existing and proposed BMPs achieved all the TLRs within the analysis region. Hence,
reasonable assurance of compliance is demonstrated.
As discussed in Section 7.1.5, a TLR-equivalent 24-hour stormwater management
volume was computed for each non-zero TLR. Through the RAA, the 24-hour
management volume achieved by a project was computed as the representative volume
apportioned to the load reduction that was or would be achieved by the project. The
resultant 24-hour management volume of a project may or may not be equal to its static
detention capacity shown in Table 15. The approach of evaluating the 24-hour
management volume metric to the TLR resulted in prioritizing more efficient BMPs that
provide greater load reduction per BMP capacity per day (24-hour period). The 24-hour
management volume of each project is shown in Figure 12.
To spatially represent the RAA output, the 24-hour management volume is illustrated in
Figure 13. As shown in the figure, analysis regions with a zero calculated TLR (e.g., anti-
degradation areas; areas demonstrating compliance via water quality data) were assigned
a 0 acre-feet 24-hour stormwater management volume. The 24-hour management volume
of a regional project was spatially represented by its drainage area. Drainage areas to an
85th percentile, 24-hour design capture project are hatched, indicating these areas
demonstrate compliance through the alternative compliance path of full 85th percentile,
24-hour design stormwater capture.
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Table 17. Beach Cities SMB WMA RAA Summary
Analysis
Region
Fecal Coliform Target Load Reduction
(TLR) BMP Load Reduction (LR) Summary
10^12
MPN/yr
% of
Baseline
Load
TLR
Equivalent
24-Hour
Management
Volume
(ac-ft)
LID Redevelopment Regional Project Distributed Project Total Load Reduction RAA Achieved? % of
Baseline
Load
24-Hour
Volume
(ac-ft)
% of
Baseline
Load
24-Hour
Volume
(ac-ft)
% of
Baseline
Load
24-Hour
Volume
(ac-ft)
% of
Baseline
Load
24-Hour
Volume
(ac-ft)
SMB-5-
01
Anti-
Degradation 0% 0 TLR = 0% for Anti-degradation site. No RAA needed n/a
SMB-5-
02 59.0 53% 67.1 0.3% 0.4 64% 81.5 0% 0 64.3% 81.9 Yes
SMB-5-
03
Anti-
Degradation 0% 0 TLR = 0% for Anti-degradation site. No RAA needed n/a
SMB-5-
04
Anti-
Degradation 0% 0 TLR = 0% for Anti-degradation site. No RAA needed n/a
SMB-5-
05
Anti-
Degradation 0% 0 TLR = 0% for Anti-degradation site. No RAA needed n/a
SMB-6-
01 54.7 49% 51.2 0.3% 0.3 24.8% 25.9 24.1% 25.2 49.1% 51.4 Yes
SMB-6-
02
Anti-
Degradation 0% 0 TLR = 0% for Anti-degradation site. No RAA needed n/a
SMB-6-
03 0.0 0% 0 TLR = 0% based on historical monitoring data. No RAA needed n/a
SMB-6-
04 0.0 0% 0 TLR = 0% based on historical monitoring data. No RAA needed n/a
SMB-6-
05
Anti-
Degradation 0% 0 TLR = 0% for Anti-degradation site. No RAA needed n/a
SMB-6-
06
Anti-
Degradation 0% 0 TLR = 0% for Anti-degradation site. No RAA needed n/a
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Note: Due to comparatively low volumes, LID redevelopment is not shown in the figure
Figure 12. 24-Hour Management Volume Breakdown in Santa Monica Bay WMA
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Figure 13. 24-Hour Management Mapping in Santa Monica Bay WMA.
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9.2. Dominguez Channel WMA
Load reduction calculations for the Beach Cities Dominguez Channel WMA are
summarized in Table 18. Reasonable assurance was demonstrated in all analysis regions.
As discussed in Section 7.2.5, a representative 24-hour stormwater management volume
was determined for each analysis region. The 24-hour management volume of the projects
are shown in Figure 14. It should be noted that, the Torrance Parkway Stormwater BMPs
are not explicitly modeled in the RAA. The Beach Cities WMG has submitted a Safe,
Clean Water Technical Resource Program application titled “Prioritize Parkway BMPs
for Dominguez Channel Toxics TMDL” to assist in project siting. The Beach Cities
WMG intends to use the EWMP compliance metrics summarized under the “Regional
Project” column in Table 18 as the design criteria. The WMG expects to deploy a
combination of catch basin inserts, green streets and parkway stormwater capture project
to meet the TLR and the 24-hour management volume need through the Technical
Resources Study.
To spatially represent the RAA output, the 24-hour management volume is illustrated in
Figure 15. The 24-hour management volume of each regional project was applied to its
drainage area. The volume assigned to areas draining to multiple projects were the
cumulative volumes from all projects. Drainage area to a full 85th percentile 24-hour
design capture project was hatched, indicating theses area demonstrated compliance
through the alternative compliance path of full 85th percentile 24-hour design stormwater
capture. In addition, area covered under separate stormwater permit (e.g. Caltrans right-
of-way, Torrance Refinery plant) was hatched.
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Table 18. Beach Cities DC WMA RAA Summary Analysis Region[1] Pollutant
Final Target Load
Reduction
BMP Load Reduction Summary
Non-Structural BMP LID Redevelopment Regional Project Distributed Projects Total Load Reduction Assurance Achieved? Absolute % Absolute % Absolute % Absolute % Absolute % Absolute % DC-N-MB (DC Freshwater) Total Copper 1.1 lb/day 82% 0.5 lb/day 39% 0.01 lb/day 0.9% 0.2 lb/day 16% 0.4 lb/day 33% 1.1 lb/day 89% Yes
Total Lead CIMP data shows no exceedance in the past 5 years. No RAA needed n/a
Total Zinc 5.3 lb/day 76% 0 lb/day 0% 0.1 lb/day 0.9% 1.6 lb/day 23% 3.7 lb/day 54% 5.4 lb/day 78% Yes
E. coli 19.0 1012
MPN/yr 41% 0 1012
MPN/yr 0% 0.3 1012
MPN/y 0.7% 8.7 1012
MPN/yr 19% 19.5 1012
MPN/yr 42% 28.5
1012
MPN/
yr
62% Yes
Benzo[a]
pyrene
1.8
E-03 lb/day 70% 0 lb/day 0% 2.4
E-05 lb/day 0.9% 4.9
E-04 lb/day 19% 1.4
E-03 lb/day 56% 2.0
E-03 lb/day 76% Yes
24-Hour
Management
Need
6.7[2] ac-ft 100% 0 ac-ft 0% 0.1 ac-ft 0.9% 1.9 ac-ft 29% 5.2 ac-ft 77% 7.2 ac-ft 100
% Yes DC-N-RB (DC Freshwater) Total Copper 3.3 lb/day 81% 1.6 lb/day 39% 0.04 lb/day 0.9% 0.5 lb/day 13% 1.3 lb/day 32% 3.4 lb/day 85% Yes
Total Lead CIMP data shows no exceedance in the past 5 years. No RAA needed n/a
Total Zinc 16.3 lb/day 74% 0 lb/day 0% 0.2 lb/day 1.0% 4.1 lb/day 19% 12.4 lb/day 56% 16.7 lb/day 76% Yes
E. coli 53.0 1012
MPN/ 35% 0 1012
MPN/y 0% 1.1 1012
MPN/y 0.7% 49.5 1012
MPN/yr 33% 19.1 1012
MPN/yr 13% 69.7
1012
MPN/
yr
47% Yes
Benzo[a]pyre
ne
5.2
E-03 lb/day 67% 0 lb/day 0% 7E-05 lb/day 1.0% 2E-
03 lb/day 25% 4E-03 lb/day 48% 6E-03 lb/day 73% Yes
24-Hour
Management
Need
22.3[2] ac-ft 100% 0 ac-ft 0% 0.2 ac-ft/ 1.0% 15.5 ac-ft 69% 8.3 ac-ft 37% 24.0 ac-ft 100
% Yes DC-S (DC Freshwate Total Copper 3.0 lb/day 76% 1.5 lb/day 39% 0.1 lb/day 0.9% 0 lb/day 0% 1.4 lb/day 36% 3.0 lb/day 76% Yes
Total Lead CIMP data shows no exceedance in the past 5 years. No RAA needed n/a
Total Zinc 11.9 lb/day 65% 0 lb/day 0% 0.2 lb/day 1.0% 0 lb/day 0% 11.7 lb/day 64% 11.9 lb/day 65% Yes
604
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Final Target Load
Reduction
BMP Load Reduction Summary
Non-Structural BMP LID Redevelopment Regional Project Distributed Projects Total Load Reduction Assurance Achieved? Absolute % Absolute % Absolute % Absolute % Absolute % Absolute %
E. coli 179.1 1012
MPN/y 45% 0 10^12
MPN/yr 0% 2.2 1012
MPN/yr 0.6% 0 10^12
MPN/yr 0% 176.9 10^12
MPN/yr 45% 179.1
1012
MPN/
yr
45% Yes
Benzo[a]pyre
ne
5.5
E-03 lb/day 55% 0 lb/day 0% 9.4
E-05 lb/day 0.9% 0 lb/day 0% 5.5
E-03 lb/day 54% 5.5
E-03 lb/day 55% Yes
24-Hour
Management
Need
22.2[2] ac-ft 100% 0 ac-ft 0% 0.3 ac-ft 1.1% 0 ac-ft 0% 21.9 ac-ft 99% 22.2 ac-ft 100
% Yes DC-TL (DC Estuary and Torrance Lateral) Total Copper 10.4 lb/day 91% 4.5 lb/day 39% 0.1 lb/day 1.0% 0 lb/day 0% 5.8 lb/day 51% 10.4 lb/day 91% Yes
Total Lead CIMP data shows no exceedance in the past 5 years. No RAA needed n/a
Total Zinc 57.4 lb/day 88% 0 lb/day 0% 0.6 lb/day 1.0% 0 lb/day 0% 56.8 lb/day 87% 57.4 lb/day 88% Yes
Total
Cadmium 0.13 lb/day 87% 0 lb/day 0% 1.0
E-3 lb/day 0.7% 0 lb/day 0% 0.13 lb/day 87% 0.13 lb/day 87% Yes
E. coli 175.3 1012
MPN/yr 49% 0 1012
MPN/y 0% 2.1 1012
MPN/yr 0.6% 0 1012
MPN/yr 0% 173.2 1012
MPN/yr 49% 175.3
1012
MPN/
yr
49% Yes
Benzo[a]pyre
ne
1.3
E-02 lb/day 67% 0 lb/day 0% 2E-04 lb/day 0.9% 0 lb/day 0% 1.3
E-02 lb/day 66% 1.3
E-02 lb/day 67% Yes
Total PAHs CIMP data shows no exceedance in the past 5 years. No RAA needed n/a
24-Hour
Management
Need
35.8[2] ac-ft 100% 0 ac-ft 0% 0.3 ac-ft 1.0% 0 ac-ft 0% 35.5 ac-ft 99% 35.8 ac-ft 100
% Yes
Total DDT CIMP data shows no exceedance in the past 5 years. No RAA needed n/a
Total PCB CIMP data shows no exceedance in the past 5 years. No RAA needed n/a
[1] Corresponding receiving water is also listed. DC = Dominguez Channel.
[2 ]Please see Table 13 on how the representative 24-hour management volume was selected for each analysis region.
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Note: Due to comparatively low volumes, LID redevelopment is not shown in the figure
Figure 14. 24-Hour Management Volume Breakdown in Dominguez Channel
WMA
606
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Figure 15. 24-Hour Management Volume Mapping in Dominguez Channel WMA
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10. DRY WEATHER RAA RESULT
The dry weather RAA was performed in accordance with the semi-quantitative approach
outlined in Section 4.2. A summary of the analysis is shown in Table 19. WMA-specific
discussion of the dry weather RAA is presented in the following subsections.
Table 19. Dry Weather RAA Summary for Dominguez Channel WMA.
WMA Analysis
Region
Is non-exempt dry
weather flow
currently non-existent
and/or sufficiently
treated or diverted?
Are sufficient
structural BMP
proposed to intercept
100% of dry weather
runoff?
Is dry weather
reasonable
assurance
demonstrated?
Santa Monica Bay All Yes n/a Yes
Dominguez
Channel
(including
Torrance Lateral)
DC-N-RB Yes Proposed Yes
DC-N-MB Yes Proposed Yes
DC-S Yes Proposed Yes
DC-TL Yes Proposed Yes
10.1. Santa Monica Bay WMA
According to monitoring and observation data collected through the Beach Cities CIMP,
the effectiveness of low flow diversions that intercept and divert 100% of non-exempt
dry weather flow from the receiving water is consistently confirmed by observations.
Therefore, reasonable assurance of compliance during dry weather is demonstrated for
the Beach Cities Santa Monica Bay WMA.
10.2. Dominguez Channel WMA
For Beach Cities DC (including Torrance Lateral) WMA, a dry weather RAA was
performed in accordance with the approach outlined in Section 4.2. The Beach Cities
WMG has attempted to eliminate non-exempt dry weather MS4 discharges using a suite
of structural BMPs and non-structural source controls (e.g., water conservation
incentives, enhanced IDDE efforts, enhanced education/outreach, and
inspection/enforcement to prevent sources of non-stormwater flow). To date, monitoring
has shown that the WMG has been successful at this endeavor, and although dry weather
flows do still exist in some outfalls draining to the DC, particularly within Torrance
Lateral, the WMG has successfully demonstrated that these discharges are considered
conditionally exempt.
In parallel to the ongoing effort of fully eliminating non-exempt dry weather MS4
discharges, the Beach Cities WMG has also planned to utilize structural BMPs to
intercept additional dry weather runoff that may cause or contribute to receiving water
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exceedances. The Alondra Park Stormwater Capture Project will intercept and capture
100% of dry weather runoff from both the DC-N-RB and DC-N-MB analysis regions. In
addition, the City of Torrance plans to provide significant parkway BMP retrofits
throughout the DC-S and DC-TL analysis regions, with a particular focus on areas that
consistently discharge to the Dominguez Channel during dry weather. For the purposes
of this EWMP, and consistent with the original EWMP, it has been assumed that such
parkway BMP retrofits will be sufficient to handle the dry weather bacteria loads tributary
to the discharge locations. Therefore, reasonable assurance of compliance during dry
weather is demonstrated for the Beach Cities Dominguez Channel WMA.
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11. CONCLUSIONS
To update the RAA for the revised Beach Cities EWMP, a modeling approach that
utilized WMMS 2.0 was applied using the rationale, analytical basis, and process
described in this RAA report. The RAA process:
1. Applied an acceptable model tailored to the Beach Cities WMG based on
available outfall and receiving water data collected through June 2020.
2. Calculated TLRs necessary to achieve applicable compliance targets.
3. Demonstrated that the existing and proposed suite of projects will attain the TLRs.
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12. REFERENCES
Beach Cities WMG (Watershed Management Group). 2020. Annual Watershed Report –
Reporting Year 2019 – 20.
Schiff, K.C., J.F. Griffith, G. Lyon. 2005. Microbiological water quality at reference
beaches in southern California during wet weather. Technical Report 448. Southern
California Coastal Water Research Project. Westminster, CA.
LACFCD (Los Angeles Flood Control District). 2020a. WMMS 2.0 Average and 90th
Percentile Water Year Simulation. Accessed December 2020 from <link>
LACFCD (Los Angeles Flood Control District). 2020b. WMMS 2.0 Phase II Report:
BMP Model and Optimization Framework. Accessed December 2020 from <link>
LACFCD (Los Angeles Flood Control District). 2020c. WMMS 2.0 Average & 90th
Percentile Water Year. Accessed January 2021 from <link>
LARWQCB (Los Angeles Regional Water Quality Control Board). 2011. Attachment A
to Resolution No. R11-009. Amendment to the Water Quality Control Plan - Los Angeles
Region to Incorporate the TMDL for Toxic Pollutants in Dominguez Channel and
Greater Los Angeles and Long Beach Harbor Waters. Adopted May 5
LARWQCB (Los Angeles Regional Water Quality Control Board). 2012. Attachment A
to Resolution No. R12-009. Amendment to the water quality control plan for the Los
Angeles Region to revise the TMDL for bacteria in the Malibu Creek Watershed. Adopted
June 7.
LARWQCB (Los Angeles Regional Water Quality Control Board). 2014a. Guidelines
for Conducting Reasonable Assurance Analysis in a Watershed Management Program,
Including an Enhanced Watershed Management Program. Los Angeles, CA.
LARWQCB (Los Angeles Regional Water Quality Control Board). 2014b. Water Quality
Control Plan: Los Angeles Region Basin Plan for the Coastal Watersheds of Los Angeles
and Ventura Counties. Accessed January 2021 from <link>.
SWRCB (State Water Resources Control Board). 2020. In the Matter of Review of
Approval of Watershed Management Programs and an Enhanced Watershed
Management Program Submitted Pursuant to Los Angeles Regional Water Quality
Control Board Order R4-2012-0175. SWRCB/OCC FILES A-2386, A-2477 & A-2508.
Sacramento, CA.
611
App D. RAA Report (2021-05-17)_clean.docx 58 May 2021
TDC Environmental. 2013. Estimate of Urban Runoff Copper Reduction in Los Angeles
County from the Brake Pad Copper Reductions Mandated by SB 346. Prepared for
Richard Watson & Associates, Inc. Accessed January 3, 2021.
612
Attachment D.1
Supplementary Calibration Exhibits
613
Water Quality Calibration
E. Coli
614
Water Quality Calibration
E. Coli
615
Water Quality Calibration
Total Cadmium
616
Water Quality Calibration
Total Copper
617
Water Quality Calibration
Total Lead
618
Water Quality Calibration
Total Copper
619
Beach Cities Watershed
Management Group
Revised EWMP
Appendix E:
Project Concept Fact
Sheets
JUNE 2021
620
The City of Manhattan Beach (City)is implementing the 28th
Street Storm Drain Infiltration Project (Project)to improve water
quality at the beach and in Santa Monica Bay by reducing
discharges from the storm drain system.The Project will capture
and infiltrate runoff and is split into two phases.Phase 1
includes approximately 48 drywells at the 26th Street Parking
Facility and Phase 2 includes an infiltration system on the beach.
The 26th Street Parking
Facility is one block East of
Manhattan Beach and
bounded by 26th Street,27th
Street,Manhattan Avenue,
and Ocean Drive.Surface
runoff from the tributary
area enters the storm drain
network and discharges to
Santa Monica Bay.
Existing Site Conditions
Infiltration
Bypass 27th Street
Storm
DrainRouted Flow
Impervious
Area to 28th
Street
Storm
Drain
Infiltration: Drywells
*Products shown above were used as examples for sizing and cost analyses; other equivalent treatment systems may be used.
Proposed BMP Project
City: Manhattan Beach Latitude: 33.894050 Longitude: -118.416294
Phase 1 BMP Treatment Process
Planning-Level Cost Estimate1
Tributary Area (ac)1,520 24-Hour Treatment
Volume (ac-ft)81.91No. of Proposed
Drywells 48
Bacteria Load
Reduction During
Critical Condition
7.2 x 1013 MPN/year
(64% of Baseline Bacteria Load)
Capital Cost
Construction
$16M
Planning &
Design $1.7M
Annual Costs
O&M
$155k
Monitoring
$50k
Multiple Benefits
Dry Well Typical Details
Site Configuration
Model Design & Performance
Community Investment Benefits
•Improved flood management and
water quality
•Enhanced beach conditions
•Reduced potential for beach
closures
•Create opportunities for education
and outreach in local communities
Nature-Based Solutions
•Provide an enhanced
environment for marine life
•Improve 26th Street Parking with
native landscaping and
permeable pavement
•Reduce impermeable area
flowing to existing drainage
system
28th Street Storm Drain Infiltration Project
1Estimates based on drywells.
2Monitoring is only required for 3 years.
Phase 2 BMP Treatment Process
Infiltration
Bypass Santa
Monica
BayRouted Flow
Impervious
Area 27th &
28th Street
Storm
Drain
Infiltration System
28th Street Storm Drain Infiltration Project
June 2021
2
1 Phase 1 only
621
This project will improve the three flood control basins to reduce
bacteria levels in receiving waters during the dry season and to
capture the 85th percentile storm event.The project deepens
the Henreitta and Entradero Basins to provide additional
detention capacity,adds passive wetland treatment and drywells
at all basins to increase the runoff management capacity.The
project also includes a variety of efforts to improve the
recreational opportunities and aesthetics of the parks.
Herondo Drain collects stormwater from portions of the cities of
Torrance,Redondo Beach,Hermosa Beach,and Manhattan Beach.Three
basins within Torrance that are connected to the Herondo Drain
including Amie,Henrietta,and Entradero Basins.
Existing Site Conditions
Infiltration
Bypass Herondo
Storm
DrainRouted Flow
Impervious
Surface
Runoff to
Storm
Drain Basin
*Products shown above were used as examples for sizing and cost analyses; other equivalent treatment systems or products may be used.
Proposed BMP Project
City: Torrance Latitude: 33.853378 Longitude: -118.371828
BMP Treatment Process
Planning-Level Cost Estimate1
Total Tributary Area
(ac)1,407 24-Hour Capture
Volume (ac-ft)46.5*
Basin Footprint (ac)
4.3 (Amie)
6.9 (Henrietta)
24 (Entradero)
Effective Drawdown
Rate (in/hr)0.8
Capital Cost
Construction
$4.5M
Planning &
Design $735k
Annual Costs
O&M
$30k
Monitoring
$80k
Multiple Benefits
Typical Details
Site Configuration
Model Design & Performance
Community Investment
Benefits
•Improved flood management and
water quality
•Enhanced park space via multi-
purpose recreational area.
•Create new recreational
opportunities via walking trail
Nature-Based Solutions
•Implements natural processes to
slow, detain, capture, and
infiltrate water
•Utilize natural vegetation
•Reduce directly connected
impermeable area flowing to
existing drainage system
Torrance Basins Enhancement & Expansion Project
1Costs from SCW application
2Monitoring is only required for 3 years.
*Equivalent to the 85th percentile, 24-hour design storm runoff from the
entire drainage area.
Torrance Basins Enhancement & Expansion
Project
June 2021
2
622
The Fulton Playfield Infiltration Project proposes to add
infiltration elements to the existing flood control basin to
transform it into a multi-benefit regional project.This will
enhance the flood control capacity of the existing basin while
adding significant water quality benefits through volume loss via
infiltration.Infiltration will be accomplished using drywells.The
project will provide full capture of dry weather volume and
controlled wet weather releases with improved inlet-outlet
control structures to manage and optimize the storage and
infiltration capacity of the project.Park enhancements including
outdoor exercise and playground equipment are also planned.
Adding features that can better capture runoff from the adjacent
school along with green water quality features such as
bioretention and ocean friendly gardens in the park and along
Rindge Lane will provide additional benefits to the community.
The site is an open green
space in the City of
Redondo Beach. The park
includes a 1.25-acre
recreational field with an
existing underground
storage basin that has
280,000 gallons of passive
storage beneath the
western half of the park.
Existing Site Conditions
Infiltration
Bypass Existing
Storm
DrainRouted Flow
Impervious
Area Draining
to the
Existing
Underground
Storage Basin
Infiltration:
13 Drywells
*Drywells were used for sizing and cost analyses; other equivalent products or treatment systems may be used but have not been included in costs.
Proposed BMP Project
City: Redondo Beach Latitude: 33.861774 Longitude: -118.372308
BMP Treatment Process
Planning-Level Cost Estimate1
Tributary Area (ac)457 24-Hour Treatment
Volume (ac-ft)26
No. of Proposed
Equivalent Drywells 13 Treatment Rate (cfs)13
Bacteria Load
Reduction During
Critical Condition
28 x 1012 MPN/year
(25% of Baseline Bacteria Load)
Capital Cost
Construction
$2.0M
Planning &
Design $395kAnnual Costs
O&M
$30k
Monitoring
$14k
Multiple Benefits
Typical Details
Site Configuration
Model Design & Performance
Community Investment Benefits
•Improved flood management
•Enhanced park via playground
•Cooperation with greening of Valor
Christian Academy
•Potential for recreational workout
stations per community
preferences
Nature-Based Solutions
•Utilize natural vegetation and
other nature-based processes
such as ocean friendly gardens to
capture, slow, and filter runoff
•Reduce directly connected
impermeable area flowing to
existing drainage system
Fulton Playfield Infiltration Project
1Estimates based on representative drywells and
previous project estimates for piping.
2Monitoring is only required for 3 years.*Nature-based BMPs may include bioretention,pervious pavement,and biofilters.
Fulton Playfield Infiltration Project
June 2021
2
623
Existing Site Conditions
*Products shown above were used as examples for sizing and cost analyses; other equivalent infiltration systems may be used.
Redondo Beach HerondoDistributed Infiltration Project
Infiltration
Bypass
Existing
Storm
DrainRouted
Flow
Impervious
Surface
Runoff
Infiltration:
Targeted
Infiltration
Systems
Overflow
Proposed BMP Project
City: Redondo Beach Latitude: Various Longitude: Various
BMP Treatment Process
Planning-Level Cost Estimate1
Typical Detail
Site Configuration
Model Design & Performance
Surface runoff enters the storm drain network through various
catch basins, as seen below on Armour Lane. The drainage area
is mostly residential, with limited commercial development.
The City of Redondo Beach is planning to implement a series of
targeted infiltration BMPs to collect surface runoff from a 342-
acre area of Redondo Beach within the Herondo Storm Drain
watershed (SMB-6-1).The infiltration BMPs will be placed
strategically upstream of existing catch basins to maximize
infiltration;see site configuration map for potential infiltration
areas.Drywells are one example of a potential infiltration BMP.
Capital Cost
Construction
$2.8M
Planning &
Design $460k
Annual Costs
O&M
$70k
Monitoring
$55k
1Estimates based on drywells.
2Monitoring only required for 3 years.
2
Tributary Area (ac)342 24-Hour Treatment
Volume (ac-ft)17.6
No. of Proposed
Infiltration BMPs 22 Treatment Rate (cfs)22
Pollutant Load
Reduction Bacteria 19 x 1012 MPN/year
(17% of Baseline Bacteria Load)
Multiple Benefits
Community Investment Benefits
•Improved flood management
Nature-Based Solutions
•Utilize natural vegetation and other nature-based processes to slow,
detain, capture, and filter water
•Reduce directly connected impermeable area flowing to existing drainage
system Redondo Beach Herondo Distributed
Infiltration Project
June 2021 624
Existing Site Conditions
*Products shown above were used as examples for sizing and cost analyses; other equivalent products or treatment systems may be used.
Hermosa Beach Distributed Drywells
Infiltration
Bypass
Existing
Storm
DrainRouted
Flow
Impervious
Surface
Runoff Infiltration:
Drywells
Overflow
Proposed BMP Project
City: Hermosa Beach Latitude: 33.857054 Longitude: -118.390251
BMP Treatment Process
Planning-Level Cost Estimate1
Multiple Benefits
Typical Detail
Site Configuration
Model Design & Performance
Untreated surface runoff enters the storm drain network through surface
catch basins in this area as the neighborhood transitions from residential
in the higher areas to commercial areas near the Pacific Coast Highway
(PCH). A typical example is shown on 3rd Street, east of PCH.
The City of Hermosa Beach is planning to implement a series of
drywells east of PCH between 1st Street and 10th Street to
capture stormwater and dry weather flows within 118 acres of
the Herondo Drain (SMB-6-1)watershed.The drywells will be
placed strategically upstream of existing catch basins to
maximize infiltration.
Capital Cost Construction of
Drywells
$1.4M
Planning &
Design $250k
Annual Costs
O&M
$35k
Monitoring
$25k
1Estimates based on drywells.
2Monitoring only required for 3 years.
2
Tributary Area (ac)118 24-Hour Treatment
Volume (ac-ft)7.7
No. of Proposed
Drywells 11 Treatment Rate (cfs)11
Pollutant Load
Reduction Bacteria 8.2 x 1012 MPN/year
(7% of Baseline Bacteria Load)
Community Investment Benefits
•Improved flood management
Nature-Based Solutions
•Utilize natural vegetation and other nature-based processes to slow,
detain, capture, and filter water
•Reduce directly connected impermeable area flowing to existing
drainage system
Source: Google Maps
Hermosa Beach Distributed Drywells
June 2021 625
Existing Site Conditions
*Products shown above are referenced as examples for sizing and cost analyses; other equivalent products or treatment systems may be used.
Manhattan Beach Dominguez Channel Distributed Infiltration Project
Infiltration
Bypass
Existing
Storm
Drain
Routed
Flow
Surface
Runoff from
Impervious
Surfaces Infiltration Overflow
Proposed BMP Project
City: Manhattan Beach Latitude: 33.898811 Longitude: -118.381272
BMP Treatment Process
Manhattan Beach Dominguez Channel
Distributed Infiltration Project
June 2021
Planning-Level Cost Estimate1
Tributary Area (ac)225 24-Hour Treatment
Volume (ac-ft)*5.2
Pollutant Load
Reduction Range
(% of Baseline Load)
Copper 83%
Zinc 77%
Bacteria 43%
Benzo [a] pyrene 71%
Typical Detail
Site Configuration
Model Design & Performance
The majority of Manhattan Beach’s tributary area within the Dominguez
Channel Watershed flows through a 27-inch storm drain under 33rd St
before turning south down Aviation Blvd. The storm drain is downstream
of a detention pond at a nearby golf course.
The City of Manhattan Beach is planning to implement
infiltration practices along 33rd Street and/or Aviation Blvd to
capture and infiltrate stormwater flows from a 255-acre mixed-
use area of Manhattan Beach and within the Dominguez
Channel watershed.Multiple types of BMPs are under
consideration to provide required treatment.
Source: Google Maps
Capital Cost
Construction
$1.4M
Planning &
Design $250k
Annual Costs
O&M
$35k
Monitoring
$25k
1Estimates based on representative drywells.
2Monitoring only required for 3 years.
2
Multiple Benefits
Community Investment Benefits
•Improved flood management
Nature-Based Solutions
•Utilize natural vegetation and other nature-based processes to slow,
detain, capture, and filter water
•Reduce directly connected impermeable areas flowing to existing
drainage system
*Includes static storage capacity and 24-hour infiltration capacity
626
The Glen Anderson Park Regional Infiltration Project will provide
infiltration via a single underground infiltration basin,a series of
drywells,or a combination of both.Wet and dry weather runoff
from City of Redondo Beach travels north in the 78-inch
reinforced concrete pipe storm drain (LACFCD BI 0729)that runs
under Vail Ave.The Project will divert runoff from this storm
drain into a pretreatment system,before flows continue into the
infiltration-based BMP.
Glen Anderson Park is a 12.4-acre multi-use park in the City of Redondo
Beach,located adjacent to Lincoln Elementary School between Rindge
Lane,Farrell Avenue,and Vail Avenue.The park has significant green
space in addition to baseball fields,tennis courts,basketball courts,and a
playground.
Existing Site Conditions
Infiltration
Bypass
Existing
Storm
DrainFlow Routed
Impervious
Area Draining
to Vail
Avenue
Infiltration
*Products shown above were used as examples for sizing and cost analyses; other equivalent products or treatment systems may be used.
Glen Anderson Park Regional Infiltration Project
Overflow
Proposed BMP Project
City: Redondo Beach Latitude: 33.882775 Longitude: -118.370948
BMP Treatment Process
June 2021
Planning-Level Cost Estimate1
Multiple Benefits
Typical Details
Site Configuration
Model Design & Performance
Capital Cost
Construction
$2.8M
Planning & Design
$460k
Annual Costs
O&M
$65k
Monitoring
$50k
Tributary Area (ac)483 24-Hour Treatment
Volume (ac-ft)9.4
Potential Footprint for
Infiltration (ac)0.45 Design Treatment
Rate (cfs)20
Pollutant Load
Reduction Range
(% of Baseline Load)
Copper 81%
Zinc 74%
Bacteria 44%
Benzo [a] pyrene 67%
Community Investment
Benefits
•Improved flood management
•Enhanced park
Nature-Based Solutions
•Utilize natural vegetation and
other nature-based processes to
slow, detain, capture, and filter
water
•Reduce directly connected
impermeable area flowing to
existing drainage system
1Estimates based on representative drywells and previous
project estimates for piping.
2Monitoring only required for 3 years.
Glen Anderson Park Regional Infiltration Project
2
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Existing Site Conditions
*Products shown above were used as examples for sizing and cost analyses; other equivalent products may be used.
Redondo Beach Dominguez Channel Distributed Infiltration Project
Infiltration
Bypass
Existing
Storm
DrainRouted
Flow
Impervious
Surface
Runoff Infiltration
BMPs
Overflow
Proposed BMP Project
City: Redondo Beach Latitude: 33.882775 Longitude: -118.370948
BMP Treatment Process
Planning-Level Cost Estimate1
Typical Detail
Site Configuration
Model Design & Performance
Surface runoff enters the storm drain network through a variety of surface
catch basins, as seen below on Redondo Beach Blvd within the drainage area.
The City of Redondo Beach is planning to implement a series of
targeted and distributed infiltration BMPs to collect surface
runoff from a portion of a 292-acre industrial area within the
Dominguez Channel watershed.Implementation of targeted
infiltration BMPs will fully capture dry weather flows in addition
to treating stormwater flows from the tributary areas.The
infiltration BMPs will be placed strategically upstream of existing
catch basins;see site configuration map for potential infiltration
areas.Drywells are one example of a potential infiltration BMP.
Capital Cost
Construction
$1.8M
Planning &
Design $320k
Annual Costs
O&M
$40k
Monitoring
$30k
1Estimates based on drywells.
2Monitoring only required for 3 years.
2
Tributary Area (ac)292 24-Hour Treatment
Volume (ac-ft)8.3
No. of Proposed
Infiltration BMPs*14 Treatment Rate (cfs)14
Pollutant Load
Reduction Range
(% of Baseline Load)
Copper 81%
Zinc 74%
Bacteria 44%
Benzo [a] pyrene 67%
Multiple Benefits
Community Investment Benefits
•Improved flood management
Nature-Based Solutions
•Utilize natural vegetation and other nature-based processes to slow,
detain, capture, and filter water
•Reduce directly connected impermeable area flowing to existing drainage
system Redondo Beach Dominguez Channel
Distributed Infiltration Project
June 2021 628
The City of Torrance is committed to implementing distributed
parkway BMPs within the Dominguez Channel watershed
management area (analysis regions Dominguez Chanel –South [DC-
S]and the Torrance Lateral draining to the Dominguez Chanel [DC-
TL])to meet the RAA requirements.Specific BMP technologies are
currently being evaluated to best address pollutants of concern,but
may include catch basin inlet filters,bioretention units,or drywells,
where deemed feasible.The City of Torrance has applied for Safe
Clean Water funding under the Technical Resources Program to
prioritize catch basins for implementation.Collectively,the Torrance
Parkway BMPs will be implemented by the City of Torrance at a level
that meets the EWMP compliance requirements.
Infiltration
Bypass
Existing
Storm
Drain
Routed
Flow
Stormwater
and Dry
Weather
Runoff
Distributed BMPs
(inlet filters,
bioretention
units, or drywells)
*Products shown above were used as examples for sizing and cost analyses; other equivalent treatment systems may be used.
Proposed BMP Project
City: Torrance Latitude: Various Longitude: Various
BMP Treatment Process Multiple Benefits
Typical Details
BMP Coverage Overview
Design Criteria for EWMP Compliance
Community Investment Benefits
•Improved flood management and
water quality
•Reducing local heat island effect
and increasing shade
•Increasing vegetation at site
locations to increase carbon
reduction and improve air quality
Nature-Based Solutions
•Implement natural processes to
slow detain, capture, and infiltrate
runoff
•Utilize natural vegetation
•Reduce impermeable area flowing
to existing drainage system
Torrance Parkway BMPs
AnalysisRegion24-Hour
Management
Volume
(ac-ft)
Pollutant Load Reduction
(% of Baseline Load)
Copper Zinc E.coli Benzo
[a]pyrene
DC-S 21.9 36%64%45%54%
DC-TL 35.4 51%87%48%66%
Bioretention
Drywell
Catch Basin Inlet Filter
DC-S
DC-TL
Treated
Flow
Torrance Parkway BMPs
June 2021 629
Beach Cities Watershed
Management Group
Revised EWMP
Appendix F:
Background
Information on the
LACFCD
JUNE 2021
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BACKGROUND INFORMATION ON THE LACFCD This attachment provides background information pertaining to the Los Angeles County Flood Control District (LACFCD), and their involvement in the Beach Cities Enhanced Watershed Management Program (EWMP) Plan. In 1915, the Los Angeles County Flood Control Act established the LACFCD and empowered it to manage flood risk and conserve stormwater for groundwater recharge. In coordination with the United States Army Corps of Engineers, the LACFCD developed and constructed a comprehensive system that provides the regulation and control of flood waters through the use of reservoirs and flood channels. The system also controls debris, collects surface storm water from streets, and replenishes groundwater with stormwater and imported and recycled waters. The LACFCD covers the 2,753 square-mile portion of Los Angeles County south of the east-west projection of Avenue S, excluding Catalina Island. It is a special district governed by the County of Los Angeles Board of Supervisors, and its functions are carried out by the Los Angeles County Department of Public Works. For the Beach Cities EWMP, the LACFCD service area is shown in Figure 1. Unlike cities and counties, the LACFCD does not own or operate any municipal sanitary sewer systems, public streets, roads, or highways. The LACFCD operates and maintains storm drains and other appurtenant drainage infrastructure within its service area. The LACFCD has no planning, zoning, development permitting, or other land use authority within its service area. The Permittees that have such land use authority are responsible under the MS4 Permit for inspecting and controlling pollutants from industrial and commercial facilities, development projects, and development construction sites. (MS4 Permit, Part II.E, page 14.) The MS4 Permit language clarifies the unique role of the LACFCD in storm water management programs: “[g]iven the LACFCD’s limited land use authority, it is appropriate for the LACFCD to have a separate and uniquely-tailored storm water management program. Accordingly, the storm water management program minimum control measures imposed on the LACFCD in Part VI.D of this Order differ in some ways from the minimum control measures imposed on other Permittees. Namely, aside from its own properties and facilities, the LACFCD is not subject to the Industrial/Commercial Facilities Program, the Planning and Land Development Program, and the Development Construction Program. However, as a discharger of storm and non-storm water, the LACFCD remains subject to the Public Information and Participation Program and the Illicit Connections and Illicit Discharges Elimination Program. Further, as the owner and operator of certain properties, facilities and infrastructure, the LACFCD remains subject to requirements of a Public Agency Activities Program.” (MS4 Permit, Part II.F, page 15). Consistent with the role and responsibilities of the LACFCD under the MS4 Permit, the EWMPs and Coordinated Integrated Monitoring Programs (CIMPs) reflect the opportunities that are available for the LACFCD to collaborate with Permittees having land use authority over the subject watershed area. In some instances, the opportunities are minimal; however, the LACFCD remains responsible for compliance with certain aspects of the MS4 Permit as discussed above.
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In some instances, in recognition of the increased efficiency of implementing certain programs regionally, the LACFCD has committed to responsibilities above and beyond its obligations under the 2012 MS4 Permit. For example, although under the 2012 MS4 Permit the Public Information and Participation Program (PIPP) is a responsibility of each Permittee, the LACFCD is committed to implementing certain regional elements of the PIPP on behalf of all Permittees at no cost to the Permittees. These regional elements include:
• Maintaining a countywide hotline (888-CLEAN-LA) and website (www.888cleanla.com) for public reporting and general stormwater management information. Each Permittee can utilize this hotline and website for public reporting within its jurisdiction.
• Broadcasting public service announcements and conducting regional advertising campaigns.
• Facilitating the dissemination of public education and activity specific stormwater pollution prevention materials.
• Maintaining a stormwater website. The LACFCD will continue to implement these elements on behalf of all Permittees during the current MS4 Permit term. With the LACFCD handling these elements regionally, Permittees can better focus on implementing local or watershed-specific programs, including student education and community events, to fully satisfy the PIPP requirements of the 2012 MS4 Permit. Similarly, although water quality monitoring is a responsibility of each Permittee under the 2012 MS4 Permit, the LACFCD is committed to implementing certain regional elements of the monitoring program to help increase the efficiency and effectiveness of this program. These efforts include:
• Conducting monitoring at the seven existing mass emissions stations required under the previous Permit. This is in addition to the LACFCD’s contribution to individual CIMP groups.
• Participating in the Southern California Stormwater Monitoring Coalition’s Regional Bioassessment Program on behalf of all Permittees. In addition, the LACFCD is committed to developing tools and programs that benefit all Permittees in Los Angeles County. Some of these efforts include the following:
• The development and maintenance of Watershed Reporting Adaptive Management & Planning System (WRAMPS), which assists permittees in preparing their MS4 annual report.
• The development and maintenance of Watershed Management Modeling System (WMMS), which is the primary model being used by watershed groups to meet reasonable assurance analysis (RAA) requirements or watershed modeling requirements in the development of their Watershed Management Program (WMP) or Enhanced Watershed Management Program (EWMP).
• The management/administration of Safe, Clean Water (SCW) Program, which provides a dedicated revenue source for all municipalities, including MS4 permittees, to implement multi-benefit stormwater projects and programs that improve water quality and either increase water supply through augmenting local groundwater and recycled water use or enhance communities.
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LACFCD Territory
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Management Group
Revised EWMP
Appendix G:
Potential Funding
Sources and
Financial Strategy
JUNE 2021
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POTENTIAL FUNDING SOURCES AND FINANCIAL STRATEGY The availability of funds is critical for the successful implementation of the Enhanced Watershed Management Plan (EWMP). This appendix provides an overview of potentially available funding sources for programs and projects proposed in the EWMP. The funding sources included in this section for consideration are Measure W (Safe, Clean Water Program), grants, interagency partnerships, bonds, State Revolving Funds, local funding opportunities, and public private partnerships. A summary of potential financial approaches for the Beach Cities Watershed Management Group (WMG) is provided in Table G-1, with additional details and discussion provided in the sections following.
Table G-1. Funding Approach Summary
Approach
Funding
Type Limitations
Potential Significance
(with Respect to
Overall Funding) Safe, Clean Water Regional Program New Revenue • Highly Competitive
• Application preparation requires significant effort/cost High
Grants New Revenue
• Highly Competitive
• No guarantee of funding accessibility
• Infrastructure projects only
• Application preparation/submission requires significant effort/cost
• Can only be used to pay for infrastructure-related projects
• O&M costs are typically excluded
Medium
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 Low
State Revolving Funds Financing • Revenue stream is needed to obtain loans
• There is a financing cost
• Infrastructure projects only
• O&M costs are typically excluded High
Local Public Funding Opportunities New Revenue • Requires voter approval
• Infrastructure projects only (except for stormwater fee) High
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Approach
Funding
Type Limitations
Potential Significance
(with Respect to
Overall Funding)
• O&M costs are typically excluded (except for stormwater fee)
Public Private Partnership
Financing • Revenue stream is needed to allow the private partner to recover their cost as well as provide return on investment High
Direct Subsidies / Cost-Sharing
• Funding source is needed to fund a subsidy program
• Some projects may underperform due to poor project implementation, O&M, and monitoring Low
RECENT FUNDING EXAMPLES WITHIN THE BEACH CITIES The Beach Cities WMG has been working cooperatively to pursue funding for projects identified in the EWMP by leveraging multiple sources of funding. In 2018, the Beach Cities WMG secured $2M in Prop 12 Santa Monica Bay Restoration Grant funding by the California Coastal Conservancy and the Santa Monica Bay Restoration Commission to fund the design and construction of the joint Beach Cities Green Street Project. The Prop 12 grant funding provides approximately 39% of the total estimated Beach Cities Green Street Project cost of $5.1M with the balance to be matched by the Beach Cities WMG agencies through other sources. With the City of Torrance serving as lead agency for this project, Beach Cities WMG has executed a cost sharing MOU to jointly fund the matching design and construction costs not covered by the grant funding. The MOU details each city’s share of the project’s preliminary engineering and final design cost and will be amended following final design to apportion construction costs. This joint project has also been submitted for FY2122 Safe Clean Water Regional Program Infrastructure funding for construction. The Beach Cities WMG members are committed to developing feasibility studies and project concepts for regional projects to be eligible for SCW infrastructure funding and to be competitive for grant funding. The City of Torrance has funded the design of the Torrance Basins Expansion Regional Project with a completed preliminary engineering and feasibility study and final design now underway. The City of Manhattan Beach has funded the preliminary engineering and feasibility study of the Manhattan Beach 28th Street Storm Drain Infiltration Project. The Beach Cities WMG members also plan to leverage the SCW Regional funding with the Municipal Returns to construct and maintain capital projects. The County of Los Angeles is leading the Alondra Park Multi-Benefit Stormwater Capture Project and has completed a preliminary design report and feasibility study for the project and was awarded $30 million in SCW Infrastructure funding and $2.1 million in Prop 1 Stormwater Grant funding for design and construction, while Caltrans is proposing to contribute $15 million. The remaining $13 million in capital costs needed for the project is being provided by the County of Los Angeles. However, financial contributions and partnerships are being solicited from the tributary agencies including the Cities of Manhattan Beach and Redondo Beach, if they should desire to obtain additional capture volume credits above their baseline allocation. In addition, each City in the Beach Cities WMG is committed to the pursuit of funding for individual
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distributed EWMP implementation projects and programs related to water quality improvement within their respective cities, as demonstrated by the following examples:
• The City of Hermosa Beach has committed financial support for identifying and implementing strategies for the establishment of sustainable revenue sources to manage stormwater programs and implement water quality improvement projects. In June 2015, the City of Hermosa Beach passed a sanitary sewer fee for residents and commercial property owners to fund maintenance and rehabilitation of its aging sewer infrastructure that had previously been funded from the City’s general fund. This dedicated fee for sanitary sewers will allow the City to redirect part of those general fund dollars for capital improvements and maintenance of the City’s storm drain system, including green street projects. The City won multiple awards for its Pier Avenue green street project and the City recently was awarded funding by the Coastal Conservancy to reconstruct a municipal parking lot to include a suite of storm water BMPs. Additionally, the City recently completed the Hermosa Beach 8th Street Improvement Project, which includes multi-benefit improvements along 8th Street between Valley Drive and Hermosa Avenue.
• The City of Manhattan Beach is committed to implementing its Green Street Policy for capital improvement projects in the public right-of-way, has established a minimum runoff capture design goal for such projects, and will also use the EWMP to identify opportunities for green street BMP retrofits in high priority areas. The City is also currently in the process of updating its Storm Drain Master Plan, which will identify locations for multi-benefit projects to facilitate compliance with the MS4 Permit. City staff has an excellent track record and appreciates the support of its Council in the pursuit of funding for and implementation of green infrastructure as evidenced by two previous example projects: a 130,000 square feet porous concrete paving project on seven municipal parking lots, and the Greenbelt Infiltration Project installed within the linear greenbelt parkland. The City is currently pursuing regional project funding for the Manhattan Beach Infiltration Project at 28th Street via the Safe, Clean Water Regional Program.
• The City of Redondo Beach’s green streets policy requires green street BMPs to be integrated with capital improvement projects (CIPs), thereby ensuring that BMPs be funded as part of ongoing and future CIPs. An example of this policy is the Redondo Beach Street Rehabilitation Project, which includes several street rehabilitation projects that include green street features such as porous gutters and crosswalks and drywells. Four of these street rehabilitation projects were completed during the 2019-2020 reporting year, addressing a combined 22 acres of green street target land use area within the Beach Cities WMG’s high priority Herondo watershed (SMB 6-1 analysis region). The City also incorporates the required addition of catch basin trash screening devices into street resurfacing projects such as the Esplanade Street Resurfacing Project. In addition, the City has a successful track record of pursuing and implementing water quality improvements grant funding such as the Alta Vista Diversion and Re-use Project and the Sapphire Storm Drain Diversion and Infiltration Project.
• The City of Torrance has appropriated funding for retrofit of 3% of catch basin BMPs in the Dominguez Channel Watershed and appropriated annual funding to complete their trash
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management and reporting plan (TMRP) implementation by the end of 2016 (four years ahead of the total maximum daily load [TMDL] compliance deadline). In addition, the City’s green streets policy requires green street BMPs to be integrated with street improvement CIPs. The City of Torrance has an established record for pursuing grant funds for Storm Water Quality Projects. Completed projects include Bioswales for City Yard ($150,000 State grant funds), Machado Lake Trash TMDL Project ($1,000,000 State grant funds), and the Stormwater Basin Enhancement Project ($3,300,000 State grant funds and $300,000 Federal grant funds). The City is currently pursuing multiple project funding awards via the Safe, Clean Water Regional Program. The foregoing examples illustrate the willingness of Beach Cities’ staff and elected officials to pursue funding for EWMP implementation projects. Additional sources of funding will also continue to be investigated, as described below. MEASURE W (SAFE, CLEAN WATER PROGRAM) Measure W was successfully passed by Los Angeles County voters in November 2018, creating the Safe, Clean Water Program to provide local, dedicated funding for stormwater and urban runoff to increase local water supply, improve water quality, and protect public health within the Los Angeles Basin. The program currently generates approximately $285 million per year. The majority of this funding goes directly back to the cities via two programs:
• The Municipal Program - 40% of the annual revenue goes directly to cities via the Municipal Program, with city-specific revenue proportional to the revenues generated within its boundaries. The Municipal Program funding can be used for eligible activities such as project development, design, construction, effectiveness monitoring, operations and maintenance (including operation and maintenance of projects built to comply with the MS4 Permit), as well as for other programs and studies related to protecting and improving water quality in lakes, rivers, and the ocean. The total annual municipal revenue projected for the Beach Cities WMG is approximately $3.4M.
• The Regional Program – 50% of the annual revenue is divided across nine watershed areas (including the South Santa Monica Bay Watershed Area, which includes the Beach Cities Area), and is devoted to funding regional watershed-based projects, project concepts, and scientific studies. The South Santa Monica Bay Watershed Area is estimated to receive up to $18.4 million annually to fund regional projects and programs. Funding for multi-benefit regional projects includes design, permits, CEQA compliance, grant-writing, right-of-way and land acquisition, construction, and long-term operations and maintenance of the facilities. To apply for regional infrastructure funds, a Safe, Clean Water Feasibility Study is required to be submitted to the local Watershed Area Steering Committee (WASC) for evaluation. The WASC, comprised of representatives from cities, agencies, and community stakeholders, reviews proposed projects and develops an annual Stormwater Investment Plan (SIP) for their Watershed Area that identifies recommendations for funding. Recommended projects included in SIPs will also be reviewed by a Scoring Committee and ultimately a Regional Oversight Committee for recommendation to the Board of Supervisors.
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The process to receive regional funding is competitive, as numerous projects across entire watershed areas are considered. However, funding is significant, consistent, and flexible to be spent on all phases of qualifying stormwater infrastructure projects. The Safe, Clean Water Program is therefore the primary funding mechanism the Beach Cities WMG will pursue to fund their various projects. GRANT OPPORTUNITIES Grants have historically been a backbone for financing stormwater projects. The majority of water-related grants are designated for flood control, drinking water, and watershed protection and most recent grants have preferences for projects that benefit underserved communities; very few grants are made available for the sole purpose of stormwater permit compliance. In order to increase the likelihood of successful grant funding, a stormwater project might need to be added to a larger project or program that serves different purposes and has different objectives rather than just for stormwater management. Thus, collaboration and coordination between stormwater agencies and other public agencies is important to increase accessible grant funding opportunities for stormwater projects. Recent Federal infrastructure funding may expand the opportunities for grants and debt forgiveness loans. H.R. 1319 entitled “The American Rescue Plan Act of 2021” is primarily a COVID relief bill, but includes funding for water, sewer, and broadband infrastructure. This legislation does not distinguish stormwater as separate from water. This bill has been passed by both houses and signed into law by the President. The funds have been both authorized and appropriated and are currently being transferred to municipal governments. The funds can also be used by special districts, such as water and sewer districts. S. 914 entitled “Drinking Water and Wastewater Infrastructure Act of 2021” reauthorizes both the Drinking Water SRF and Clean Water SRF programs at current levels with annual increases through 2026. It also reauthorizes the WIFIA funding at current levels through 2026. This bill has passed the Senate and appears to have sufficient support to pass the House and be signed into law by the President. While this bill authorizes the funding through 2026, it does not appropriate the funds. The funds will be appropriated on an annual basis through the regular annual federal budget appropriations. Many grant funds do not cover 100% of the project costs, but instead, cost sharing from local governments (as much as 50%) is required under grant provisions. Furthermore, grants typically cover only project capital costs, but do not provide funding to cover ongoing operations and maintenance, and replacement costs of the infrastructure. Thus, alternative funding sources would be needed to provide stable O&M revenues as well as costs for replacement for implemented projects. Table G-2 presents some potential grant opportunities available that the Beach Cities can apply to fund the EWMP projects.1
1 Some information in Table G-2 has not been updated due to a lack of update to relevant websites. This is not surprising in light of the global COVID-19 pandemic that is still ongoing. All the information presented in Table G-2 is subject to change.
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The Beach Cities WMG has expressed commitment to pursue grant opportunities. Numerous grants have been sought in the past by the Group, including multiple Prop 1 Coastal Conservancy grants, a Prop 68 Urban Flood Protection grant, Prop 12 Coastal Santa Monica Bay Restoration Grant funding by the California Coastal Conservancy, and multiple rounds of Prop 1 Stormwater Grant funding. Since SB-985-Stormwater Resource Planning became effective in 2014, local governments have been required to develop a stormwater resource plan and be in compliance with provisions of 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. In 2017, the Group received approval that the Beach Cities EWMP serves as a functionally equivalent stormwater resources plan. See Appendix H for related details.
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Table G-2. Relevant Grant Opportunities
Program Department Purpose Ineligible Uses Funding Limits WaterSMART: Water and Energy Efficiency Grants
US Bureau of Reclamation Projects should seek to conserve and use water more efficiently, increase the use of renewable energy, mitigate conflict risk in areas at a high risk of future water conflict, facilitate water markets, or carry out other activities to address climate related impacts on water or prevent any water-related crisis or conflict.
Normal operations, maintenance, and replacement (OM&R). OM&R is described as system improvements that replace or repair existing infrastructure or function without providing increased efficiency or effectiveness of water distribution over the expected life of the improvement. Construction of a building.
FY 2021 Funding is awarded at one of two levels: Funding Group I: Up to $500,000 per agreement for a project up to 2 years. Funding Group II: Up to $2,000,000 for an agreement for up to 3 years for a small number of projects.
WaterSMART: Cooperative Water Management Program (CWMP) Grants
US Bureau of Reclamation The purpose is to improve water quality and ecological resilience and to reduce conflicts over water through collaborative conservation efforts in the management of local watersheds. CWMP provides funding to watershed groups to encourage diverse stakeholders to form local solutions to address their water management needs. Funding is provided on a competitive basis for: 1) watershed group development and watershed restoration planning, and 2) implementation of watershed management projects.
Please visit the following website for evaluation criteria: http://www.usbr.gov/WaterSMART/cwmp/docs/ CWMPEvaluationCriteria.pdf
Phase I funds shall be used to establish or enlarge a watershed group, to develop a mission statement for the watershed group, to develop project concepts, and to develop a restoration plan. Phase II funds shall be used to plan and carry out watershed management projects. Phase III funds shall be used to plan and carry out at least one watershed management project.
IRWM Implementation Program Proposition 84 (Chapter 2, §75026)
Department of Water Resources
Award funds for implementation of projects consistent with IRWM Plans to assist local public agencies in meeting long-term water management and resilience needs of the state, including the delivery of safe drinking water, and protection of water quality and the environment.
Operation and maintenance activities Bond funding allocation for entire program is $1 billion. Prop 84 allots grant funding to 11 funding areas defined by the hydrologic regions of the state.
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Program Department Purpose Ineligible Uses Funding Limits Flood Corridor Program Propositions 1E, 84 and 13
Department of Water Resources
Flood risk reduction through non-structural projects that include wildlife habitat enhancement and/or agricultural land preservation components
Flood protection projects that do not include wildlife habitat enhancement or agricultural land preservation benefits
$5 million per eligible project. 10% non-state, non-federal cost share required; may be reduced to 5% or no-cost share if serving disadvantaged or severely disadvantaged community Flood Control Subventions Program Propositions 1E and 84
Department of Water Resources
Implementation of federally authorized flood control projects (minor or major) and Watershed Protection Flood Prevention Projects
Flood control projects without federal authorization Variable state cost-share percentage based on multipurpose objectives for projects, ranging from a minimum of 50% to a maximum of 70% Statewide Flood Emergency Response Program Proposition 84
Department of Water Resources
Preparing or updating local emergency plan; Coordinating flood emergency planning and preparedness (including training & exercise); Developing communication & coordination response process; Collecting & exchange of flood information; Purchase & installing equipment for interoperable emergency communication.
Projects not included in guidelines. Projects in the Legal Delta. $10 million for Statewide (outside the legal Delta) for Prop 84.
California Coastal Conservancy, Prop 1 ($100.5 million allocated)
California Coastal Conservancy Funding for multi-benefit water quality, water supply, and watershed protection and restoration projects. Projects that do not comply with the Proposition 1 Grant Program Guidelines. Projects that use potable water for irrigation. O&M projects are not eligible.
$10 million per year grants will be made available over the next 10 years.
Storm Water Grant Program, Prop 1 ($200 million), approved as part of the Water Quality, Supply and Infrastructure Improvement Act (2014).
State Water Resources Control Board and Regional Water Quality Control Boards
Funding for multi-benefit storm water management projects which will improve regional water self-reliance, security, and adapt to the effects on water supply arising from climate change.
Projects that 1) must seek eminent domain as part of their project implementation timeline; 2) do not meet the requirements of the Prop 1 Storm Water Grant Program Guidelines, the Storm Water Resources Plan Guidelines, Water Code, and Prop 1; 3) consist of only education and outreach activities.
Planning projects: min. $50K and max. $500K; Implementation projections: min. $250K and max. $10M.
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PROJECT-SPECIFIC INTERAGENCY PARTNERSHIPS Stormwater management projects often overlap with the jurisdiction of other public agencies, including water and transportation agencies, as well as parks and schools. Interagency partnerships would not only allow agencies involved to leverage one another’s available funding resources to make cost intensive projects possible but would also improve local government funding efficiency. These types of interagency partnership projects could also optimize the potential social, environmental, and economic benefits provided to the community. An interagency partnership also provides an alternative avenue for stormwater agencies to access to grant funding that would otherwise not be available to them. In addition to the above benefits, a partnership with public utility agencies, such as water and refuse collection services, might also provide a mechanism for cost transfer from stormwater agencies to these agencies. For example, the use of stormwater for 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 G-3 provides a list of potentially viable partnerships and the benefits derived from management of stormwater runoff.
Table G-3. Added Benefits of Interagency Partnership for Stormwater Management
Potential Partners Benefits Derived from Stormwater Management Flood control district • Flood protection
• Climate change mitigation Caltrans • Surface water pollution prevention
• Increased project siting opportunities in transportation corridors Water agencies • Potable water conservation through stormwater use for non-potable water purposes
• Surface water pollution prevention
• Increase non-potable water storage through installation of underground cisterns Parks, Coastal Commission • Terrestrial and marine habitat protection by reducing trash from entering the ocean and other terrestrial habitats
• Water pollution prevention
• Erosion reduction LOCAL BOND ISSUANCE Bonds have been utilized by local governments to provide funding for stormwater projects. There are two types of bonds that can be utilized. One of them is GO bonds. GO bonds are issued by local governments, which are repaid through a tax surcharge (e.g., property). The City of Los Angeles, for example, has used GO bonds to fund their stormwater projects. The City sold $440 million GO bonds under Proposition O Clean Water Bonds. The bond proceeds were used for implementation of 39 projects but could not be used for ongoing maintenance, operations, and replacement of these facilities (Farfsing and Watson, 2014). The challenge of utilizing GO bonds is that GO bond issuance and the amount to be issued must be approved by two-third of the voters. The main drawback of election approval requirement is that the cost of holding an election can be high and the chance of success is often unpredictable.
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The last decade has seen the emergence of a new category of bonds generically called “green” bonds. A green bond is a type of fixed-income instrument that is specifically earmarked to raise money for climate and environmental projects. These bonds are typically asset-linked and backed by the issuing entity's balance sheet, so they usually carry the same credit rating as their issuers’ other debt obligations. Green bonds are designated bonds intended to encourage sustainability and to support climate-related or other types of special environmental projects. More specifically, green bonds finance projects aimed at energy efficiency, pollution prevention, sustainable agriculture, fishery and forestry, the protection of aquatic and terrestrial ecosystems, clean transportation, clean water, and sustainable water management. They also finance the cultivation of environmentally friendly technologies and the mitigation of climate change. Green bonds come with tax incentives such as tax exemption and tax credits, making them a more attractive investment compared to a comparable taxable bond. These tax advantages provide a monetary incentive to tackle prominent social issues such as climate change and a movement to renewable sources of energy. To qualify for green bond status, they are often verified by a third party such as the Climate Bond Standard Board, which certifies that the bond will fund projects that include benefits to the environment. Another type of bonds that can be used at the local level is revenue bonds. Revenue bonds are tax-exempt securitized bonds that are issued by utility agencies, such as water agencies. These bonds are repaid through utility rate increases charged directly to customers. Recent enactment of AB-850-Public Capital Facilities: Water Quality allows local publicly owned water agencies to finance water quality and water conservation related projects by issuance of revenue bonds through a Joint Powers Authority (JPA). Under the provisions of AB-850, water agencies are allowed to use the bond proceeds to pay for construction, repair, maintenance, and operations of eligible projects. Both stormwater capture and water quality compliance projects are considered as eligible projects that can be financed through bond issuance under the AB-850 mechanism. Additionally, AB-850 authorizes water agencies to repay these bonds through water utility rate increases – the same way as other revenue bonds not issued under the SB-850 mechanism by water agencies. Such rate increases are also subject to Proposition 218 approval under the exempt category (i.e., only a public hearing is required). SB-628–Enhanced Infrastructure Financing Districts (EIFD) will allow issuance of general obligation bonds within the EIFD inside a city or a county. The Bill authorizes a legislative body to establish an enhanced infrastructure financing district, adopt an infrastructure financing plan, and issue bonds upon approval by 55% of the voters to finance public capital facilities such as collection and treatment of water for urban uses and flood control projects. Under the provisions of SB-628, a City or a County can establish an EIFD of any size. If a defined EIFD has fewer than 12 registered voters, only a protest hearing is required to be conducted for landowners. The number of votes that each landowner gets will depend on the size of the land they own. The ballot will specify a vote per acre or a portion of an acre. The bonds issued under this bill will be repaid through property tax increase (i.e. tax increment financing). The district will cease to exist in no more than 45 years from the date on which bond issuance is approved.
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STATE REVOLVING FUNDS The Clean Water Act (CWA) provided for the creation of Clean Water State Revolving Fund (CWSRF) program capitalized by federal and state funds which in turn provides municipalities with a permanent source of low-cost financing for a range of water quality infrastructure projects. The California CWSRF program is administered by the State Water Resource Control Board, Division of Financial Assistance.2 The “Policy for Implementing the Clean Water State Revolving Fund,”3 amended in 2019, provides guidance for applying for financial assistance from the CWSRF program and each year an “Intended Use Plan”4 is drafted to provide information about the current financing terms and fund availability. The CWSRF finances water quality projects similar to those proposed in the EWMP, including nonpoint source, watershed protection or restoration, and estuary management projects (USEPA, 2014). The main advantage of CWSRF is that their interest rates are typically much lower than market rates (e.g. 3% for a 20-year loan instead of 6%). The loans are project-specific and can serve as a good financial resource for funding project design and construction. The CWSRF program loans carry an interest rate set at one-half of the most recent state GO bond rate at time of funding approval and repayment begins one year after completion of construction with a term of up to 30 years or the useful life of the project. There is no maximum funding limit, but partial funding may be applied based on funds availability and the applicant’s ability to repay. Loan forgiveness is available via subsidy of up to 50% of eligible capital costs and 75% of eligible planning costs, up to a total cap of $4 million, through the Green Project Reserve (GPR). Congress’ intent in enacting the GPR is to direct State investment practices in the water sector to guide funding toward projects that utilize green or soft-path practices to address green infrastructure, water or energy efficiency improvements, or other environmentally innovative activities.5 The GPR sets a new precedent for the SRFs by targeting funding towards green infrastructure and water quality projects that states may not have funded in prior years. Any project eligible for GPR funding must also qualify for the CWSRF program. Access to the State Revolving Funds is limited by the agencies’ ability to borrow due to repayment of other debt obligations (e.g. lease burden). It has been reported that a typical median net lease burden for a California county is 1.7% of general fund revenues while the total burden of lease and General Fund obligations is 1.9% (Moody, 2012). Loan repayment will require alternative funding sources if reliance on general fund resources is not an option. A CWSRF program loan application consists of four packages - the General Information Package, the Technical Package, the Environmental Package, and the Financial Security Package. The application packages are submitted online via the Financial Assistance Application Submittal Tool (FAAST).6 When the General Information Package is submitted, a project manager will contact and support the
2 https://www.waterboards.ca.gov/water_issues/programs/grants_loans/srf/ 3 https://www.waterboards.ca.gov/drinking_water/services/funding/documents/srf/dwsrf_policy/final_policy_1219.pdf 4 https://www.waterboards.ca.gov/water_issues/programs/grants_loans/docs/cwsrf_iup_sfy2020_21_final.pdf 5 https://www.epa.gov/sites/production/files/2015-04/documents/green_project_reserve_eligibility_guidance.pdf 6 https://faast.waterboards.ca.gov
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applicant through the remaining steps of the application process. All submitted projects are evaluated annually to identify eligibility and receive a priority score for placement on the Fundable List. LOCAL PUBLIC FUNDING OPPORTUNITIES AND APPROVAL PROCEDURES Stormwater charges are potentially the most critical local funding source to finance stormwater programs in California. These charges include stormwater fees and taxes, as well as other funds generated through general obligation and revenue bond issuance. Table G-4 provides an overview of potential local funding sources that may be utilized to provide funds to finance stormwater programs. An important factor to consider when utilizing these funding mechanisms is the respective approval mechanisms as discussed below.
Table G-4. Local Funding Opportunities
Fees Taxes Bonds
• Fixed and volumetric service fees
• Property assessments or fees
• Developer fees or connection fees (a one-time fee)
• Permitting fees
General taxes
• Property, sales, and other activities
Special taxes
• Parcel taxes to pay for flood protection, stormwater management, watershed protection
• Sales tax add-ons
• Transient Occupancy Tax to pay for creeks restoration and water quality improvement projects
General bonds
• Repaid through a property tax surcharge
Revenue bonds
• Issued by local utilities (e.g. water)
• Repaid by service fees, developer fees, plus occasional special taxes Local funding opportunities presented in Table G-4 are subject to approval mechanisms that can vary from holding a written protest hearing to an election, depending on the type of funding sought after (Table G-5). The types of charges that are deemed to be most suitable for stormwater-related services are property-related fees. For a property-based, flood control-related stormwater management fee, an election is required to be conducted under the provisions of Proposition 218. However, there are two categories under Proposition 218 that are exempt from the election approval requirements. They are water-related and refuse collection services. Although there are differing legal opinions on the matter, the approval of AB2403 has extended the definition of water in Proposition 218 to include stormwater capture projects for infiltration and direct non-potable uses, which means that these projects may be exempt from the election requirement under Proposition 218. Even with the extended definition of water in the California Constitution, the existing form of Proposition 218 still requires voter approval for stormwater fees which has limited stormwater agencies’ ability to generate sufficient revenue to support stormwater projects related to permit compliance. Given the existing unique regulatory framework and limitation of Proposition 218, some local governments have broken down the stormwater revenue requirements by functions instead of a single property-related fee. Some of them have utilized the exempt category under Proposition 218 to fund stormwater projects with success. The Cities of Signal Hill, Poway, and Solana Beach, for example, have utilized a surcharge on trash collection fees to cover the some of the cost for
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stormwater-related trash collection and management. A surcharge on water utility fees has also been used by the Cities of Del Mar, Oceanside, and Solana Beach to provide funding to fund stormwater operation as part of the drinking water pollution prevention effort (Farfsing and Watson, 2014). Pollution prevention is an important component in stormwater management. Given that majority of the pollutants in stormwater runoff originate from vehicles, some local governments have used other non-property-related surcharges to provide funding for stormwater programs. For example, the Orange County Transportation Authority has used the County’s sales tax to provide some funding for a water quality improvement and environmental cleanup program. The San Mateo County has also added a surcharge on the vehicle license fee to provide funding for their stormwater pollution management program. It is also foreseeable that pollutant specific, such as a TMDL-related fee could be established to provide funding for TMDL compliance related programs in the future. In addition to fees that provide steady revenue, another possible revenue source would be to charge fines to property owners that violate discharge limits (volumetric- or TMDL-based). Fines are not considered as a stable financial income; however, they discourage behavior or practices that will lead to non-compliance. Furthermore, fines are exempt from election requirements under Proposition 26 and have been commonly used by water agencies to discourage excessive water consumption behavior. The use of fines under Proposition 26 as a financial instrument to management stormwater discharge in urban areas is still uncommon but might worth exploring.
Table G-5. Local Funding Approval Mechanisms
Proposition 13
(1978)
Proposition 218
(1996)
Proposition 26
(2010)
General
taxes Flexible Simple majority for cities and counties, not available to special districts (rules from the earlier
proposition remain in
place)
General
Obligation
Bonds Two-thirds of local voters Two-thirds of local voters Two-thirds of local voters
Special taxes Two-thirds of local voters (rules from the earlier proposition remain in
place) (rules from the earlier
proposition remain in
place)
Property
taxes 1% of purchase price + 2% annual increases
(rules from the earlier proposition remain in
place) (rules from the earlier
proposition remain in
place)
Property-
related fees
and
assessments
Flexible 1. All water-related and refuse collection services: strict cost-of-service requirements 2. All water-related and refuse collection services: property-owner protest hearing 3. Floods and stormwater: 50% of property owners or two-third popular vote
(rules from the earlier
proposition remain in
place)
Non-
property-
related fees Flexible Flexible Stricter requirements (more likely to be a tax)
Wholesale
fees Flexible Flexible Stricter cost-of-service requirements
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PUBLIC PRIVATE PARTNERSHIPS Public private partnerships (P3) can be achieved through two approaches. The conventional approach will involve having the private partner to undertake design and construction, and sometimes even operation and maintenance of the facilities. The private partner will recover the cost plus their return-on-investment through a guaranteed revenue stream (e.g. a user fee) over a long period (e.g. 30- 40 years). The main advantage of such an approach is that the upfront financing costs are provided through the private partner while the project performance is guaranteed by the private partner. Also, P3 can be utilized when agencies have restrictions on the amount of debt that they can carry (e.g. agencies want to maintain low lease burden or have high lease burden). Potential cost saving can be achieved through higher financial efficiency during project implementation phase. P3 can also expedite project implementation by simplifying administrative procedures for financing as well as eliminating the need for tendering. The main challenge for implementation of P3 is to get voters to approve a longer revenue stream to repay the private partner. The amendment of Proposition 218 is expected to lower such hurdle for providing such a revenue stream. The second P3 approach is through direct financial subsidies to local projects that do not contribute to cash revenue generation. However, subsidies can create a financial incentive to encourage local participation without providing the full cost for project implementation. Such an approach can increase financial efficiency by leveraging financial input from communities. A list of cities that utilize financial subsidies to maximize their local stormwater capture capacity is provided in Table G-6. Based on these examples presented in Table G-6, subsidies can be given out in forms of 1) rebates per project with caps for stormwater runoff reduction projects, 2) rebate per rain barrel or cistern, 3) rebate per parcel, 4) stormwater fee reduction, and 5) cost sharing. Among all the runoff capture subsidy programs listed in Table G-6, the approach adopted by the City and County of San Francisco is considered as the most progressive. The City and County adopted the onsite Water Reuse for Commercial, Multi-family, and Mixed-Use Development Ordinance which amended the San Francisco Health Code to allow for the collection, treatment, and use of alternative water sources (including stormwater runoff) for non-potable applications. The City and County has since developed a Non-potable Water Program that allows commercial, mixed use, and multifamily residential property owners to collect, treat and reuse water from various sources onsite, including stormwater runoff. The Program also allows the property owners to act as local non-potable water suppliers to provide non-potable water to buildings in the vicinity. Property owners or developers are required to comply with stringent monitoring and reporting requirements for 10 years in order to maintain such privilege. The San Francisco Public Utilities Commission (SFPUC) has created a grant assistant program that provides up to $250,000 for single building projects and up to $500,000 for district-scale projects meeting specific eligibility criteria to encourage participation.
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Table G-6. Select Cities that Subsidize Private Stormwater Infrastructure
Reference Runoff Reduction Runoff Capture and Use San Francisco, CA (SFPUC, 2015) Grants
• Up to $30,000 with 35% match requirement
• Up to $100,000 with 25% match requirement
Grants (treatment is required)
• Up to $250,000 for single building projects
• Up to $500,000 for district-scale projects Palo Alto, CA (City of Palo Alto, 2015) Rebates
• Permeable pavement, ≤ $1,000 at $1.5/sq. ft.
• Green roofs, ≤ $1,000 at $1.5/sq. ft. Rebates (roof runoff)
• Rain barrel $50 each
• Cisterns ≤ $1,000 at $1.50/sq. ft.
Seattle, WA (Seattle Public Utilities, 2015) • Rebates for onsite facility installation, e.g. rain garden
• Stormwater drainage fee reduction
• Rebates for onsite facility installation, e.g. cistern (Roof runoff)
• Stormwater drainage fee reduction Montgomery County, MD (County of Montgomery, 2015) Rebates
• Residential, ≤ $2,500 per parcel
• Commercial, ≤ $10,000 per parcel Rebates (roof runoff)
• Residential, ≤ $2,500 per parcel
• Commercial, ≤ $10,000 per parcel Washington, D.C. (Washington D.C., 2015)
Residential rebates Trees, ≤ $50 or $100 per tree Pervious surface, ≤ $2,500 at $1.25/sq. ft. All customers: Provide ≤55% stormwater fee discount
Residential rebates (roof runoff) Cisterns, ≤ $500 at $1/gallons All customers: Provide ≤55% stormwater fee discount REFERENCES California Financing Coordinating Committee (CFCC), 2015. 2015 Funding Fairs Handbook. California Stormwater Quality Association (CASQA), 2015. Vision and Strategic Actions for Managing Stormwater in the 21st Century (Version 1). January. City of Palo Alto, 2015. Innovative Stormwater Measures Rebate Program. http://www.cityofpaloalto.org/gov/depts/pwd/stormwater/rebates/default.asp) County of Montgomery, 2015. RainScapes Rewards Rebate Program. Environmental Protection. County of Montgomery, MD. (http://www.montgomerycountymd.gov/DEP/water/rainscapes-rebates.html) Farfsing and Watson, 2014. Stormwater Funding Options – Providing Sustainable Water Quality Funding in Los Angeles County. League of California Cities, Los Angeles County Division and California Contract Cities Association. October. LADWP, 2015. Authorization to Establish a Joint Powers Authority for Water Financing. Los Angeles Department of Water and Power. [http://clkrep.lacity.org/onlinedocs/2015/15-0148_misc_02-05-2015.pdf] Public Policy Institute of California (PICC), 2014. Paying for Water in California.
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San Francisco Public Utilities Commission (SFPUC), 2015. San Francisco’s Non-potable Water Program. A Guidebook for Implementing Onsite Water Systems in the City and County of San Francisco. City and County of San Francisco, CA. Seattle Public Utilities (SPU), 2015. RainWise Rebates for Cisterns and Rain Gardens. WA. (http://www.seattle.gov/util/environmentconservation/projects/drainagesystem/greenstormwaterinfrastructure/rainwise/rebates/) USEPA, 2013b. The Importance of Operation and Maintenance for the Long-Term Success of Green Infrastructure. A Review of Green Infrastructure O&M Practices in ARRA Clean Water State Revolving Fund Projects. Office of Water. United State Environmental Protection Agency. PA-832-R-12-007. USEPA, 2014. Developing an Outreach Strategy. July 1. (http://water.epa.gov/polwaste/npdes/swbmp/Developing-an-Outreach-Strategy.cfm) Washington D.C., 2015. RiverSmart Rebates. District Department of the Environment. Washington D.C. (http://ddoe.dc.gov/riversmartrebates)
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Beach Cities Watershed
Management Group
Revised EWMP
Appendix H:
Community
Involvement
for EWMP
Implementation
JUNE 2021
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COMMUNITY PARTICIPATION IN IMPLEMENTATION OF THE BEACH CITIES EWMP
INTRODUCTION As part of a previous Prop 1 Stormwater Implementation Grant application, the Beach Cities Watershed Management Group (Beach Cities WMG) submitted the required checklist and self-certification to the State Water Resources Control Board Department of Financial Assistance (SWRCB DFA) staff to demonstrate that the Beach Cities EWMP, in combination with several other existing documents, is functionally equivalent to a Storm Water Resource Plan (SWRP) consistent with the SWRP Guidelines.1 The original checklist and self-certification is attached herein. SWRCB DFA staff reviewed the checklist and identified one item in the checklist, Item #44, that required further revision in order for the Beach Cities SWRP to receive approval as functionally equivalent. Item #44 of the checklist addresses the Water Code Section 10562(b)(4) requirement to include community participation during plan implementation. The SWRP Guidelines provide the following guidance statement with respect to the mandatory statutory requirement to provide for community participation in plan development and implementation [California Water Code 10562(b)(4)]:
To maximize community-based benefits, key stakeholders and the public should be
involved in all appropriate implementation steps of the Storm Water Resource Plan.
Public education and opportunities for public participation in actions, decisions,
and projects implemented through watershed-based storm water management
should be provided. SWRCB DFA staff requested the Beach Cities checklist and SWRP be revised to incorporate its plan for community participation during implementation of the SWRP. Accordingly, this memorandum was drafted to provide additional documentation on that element of the Beach Cities SWRP. As described in more detail below, the Beach Cities SWRP includes community participation on both the regional and local scale. INTEGRATED REGIONAL WATER MANAGEMENT PLAN The Greater Los Angeles County Integrated Regional Water Management Plan (GLAC IRWMP) is a collaborative effort to identify and implement water management solutions on a regional scale that increase regional self-reliance, reduce conflict, and manage water to concurrently achieve social, environmental, and economic objectives on a regional scale. The GLAC IRWMP crosses jurisdictional, watershed and political boundaries; involves many agencies, stakeholders, individuals and groups; and attempts to address the issues and differing perspectives of all the entities involved through mutually beneficial solutions. The GLAC IRWMP is a multi-year effort among water retailers, 1 SWRCB, 2015. Storm Water Resource Plan Guidelines, December 15, 2015.
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wastewater agencies, stormwater and flood managers, watershed groups, the business community, tribes, agriculture and non-profit stakeholders. The GLAC IRWMP provides a mechanism for: 1) coordinating, refining, and integrating existing planning efforts within a comprehensive, regional context; 2) identifying specific regional and watershed-based priorities for implementation projects; and 3) providing funding support for the plans, programs, projects, and priorities of existing agencies and stakeholders. There are twelve (12) EWMPs and seven (7) individual Watershed Management Programs (WMPs) developed under the LA MS4 Permit that lie within the GLAC IRWM region. These EWMPs and WMPs have been incorporated into the GLAC IRWM and as such the GLAC IRWM provides a successful framework for reaching stakeholders and the public in implementing the programs and projects in the EWMPs and WMPs. By including the EWMPs and WMPs under the umbrella of the GLAC IRWMP, the region enjoys a unified approach in engaging the public in developing water projects for water quality, supply, habitat and recreation. The EWMP prepared by the Beach Cities WMG and approved by the Los Angeles Regional Water Quality Control Board is one of the EWMPs incorporated into the GLAC IRWMP. In addition, regional projects identified in the Beach Cities’ EWMP have been incorporated into the GLAC IRWMP. The GLAC IRWM Governance Structure creates a platform for water agencies, municipalities, environmental organizations and other stakeholder groups to discuss and share stormwater issues and ideas. The GLAC IRWMP meets periodically with stakeholders to discuss regional collaborative efforts, such as those included in the EWMPs. There are also five Subregional Steering Committees which coordinate local outreach efforts and planning, and the Beach Cities EWMP participates in the South Bay Steering Committee. GLAC IRWM outreach activities are posted on the LA Water Plan website (LAWaterPlan.org). The GLAC IRWM includes a Steering Committee dedicated to facilitating and supporting efforts to provide outreach activities to disadvantaged communities. A Disadvantaged Community Coordinator position was created to lead outreach efforts within the GLAC Region. In 2015, the Disadvantaged Community Coordinator led a Water Dialogue speaker series across Los Angeles to initiate discussions on water issues and to educate the public on water policy. The Disadvantaged Community Coordinator also played an active role in shaping legislation and the development of IRWM-related grant programs to maximize disadvantaged community priorities. In 2016, the Department of Water Resources (DWR) released the Final Request for Proposals for the Disadvantaged Community Involvement Program (DACIP). DWR designated $9.8 million of Proposition 1 grant funding for the Los Angeles – Ventura Funding Area. The Purpose of the DACIP is to involve disadvantaged communities and economically distressed areas in the IRWM planning process. The Program seeks to increase understanding of water needs in these areas and develop long-term solutions to address these needs, including developing projects. In 2018, two contracts were awarded to develop community outreach public education materials and broad-based public education campaigns for the Program. MEASURE W (SAFE, CLEAN WATER PROGRAM) The Measure W parcel tax on the impermeable area of private parcels throughout Los Angeles County was successfully passed by Los Angeles County voters in November 2018, creating the Safe, Clean Water Program to provide local, dedicated funding for stormwater and urban runoff to increase local water supply, improve water quality, and protect public health within the Los Angeles Basin. The
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program currently generates approximately $285 million per year. The majority of this funding goes directly back to the cities via two programs:
• The Municipal Program - 40% of the annual revenue goes directly to cities via the Municipal Program, with city-specific revenue proportional to the revenues generated within its boundaries. The Municipal Program funding can be used for eligible activities such as project development, design, construction, effectiveness monitoring, operations and maintenance (including operation and maintenance of projects built to comply with the MS4 Permit), as well as for other programs and studies related to protecting and improving water quality in lakes, rivers, and the ocean. The total annual municipal revenue projected for the Beach Cities WMG is approximately $3.4M.
• The Regional Program – 50% of the annual revenue is divided across nine watershed areas (including the South Santa Monica Bay Watershed Area, which includes the Beach Cities Area), and is devoted to funding regional watershed-based projects, project concepts, and scientific studies. The South Santa Monica Bay Watershed Area is estimated to receive up to $18.4 million annually to fund regional projects and programs. Funding for multi-benefit regional projects includes design, permits, CEQA compliance, grant-writing, right-of-way and land acquisition, construction, and long-term operations and maintenance of the facilities. The application process for regional program funds requires both local and regional outreach efforts. First, project development requires significant buy-in from the local community, with a demonstration of outreach efforts and community support as a critical part of the project application score. Second, project applications are submitted to the local Watershed Area Steering Committee (WASC) for evaluation. The WASC, comprised of representatives from cities, agencies, and community stakeholders, reviews proposed projects and develops an annual Stormwater Investment Plan (SIP) for their Watershed Area that identifies recommendations for funding. The review process is a public process, with the general public able to attend meetings and provide comments on considered projects. Recommended projects included in SIPs are also reviewed by a Regional Oversight Committee consisting of LA County Board of Supervisor-appointed subject matter experts for recommendation to the Board of Supervisors. In addition, the WASC includes a Watershed Coordinator who assists the WASC with community and stakeholder education and engagement. Therefore, projects are required to receive region-wide support for successful funding. In addition to the programs listed above, ten percent of the total annual revenue generated from the Safe, Clean Water Program is allocated to the Los Angeles County Flood Control District. The District will oversee capacity building programs including a public education program, local workforce job training, and school education programs:
• Public Education Program – LA County’s Water for LA initiative is a trusted resource on all things water to educate the public and foster more sustainable behavior to help ensure the future of the region. Water for LA envisions an LA County where residents understand and nurture their relationship with water – where it comes from, its connection to the rivers and lakes upstream, and how their actions impact their neighbors, region, ocean, and planet.
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• Workforce Training Program – The District will implement a Workforce Training Program that will provide certification classes and vocational training at the community level for the construction, inspection, operation, and maintenance of stormwater management and multi-benefit projects.
• School Education Program - The District will develop and implement a School Education Program about the LA County region and its relationship with stormwater. LOCAL COMMUNITY PARTICIPATION AND PUBLIC ENGAGEMENT In addition to the outreach efforts related to the GLAC IRWM and Safe, Clean Water Program, the Beach Cities WMG conducts several local outreach programs as part of the SWRP implementation. The Beach Cities have established a Memorandum of Understanding for the Administration and Cost Sharing for Coordination and Implementation of the Coordinated Integrated Monitoring Program (CIMP Implementation MOU), which supports the Beach Cities EWMP and drives the EWMP adaptive management process. The CIMP Implementation MOU became effective on April 14, 2016 and was unanimously extended by the Beach Cities WMG for two, 1-year terms. In December 2020, the CIMP MOU was amended to add additional services to the Scope of Services, authorize increased costs, and extend the term through December 31, 2023 with the option to further extend the term by unanimous written concurrence. The CIMP MOU includes funding and scope for watershed coordination activities including a number of tasks that facilitate public education and opportunities for public participation. The watershed coordination scope of work is adjusted annually to best address the watershed needs. The scope for reporting year 2020-2021, for example, included the following relevant tasks that support public education and participation:
• Development and implementation of watershed-specific stormwater outreach materials in the form of digital content and print materials for public dissemination.
• Coordination and management of monthly WMG meetings.
• Representation at Los Angeles Regional Water Board meetings and workshops.
• Participation in Regional EWMP and CIMP Coordination meetings on behalf of the WMG.
• Assistance with the Adaptive Management Process and updating of the Beach Cities EWMP, which includes public outreach.
• Assistance aligning joint projects for funding opportunities such as Safe, Clean Water Regional funding and GLAC IRWMP Prop 1 funding.
• Preparation of Watershed Joint Annual Reports to the Los Angeles Regional Water Quality Control Board evaluating progress toward achievement of the EWMP targets and milestones.
PUBLIC PARTICIPATION DURING EWMP DEVELOPMENT The Beach Cities WMG has conducted outreach to engage the public, Los Angeles Regional Water Quality Control Board staff, and other interested parties to support EWMP development. Input has been incorporated, as appropriate. These efforts are described in more detail below.
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Public Workshops – Original EWMP. For development of the original EWMP, public workshops were held on May 21, 2014 at the Joslyn Center in Manhattan Beach and on May 27, 2015 at the Redondo Beach Public Library. An informational presentation was provided followed by a question and answer period to encourage stakeholder input. Concerns were noted and considered during EWMP development by the Beach Cities WMG.
Technical Advisory Committee (TAC). The Beach Cities WMG actively participated in the Los Angeles region TAC and applicable subcommittees throughout the EWMP process.
LARWQCB Presentations. The Beach Cities WMG presented the proposed RAA approach to LARWQCB staff on April 9 and June 6, 2014. LARWQCB staff provided feedback during these meetings and in general they were supportive of the proposed approach. One additional meeting was held on July 31, 2014 to discuss Torrance-specific matters. In addition, the Beach Cities WMG presented the EWMP and progress on implementation to the LARWQCB in July 2018.
Public Website – Revised EWMP. As part of the revision process for the Beach Cities EWMP in 2021, the Beach Cities WMG created a website that highlighted the EWMP update process; provided details for each proposed project; and allowed for public comment to be submitted. The website was launched in May 2021.
Public Virtual Webinar – Revised EWMP. The Beach Cities WMG held a public virtual webinar on May 19, 2021 to present the draft Revised EWMP to the Beach Cities communities and receive public input. The webinar was publicized in advance by each of the four Beach Cities.
City Council Review and Adoption. The cities of Hermosa Beach, Manhattan Beach, Redondo Beach, and Torrance each brought the draft Beach Cities EWMP (2015) and draft revised Beach Cities EWMP (2021) to their respective city councils for consideration and approval to submit to the Regional Board. This process is open to the public, and residents are encouraged and invited to share comments related to the EWMP at these council meetings. Voiced concerns and recommendations were noted and considered for inclusion in the final EWMP and final Revised EWMP.
PUBLIC PARTICIPATION DURING PROJECT IMPLEMENTATION Separate MOUs will be developed as needed for each joint regional project undertaken by the Beach Cities WMG. These MOUs for cost-sharing of design and construction of regional projects will incorporate public engagement and participation at key points in the project design and construction including:
• City Council consideration and approval authorizing implementation of each regional project at award of design contract—City Council meetings are public and also can be viewed through public media feeds;
• Development of a CEQA-compliant evaluation of the project;
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• Public workshops at the preliminary design phase to share project design concepts and solicit public input and participation;
• Public groundbreaking event at the start of construction which are publicized via press release
• Coordination and outreach to the local community immediately adjacent and others that may be affected during construction of the project
• Ribbon cutting at the conclusion of construction which are publicized via press release Currently, multiple regional projects are being planned or developed by the Beach Cities WMG. Many of these projects involve more than one agency. In these cases, the relevant agencies have been coordinating outreach and community engagement efforts. For example, the Beach Cities Green Street Project involves all four Beach Cities. The four cities are coordinating outreach efforts, partnering with a local outreach firm to engage the community via both online and in-person events during project design. In the case of individually implemented EWMP regional projects or distributed projects that do not require an MOU among the EWMP WMG members, the individual agency implementing the project will carry out appropriate public engagement elements for each project. One such multi-benefit regional project underway in the City of Torrance is highlighted below.
Torrance Stormwater Basins Enhancement and Expansion Project Following initial enhancements to the Amie, Henrietta, and Entradero Flood Control Basin network completed in 2015, the City of Torrance is moving forward with further improvements to expand the capacity of these basins to fully retain the 85th percentile, 24-hour design storm from their combined 1,407-acre tributary area, comprising approximately one half of the tributary area to the Herondo Storm Drain system. The scope of this basin expansion project includes:
• Deepening of the existing Henrietta and Entradero Basins to increase storage capacity;
• Installation of drywells at Henrietta Basin to improve infiltration; and
• Adjustment of pumping levels at Amie Basin to ensure retention of the 85th percentile design storm. The project, which includes additional benefits such as walking trails and educational material, was recently submitted for funding under the Safe Clean Water Program. Preliminary design of the project is currently in process, with an estimated construction completion in 2024 (City of Torrance, 2020a). For the first enhancement project, a community meeting was held prior to design of the project. The project design approach was also presented at the California Storm Water Quality Association conference in September 2014. At the completion of the project, an open house was held for the community on November 7, 2015. Ongoing outreach occurs through monthly docent-led tours of the Henrietta Basin.
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For the current expansion project, the City of Torrance held its first community outreach meeting at Entradero Park on October 10, 2020. Due to COVD-19-related restrictions and concerns, the meeting was safely held outdoors, with mask requirements and social distancing observed. 44 residents were registered as attendants at the meeting, and 23 comment cards were submitted by attendees. Additionally, the City maintains a project-specific website that provides residents with project information and provides direction on how to provide feedback on the project.
PUBLIC ENGAGEMENT AND EDUCATION IN STORMWATER POLLUTION PREVENTION The Beach Cities WMG has been implementing a customized, collaborative Public Information and Participation Program (PIPP) consistent with Regional Board staff’s approval of this approach through adaptive management in March 2019. The PIPP has been adapted to address the Beach Cities WMG’s highest water quality priorities and to allow for more effective and targeted distribution of education and outreach materials to Beach Cities residents and businesses. This customized strategy includes the ongoing development of outreach materials promoting behavioral change in the DIY residential community that is a source of targeted pollutants of concern to the Beach Cities WMG and distribution of these materials using multiple methods, such as distribution of print materials at public offices and community events and the use of internet-based platforms. This customized strategy includes a variety of outreach efforts. Examples of the types of outreach methods which have been implemented to engage the public by the Beach Cities WMG members or in partnership with other local agencies are provided below.
Environmentally Friendly Landscaping, Gardening and Pest Control webpages The Beach Cities WMG along with the Peninsula WMG, has established and collaboratively maintains and periodically updates Sustainable Gardening and Landscaping and Integrated Pest Management (IPM) webpages to disseminate information on CA friendly landscaping, responsible irrigation, integrated pest management and the proper use and disposal of pesticides and fertilizers. The Beach Cities and Peninsula WMGs contract with the South Bay Environmental Services Center (SBESC) to host these pages on their website: http://www.southbaycities.org/programs/environmentally-friendly-landscaping-gardening-and-pest-control. The South Bay Environmental Services Center (SBESC), a clearinghouse for energy efficiency, water conservation and environmental information. The SBESC is a program of the South Bay Cities Council of Governments, a joint powers authority of 16 cities in the South Bay of Los Angeles along with the County of Los Angeles. The SBESC website is the central place for residents to explore information regarding environmental topics, and their E-newsletter has a circulation of nearly 15,500. The website also promotes visitation of the Beach Cities WMG’s several water-efficient demonstration gardens by listing their location and showcasing photos.
Residential Rainwater Harvesting Guide The Beach Cities WMG in partnership with the Peninsula WMG developed the South Bay Homeowner’s Guide to Rainwater Harvesting. The concept and design for the guide were adapted from the City of Los Angeles Rainwater Harvesting Program – A Homeowner’s How-To Guide November 2009 1st Edition, and a similar guide prepared by the Santa Monica Bay Restoration Foundation for Culver City. The guide provides an introduction to residential rainwater harvesting and covers the topics of downspout disconnection and redirection to permeable surfaces, rain garden
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design and installation, selection of appropriate CA friendly plants, and rain barrel installation. The guide also provides a wealth of additional resources for homeowners looking to implement additional rainwater harvesting methods or seeking supplemental information. Multiple stakeholders were engaged in the development of this rainwater harvesting program with multiple city staffs, particularly building officials, as well as Los Angeles County Building & Safety staff involved in reviewing and commenting on the Guide to ensure that it would be consistent with local ordinances and policies. Several opportunities for input were provided and this constructive stakeholder feedback has improved the utility of the Guide. The Guide includes a section on maintenance and incorporates advice on periodic inspection and measures or adjustments to correct common problems.
Business Assistance Program for Food Service Establishments and Mobile Businesses The Beach Cities WMG conducts annual inspections of food service establishments during which onsite managers are educated about stormwater and non-stormwater pollution prevention requirements. The managers are advised of opportunities to become certified in one of several environmental certification programs (Bay Foundation Clean Bay Restaurant Certification, Surfrider Ocean Friendly Restaurant Certification, Green Business Certification). The Beach Cities WMG also developed a “Flow on the Go” tip card to distribute to targeted mobile businesses that generate wastewater such as auto detailers, window washers, and pet groomers as potential sources of non-stormwater discharges containing pollutants of concern. The tip card covers site preparation and cleanup, spill prevention and response, storm drain inlet protection, and proper disposal of wastewater. The tip card also encourages the use of dry-cleaning methods and environmentally friendly cleaning products. While this outreach targets the mobile business sector, it will also reach residents and businesses that use these services and educate them on proper BMPs and the importance of proper waste disposal. The tip card was developed for both digital posting to agency websites as well as distribution through code enforcement interactions and at public counters.
Ocean Friendly Landscape Workshops West Basin Municipal Water District, in partnership with Surfrider Foundation, provides free Ocean Friendly Landscape workshops for residents within the Beach Cities WMG to help them manage their landscapes more efficiently. The program consists of a classroom presentation along with a hands-on-workshop at a demonstration garden location. Topics covered in the workshops have addressed both stormwater and non-stormwater pollutant source reduction. Residents learn about permeable pavement, drought-tolerant and native plants, proper use of mulch and smart irrigation control equipment. The objective of these workshops is to teach participants to apply methods that will reduce water consumption, runoff, and ocean pollution. As part of the Ocean Friendly Landscape program, West Basin periodically holds weather-based irrigation controller exchange events where customers can attend a 30-minute training on how to install and operate the weather-based irrigation controllers and then trade in their old, inefficient controllers for a new free controller. This program is typically promoted by each of the Beach Cities agencies through their websites and e-distribution channels.
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Rain Barrel Distribution Rain barrel distribution or rebate programs engage and educate the community through active participation in stormwater capture and may serve as a stepping-stone to more significant residential stormwater capture retrofit projects such as downspout disconnection into cisterns or rain gardens. The West Basin Municipal Water District program has distributed free rain barrels to residents within its service district; the program has included a 50-gallon capacity barrel equipped with overflow spout, built-in mosquito screen, and a rain gutter downspout flex arm hose connector. In a separate program, the Metropolitan Water District of Southern California (MWD) has provided $75 rebates to residents within its service district who purchased their own barrels. To date, an estimated total of 1,986 residences have been retrofit with rain barrels in the Beach Cities WMG area.
Irrigation Reduction Incentives West Basin Municipal Water District offers a Landscape Irrigation Efficiency Program for large landscape water users (residents and businesses) within its service area, including the Beach Cities WMG members. The program provides outdoor water evaluations which identify leaks, broken sprinklers and pipes, unnecessary runoff, sprinkler controller issues, and other water wasting problems in landscapes. The program includes sprinkler nozzle retrofits and an outdoor water use report complete with recommendations on more efficient outdoor watering habits. The Beach Cities agencies also maintain a number of California Friendly gardens and landscapes located throughout the Beach Cities WMG area that demonstrate to residents the beauty, utility and economy of native and drought-tolerant plants which require less water, fertilizer and pesticides than traditional landscape plantings. Most of these demonstration gardens are also equipped with interpretive signage. The Environmentally Friendly Landscaping, Gardening and Pest Control webpages hosted by the South Bay Environmental Services Center include a page dedicated to highlighting these demonstration gardens.
Community Events Each of the Beach Cities typically hosts an annual Coastal Cleanup Day event on its respective beach in partnership with Heal the Bay, the Ocean Conservancy, and the California Coastal Commission. Each agency also hosts at least one other public outreach event each year, such as a household hazardous waste roundup, an Earth Day event or Safety Fair, which provide opportunities to disseminate information about stormwater and urban runoff pollution.
Pet Waste Management Outreach The Beach Cities WMG agencies maintain pet waste collection and clean-up stations in each of their respective municipal parks. In addition, the linear greenbelts that serve as jogging/walking paths through the cities of Hermosa Beach, Manhattan Beach and Redondo Beach are also equipped with pet waste collection stations, as are The Strands in Hermosa and Manhattan Beach and the Esplanade in Redondo Beach. These pet waste stations serve as a catalyst and reminder for behavior change by pet owners as well as a means of reducing pollutant loading.
Small Construction Site BMP Brochure In order to enhance the effectiveness of the Beach Cities WMG agency’s individual construction programs and to provide a comprehensive and uniform set of expectations for building contractors
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across the EWMP area, the Beach Cities WMG developed a Small Site Construction brochure targeted at contractors working on construction sites less than 1-acre in disturbed area. The brochure is available in both English and Spanish and describes the BMPs required by the MS4 Permit, including an illustration of where and how to deploy these BMPs on a residential construction site. The brochure also includes information regarding material storage and handling as well as spill prevention, clean-up and disposal.
Regional Residential and Business Outreach In addition to the development and distribution of outreach materials targeted at the local residential community, the Beach Cities WMG leverages successful existing statewide and regional outreach programs such as the CalRecycle Used Oil and Household Hazardous Waste Program (Used Oil Program) and many additional programs coordinated by the South Bay Environmental Services Center (SBESC) and promoted through SBESC via e-mail blasts to residents and businesses regarding opportunities to learn and become actively involved in water conservation and stormwater pollution prevention. These include Metropolitan Water District California Friendly Landscaping and Turf Removal workshops, Water Replenishment District’s Eco-Friendly Gardener Series, and West Basin water conservation workshops and classes.
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ATTACHMENT 1 – CHECKLIST AND SELF-CERTIFICATION
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65270.00001\34012066.1
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AMENDMENT TO DISSOLUTION OF MEMORANDUM OF UNDERSTANDING
BETWEEN
THE CITY OF HERMOSA BEACH, THE CITY OF MANHATTAN BEACH, THE CITY OF REDONDO
BEACH, THE CITY OF TORRANCE, AND THE LOS ANGELES COUNTY FLOOD CONTROL DISTRICT
RELATED TO DESIGN OF JOINT REGIONAL PROJECTS WITHIN THE SMB 6-01 ANALYSIS REGION
OF THE ENHANCED WATERSHED MANAGEMENT PROGRAM (EWMP)
FOR THE BEACH CITIES WATERSHED MANAGEMENT GROUP
This document memorializes an amendment to the 2020 dissolution of the 2017 MEMORANDUM
OF UNDERSTANDING BETWEEN THE CITY OF HERMOSA BEACH, THE CITY OF MANHATTAN
BEACH, THE CITY OF REDONDO BEACH, THE CITY OF TORRANCE, AND THE LOS ANGELES COUNTY
FLOOD CONTROL DISTRICT FOR IMPLEMENTATION OF JOINT REGIONAL PROJECTS WITHIN THE
SMB 6-01 ANALYSIS REGION OF THE ENHANCED WATERSHED MANAGEMENT PROGRAM
(“EWMP”) FOR THE BEACH CITIES WATERSHED MANAGEMENT GROUP. Collectively, these
entities shall be known herein as “PARTIES” or individually as “PARTY”.
RECITALS
A. In 2020, the Parties entered into a dissolution agreement. The purpose of the
agreement was expressly stated to “wind down the obligations set forth in the September 26,
2017 cost sharing MOU and to memorialize an understanding of the Parties’ intent to consider
implementing a new a joint regional structural project(s) within the SMB 6-01 analysis region of
the EWMP Area identified in the EWMP due to the interconnected nature of the MS4, until such
time as a new project site or sites are identified and the Parties enter into a new cost-sharing
MOU for the project(s) to replace this agreement.
B. Under the dissolution agreement, Hermosa Beach committed to, among other things,
“fund $160,000 and Redondo Beach [would] manage a feasibility study to identify feasible
location(s) for an alternative project or projects in Redondo Beach, and additional alternative
location(s) within Hermosa Beach if the project or project locations in Redondo Beach do not
feasibly and economically achieve the water quality limits set forth in the MS4 permit, in
collaboration with Hermosa Beach staff, subject to the limitation that a project (or projects) in
Hermosa Beach shall capture no more than 150% of Hermosa Beach’s contribution to the
Herondo Storm Drain (approximately 20.4 %).
C. The EWMP is required to be updated by June 30, 2021. Due to the accelerated timeline
of this EWMP update, the full feasibility study anticipated in the dissolution agreement was not
completed. In lieu of that initial feasibility study, the parties (through their consultant) engaged
in analysis of existing data and new modelling, and identified new project options that were not
known at the time the dissolution agreement was negotiated. While feasibility studies will
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commence soon, the parties agree that the funding commitment from Hermosa Beach will be
removed from the dissolution agreement in light of this modified path forward and EWMP
Update.
NOW, THEREFORE, in consideration of the mutual benefits to be derived by the PARTIES,
and of the promises contained in this Amendment to Dissolution of MOU, the PARTIES agree as
follows:
Section 1. Recitals. The recitals set forth above are incorporated into this Amendment to
Dissolution of MOU.
Section 2. Amendment. The parties agree that the Dissolution of MOU is hereby amended
to add the following additional new paragraph 3.h:
h. Notwithstanding the terms above, should the parties approve a revised EWMP that has
not proceeded under process detailed above, the City of Hermosa Beach is relieved of its
obligation to fund the first $160,000 for the feasibility study referenced in subsections b
and c above. The parties will proportionally share the cost of any future feasibility studies
related to the EWMP Update in accordance with the Memorandum Of Understanding
Between The City Of Redondo Beach, The City Of Hermosa Beach, The City Of Manhattan
Beach, The City Of Torrance, And The Los Angeles County Flood Control District Regarding
The Administration And Cost Sharing For Updating The Enhanced
Watershed Management Program And Reasonable Assurance Analysis For The Beach
Cities Watershed Management Group (executed by Hermosa Beach on October 27, 2020).
Section 3. The remaining terms of the Dissolution of MOU remain in force and effect, except as
modified in this Amendment.
IN WITNESS WHEREOF, the PARTIES hereto have caused this MOU to be executed by their
duly authorized representatives and affixed as of the date of signature of the PARTIES:
[SIGNATURE PAGES FOLLOW]
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CITY OF MANHATTAN BEACH
By: Date:
Bruce Moe
City Manager
ATTEST:
By:
Liz Tamura
City Clerk
APPROVED AS TO FORM:
By:
Special Counsel
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CITY OF TORRANCE
By: Date:
Patrick J. Furey, Mayor
ATTEST:
By:
Rebecca Poirier
City Clerk
APPROVED AS TO FORM:
By:
Patrick Q. Sullivan, City Attorney
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CITY OF REDONDO BEACH
By: Date:
William C. Brand, Mayor
ATTEST:
By:
Eleanor Manzano
City Clerk
APPROVED AS TO FORM:
By:
Mike Webb, City Attorney
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CITY OF HERMOSA BEACH
By: Date:
Justin Massey
Mayor
ATTEST:
By:
Eduardo Sarmiento
City Clerk
APPROVED AS TO FORM:
By:
Michael Jenkins, City Attorney
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City Hall
1315 Valley Drive
Hermosa Beach, CA 90254
Staff Report
REPORT 21-0296
Honorable Mayor and Members of the Hermosa Beach City Council
Regular Meeting of June 8, 2021
APPROVAL OF SECOND AMENDMENT TO AGREEMENT FOR JANITORIAL MAINTENANCE
SERVICES WITH COMMERCIAL BUILDING MAINTENANCE (FORMERLY GOLDEN TOUCH
CLEANING, INC.)
(Interim Public Works Director Angela Crespi)
Recommended Action:
Staff recommends City Council:
1.Approve the proposed second amendment to an agreement with Commercial Building
Maintenance for janitorial maintenance services to extend the contract by one year,through
June 30,2022,and to increase the total amount of the agreement by $133,890 for services
during the extended contract year,resulting in a total amended contact term of five years and
a total amended contract amount of $590,619; and
2.Authorize the Mayor to execute and the City Clerk to attest the attached second amendment
subject to approval by the City Attorney (Attachment 2).
Executive Summary:
The City entered into a contract on June 15,2017 with Commercial Building Maintenance (formerly
known as Golden Touch Cleaning,Inc.)to provide janitorial maintenance services at City-owned
facilities.At the June 23,2020 meeting,City Council approved the first amendment extending the
agreement by one year and increasing the compensation by $128,733.The current agreement is
set to expire on June 30,2021.The proposed second amendment would extend the agreement for
one additional year and increase the compensation by $133,890 for the additional year of services,
resulting in a total amended contract term of five years and total amended contract amount of
$590,619.The additional year would allow staff the time necessary to perform a new competitive
bidding process.
Background:
On May 4,2017,the City invited janitorial contractors to submit proposals for the provision of
janitorial maintenance services at City-owned properties.The Request for Proposals (RFP)covered
services needed at City Hall;Community Center;Community Services Building;Bowling Green
Building;South Park;the Police Department;and the City Yard for a three-year period from FY 2016-
17 through FY 2019-20.Commercial Building Maintenance (formerly known as Golden Touch
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REPORT 21-0296
17 through FY 2019-20.Commercial Building Maintenance (formerly known as Golden Touch
Cleaning, Inc.) was selected as the most qualified vendor.
At its regular meeting on June 15,2017,City Council approved the award of a three-year janitorial
maintenance services agreement with Commercial Building Maintenance (formerly known as Golden
Touch Cleaning,Inc.)with a not-to-exceed compensation amount of $327,996 (Attachment 1).The
scope of work includes the provision of janitorial maintenance services at various City-owned
facilities.At its regular meeting on June 23,2020,City Council approved the first amendment
extending the agreement by one year and increasing the total compensation by $128,733 for the
fourth year of services.
Past Council Actions
Meeting Date Description
June 15, 2017 (Regular Meeting)
Award of janitorial maintenance services agreement to Commercial Building
Maintenance (formerly known as Golden Touch Cleaning, Inc.)
June 23, 2020 (Regular Meeting)
Approval of first amendment to agreement extending term by one year and increasing
the compensation by $128,733
Discussion:
For the past four years,Commercial Building Maintenance has provided janitorial maintenance
services at City-owned facilities.With the current agreement set to expire on June 30,2021,staff
recommends extending the agreement for a fifth and final year.
Due to workload related to the COVID-19 pandemic and reduced staffing levels,the Public Works
Department was unable to prepare a new Request for Proposals (RFP)process to competitively
select a new vendor.Approval of the requested one-year extension would allow the continuation of
these services while a new selection process is prepared and completed.
Commercial Building Management has performed all requested services at a satisfactory level
including cleaning and disinfecting for the COVID-19 pandemic.In a proposal provided by the
contractor,the cost for the FY 2021-22 contract year would be $133,890 and would include additional
services resulting from the COVID-19 pandemic.The added sanitation services would consist of a
roaming day porter working an eight-hour schedule from 8:00 a.m.to 4:00 p.m.to allow additional
sanitation,disinfecting,and restocking of common areas and restrooms twice per day at City Hall,
Community Center, Police Station, and City Yard (Attachment 3).
If approved,the proposed second amendment would extend the agreement through June 30,2022
with an annual contract amount of $133,890 for the fifth contract year.In total,the amended
agreement would have a total compensation amount of $590,619 over five years (Attachment 2).
General Plan Consistency:
This report and associated recommendation have been evaluated for their consistency with the City’s
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This report and associated recommendation have been evaluated for their consistency with the City’s
General Plan. Relevant Policies are listed below:
Infrastructure Element
Goal 1. Infrastructure systems are functional, safe, and well maintained.
Policies:
·1.8 Minimize recurring repairs.Ensure that recurring repairs to City facilities are minimized by
investing in low maintenance materials and performing preventive procedures where available.
Fiscal Impact:
The fiscal impact of the recommended action would be covered by the requested appropriation of
$133,890 in the FY 2021-22 Preliminary Budget from the General Fund’s Building Maintenance
Division.
Agreement Modification Request
Agreement
Current
Authorized
Amount
Modified
Request
Amount
FY 2021 -22
Budget Dept.
Account #
Total Revised
Contract
Amount
Janitorial Maintenance Services
Agreement with Commercial
Building Maintenance
$456,729
$133,890
001 -4204 -4201
$590,619
Attachments:
1.Agreement for Janitorial Maintenance Services Agreement with Commercial Building
Maintenance
2.Proposed Second Amendment to Commercial Building Maintenance
3.Proposal from Commercial Building Maintenance for FY 2021-22 Services
Respectfully Submitted by: John Cordova, Public Works Superintendent
Concur: Lucho Rodriguez, Deputy City Engineer
Concur: Angela Crespi, Interim Public Works Director
Noted for Fiscal Impact: Viki Copeland, Finance Director
Legal Review: Mike Jenkins, City Attorney
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Staff Report
REPORT 21-0296
Approved: Suja Lowenthal, City Manager
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SECOND AMENDMENT TO AGREEMENT FOR JANITORIAL MAINTENANCE
SERVICES BETWEEN THE CITY OF HERMOSA BEACH AND COMMERCIAL
BUILDING MANAGEMENT (FORMERLY GOLDEN TOUCH CLEANING, INC.) TO
EXTEND THE CONTRACT ONE YEAR AND INCREASE THE CONTRACT
AMOUNT.
This Second Amendment to the Agreement for Janitorial Maintenance Services
(“Second Amendment”) is entered into by and between the City of Hermosa Beach, a
municipal corporation (“City”) and Commercial Building Maintenance (“Contractor”) as of
July 1, 2021.
RECITALS
A.City and Contractor are parties to an Agreement for Janitorial Maintenance Services
dated June 15, 2017 (the “Agreement”) by which City engaged Contractor to provide
janitorial maintenance services at City-owned facilities.
B.On June 23, 2020, the City and Consultant executed a first amendment to the Agreement
to extend the contract term for one year, and increase the annual amount of $109,332 by
$19,401 for a total of $128,733 to continue janitorial maintenance services plus extra
services to accommodate sanitation requirements pertaining to COVID-19.
C.City and Contractor now desire to amend the Agreement in order to extend the contract
term for one year, and increase the annual amount of $128,733 by $5,157 for a total of
$133,890 to continue janitorial maintenance services, including extra services to
accommodate sanitation requirements pertaining to COVID-19.
NOW, THEREFORE, in consideration of the foregoing, the agreement is
amended as follows:
1.Notwithstanding the provisions of Section 2 of the Agreement, the term of the
Agreement is extended for one additional year to June 30, 2022, on which date
it will expire unless extended in writing by the parties.
2. City shall pay Contractor a fixed sum of $133,890 for services as
described in Exhibit A from July 1, 2021 through June 30, 2022.
Except as above modified, in all other respects the Agreement is hereby reaffirmed in full
force and effect.
CITY OF HERMOSA BEACH CONSULTANT
Justin Massey, Mayor David Parsons, President
Commercial Building Maintenance
ATTEST: APPROVED AS TO FORM:
Eduardo Sarmiento, City Clerk Michael Jenkins, City Attorney
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City of Hermosa Beach Cost Proposal for year 07/01/21 - 06/30/2022
Note: Covid-19 guide lines were provided and will be followed during this contract.
Proposal Items Monthly Cost Yearly Cost
1.-Clark Building $546.00 $6,552.00
2.-General Services Building $420.00 $5,040.00
3.-City Hall, Council Chambers, Patio and $1,150.00 $13,800.00Public Restrooms
4.-Police Department $1,325.00 $15,900.00
5.-Jail $200.00 $2,400.00
6.-Community Center, Gymnasioum,$2,200.00 $26,400.00Theater and Courtyard
7.-City Yard $350.00 $4,200.00
8.-Fire Department $340.00 $4,080.00
9.-South Park $165.00 $1,980.00
10.-Lawn Bowling Building $165.00 $1,980.00
11.-
Roaming Day Porter, Community Center,
$4,296.44 $51,557.31Police Dept, City Hall & City Yard.
He will sanitize, disinfect and restocked
all common areas restooms twice per day.
Totals $11,157.44 $133,889.31
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Staff Report
City Hall
1315 Valley Drive
Hermosa Beach, CA 90254
Staff Report
REPORT 21-0297
Honorable Mayor and Members of the Hermosa Beach City Council
Regular Meeting of June 8, 2021
APPROVAL OF FIRST AMENDMENT TO AGREEMENT FOR SANITARY SEWER HYDRO-
FLUSHING AND VIDEO INSPECTION MAINTENANCE SERVICES WITH EMPIRE PIPE
CLEANING & EQUIPMENT, INC.
(Interim Public Works Director Angela Crespi)
Recommended Action:
Staff recommends City Council:
1.Approve the proposed first amendment to an agreement with Empire Pipe Cleaning &
Equipment,Inc.for sanitary sewer hydro-flushing and video inspection maintenance services
to extend the contract by one year,through June 30,2022,and to maintain the annual amount
of $160,310 for fixed services during the extended contract year,resulting in a total amended
contract term of four years and total amended contract amount of $637,020; and
2.Authorize the Mayor to execute and the City Clerk to attest the attached first amendment
subject to approval by the City Attorney (Attachment 2).
Executive Summary:
The City entered into a contract on September 17,2018 with Empire Pipe Cleaning &Equipment,
Inc.to provide sanitary sewer hydro-flushing and video maintenance services throughout the City.
The current agreement is set to expire on June 30,2021.The proposed first amendment would
extend the agreement for one additional year and maintain the current annual amount of $160,310
for fixed services to be provided during the fourth contract year,resulting in a total amended contract
term of four years and total amended contract amount of $637,020.The additional year would allow
staff the time necessary to perform a new competitive bidding process.
Background:
On June 14,2018,the City invited sanitary sewer hydro-flushing and video contractors to submit
proposals for the provision of sanitary sewer-hydro flushing and video services.The Request for
Proposals (RFP)covered the maintenance of 37 miles of sewer mains and 880 sewer access holes
for a three-year period from FY 2019-20 through FY 2020-21.Empire Pipe Cleaning &Equipment,
Inc. was selected as the lowest responsible bidder meeting all qualifications.
At its regular meeting on September 17,2018,City Council approved the award of a three-year
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At its regular meeting on September 17,2018,City Council approved the award of a three-year
sanitary sewer hydro-flushing and video maintenance services agreement with Empire Pipe Cleaning
&Equipment,Inc.with a fixed compensation amount of $476,710 (Attachment 1).The scope of
work includes an annual citywide cleaning of the entire system,quarterly cleaning of known problem
areas,and emergency on-call services.These services assist the City in providing reliable sewer
collection services to residents and businesses within city limits.All sewer flows are conveyed to the
Los Angeles County Sanitation Districts system for treatment and processing.
Past Council Actions
Meeting Date Description
September 17, 2018 (Regular Meeting)
Award of sanitary sewer mainteannce services agreement to Empire Pipie Cleaning &
Equipment, Inc.
Discussion:
For the past three years,Empire Pipe Cleaning &Equipment,Inc.has provided the necessary sewer
hydro-flushing and video services to the City.With the current agreement set to expire on June 30,
2021, staff recommends extending the agreement for a fourth and final year.
Due to workload related to the COVID-19 pandemic and reduced staffing levels,the Public Works
Department was unable to prepare a new Request for Proposals (RFP)process to competitively
select a new vendor.Approval of the requested one-year extension would allow the continuation of
these critical services while a new selection process is prepared and completed.
Empire Pipe Cleaning &Equipment,Inc.has performed all requested services at a satisfactory level
including timely response to sewer emergencies.In a letter dated February 22,2021,the contractor
agreed to maintain current pricing for one additional year (Attachment 3).If approved,the proposed
first amendment would extend the agreement by through June 30,2022 and with an annual amount
of $160,310 for the fourth contract year.In total,the amended agreement would have a total
compensation amount of $637,020 over four years (Attachment 2).
General Plan Consistency:
This report and associated recommendation have been evaluated for their consistency with the City’s
General Plan. Relevant Policies are listed below:
Infrastructure Element
Goal 1. Infrastructure systems are functional, safe, and well maintained.
Policies:
·1.8 Minimize recurring repairs.Ensure that recurring repairs to City facilities are minimized by
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investing in low maintenance materials and performing preventive procedures where available.
Fiscal Impact:
The recommended action would result in a request for an appropriation of $160,310 in the FY 2021-
22 Preliminary Budget from the Sewer Fund.
Agreement
Current
Authorized
Amount
Modified
Request
Amount
FY 2021-22
Budget Dept.
Account #
Total Revised
Contract
Amount
Sanitary Sewer Hydro-Flushing
and Video Inspection
Maintenance Services with Empire
Pipe Cleaning & Equipment, Inc.
$476,710 $160,310 160-3102-4201 $637,020
Agreement Modification Request
Attachments:
1.Agreement for Sanitary Sewer Hydro-Flushing and Video Inspection Maintenance Services
with Empire Pipe Cleaning & Equipment, Inc.
2.Proposed First Amendment to Empire Pipe Cleaning & Equipment, Inc. Agreement
3.Letter Dated February 22, 2021 from Empire Pipe Cleaning & Equipment, Inc.
Respectfully Submitted by: John Cordova, Public Works Superintendent
Concur: Lucho Rodriguez, Deputy City Engineer
Concur: Angela Crespi, Interim Public Works Director
Noted for Fiscal Impact: Viki Copeland, Finance Director
Legal Review: Mike Jenkins, City Attorney
Approved: Suja Lowenthal, City Manager
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FIRST AMENDMENT TO AGREEMENT FOR SANITARY SEWER HYDRO-
FLUSHING AND VIDEO INSPECTION MAINTENANCE SERVICES BETWEEN THE
CITY OF HERMOSA BEACH AND EMPIRE PIPE CLEANING & EQUIPMENT INC.
TO EXTEND THE CONTRACT ONE YEAR.
This First Amendment to the Agreement for Sanitary Sewer Hydro-Flushing and Video
Inspection Maintenance Services (“First Amendment”) is entered into by and between the City
of Hermosa Beach, a municipal corporation (“City”) and Empire Pipe Cleaning and
Equipment Inc. (“Contractor”) as of July 1, 2021.
RECITALS
A. City and Contractor are parties to an Agreement for Sanitary Sewer Hydro-Flushing
and Video Inspection Maintenance Services dated September 17, 2018 (the
“Agreement”) by which City engaged Contractor to provide sanitary sewer hydro-
flushing and video inspection maintenance services on City-owned sewer lines,
manholes, and equipment.
B. City and Contractor now desire to amend the Agreement in order to extend the contract
term for one year, and maintain the annual amount of $160,310, to continue sanitary
sewer hydro-flushing and video inspection maintenance services.
NOW, THEREFORE, in consideration of the foregoing, the Agreement is amended as
follows:
1. Notwithstanding the provisions of Section 2 of the Agreement, the term of the
Agreement is extended for one additional year to June 30, 2022, on which date
it will expire unless extended in writing by the parties.
2. City shall pay Contractor a fixed sum of $160,310 for services as
described in Exhibit A from July 1, 2021 through June 30, 2022.
Except as above modified, in all other respects the Agreement is hereby reaffirmed in full
force and effect.
CITY OF HERMOSA BEACH CONSULTANT
Justin Massey, Mayor Craig Van Thyne, Vice President
Empire Pipe Cleaning & Equipment Inc.
ATTEST: APPROVED AS TO FORM:
Eduardo Sarmiento, City Clerk Michael Jenkins, City Attorney
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City Hall
1315 Valley Drive
Hermosa Beach, CA 90254
Staff Report
REPORT 21-0350
Honorable Mayor and Members of the Hermosa Beach City Council Regular
Meeting of June 8, 2021
UPDATE TO COMMERCIAL AND RESIDENTIAL EVICTION MORATORIUMS
(City Attorney Michael Jenkins)
(Assistant City Attorney Monica Castillo)
Recommended Action:
Staff recommends City Council:
1.Option 1:
a.Allow the Commercial Eviction Moratorium to sunset on June 30, 2021;
b.Take no action to readopt a Residential Eviction Moratorium;
c.Extend the requirement that residential landlords obtain building permits before evicting
tenants to demolish or substantially remodel property; and
d.Aggressively promote the state rental assistance program on the City’s website and
other local media.
2.Option 2:
a.Allow the Commercial Eviction Moratorium to sunset on June 30, 2021;
b.Adopt a new Residential Eviction Moratorium,effective July 1,2021,with amendments
to reflect current economic, regulatory, and public health climate;
c.Extend the requirement that residential landlords obtain building permits before evicting
tenants to demolish or substantially remodel property;
d.Consider extending the requirement that commercial landlords obtain building permits
before evicting tenants to demolish or substantially remodel property; and
e.Aggressively promote the state rental assistance program on the City’s website and
other local media.
3.Option 3:
a.Provide other direction to staff.
Executive Summary:
The City of Hermosa Beach currently has eviction moratoriums in place protecting commercial and
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residential tenants through June 30, 2021. Staff recommends City Council receive an update and
provide staff direction regarding the approaching expiration of the City’s commercial and state’s
residential eviction moratoriums and other expiring tenant protections.
Background:
Commercial Eviction Moratorium for Non-Payment of Rent Due to COVID-19
The City of Hermosa Beach has an eviction moratorium in place protecting commercial tenants from
eviction for failure to pay rent due to financial impacts related to the COVID-19 pandemic through
June 30,2021,effectively deferring payment of rent during the current commercial eviction
moratorium period.Those who suffer a partial loss of income during the moratorium must pay the pro
-rated shared of their rent that corresponds to the income they generated during the period of loss.
The City’s moratorium was adopted pursuant to Governor Newsom’s Executive Order N-03-21,
authorizing commercial eviction moratorium ordinances at the local level.The order will expire on
June 30, 2021, the same day when the City’s commercial eviction moratorium expires.
Repayment Period: July 1 - December 31, 2021
If the moratorium is not extended,tenants will have six months from when the moratorium expires to
completely repay deferred rent.Starting July 1,2021,commercial tenants must again pay their full
monthly rent on time and begin paying portions of deferred rent remaining from the moratorium
period.They have until December 31,2021 to pay off all remaining deferred rent.Conceivably,a
tenant could pay any amount above the tenants monthly rent during the repayment period and pay
the remaining sum on December 31, 2021.
Residential Eviction Moratorium for Non-Payment of Rent Due to COVID-19
The City’s existing residential eviction moratorium incorporates the state’s procedures for eviction
protection and also sets forth the repayment period for deferred rent as dictated by state law.It
covers two different moratorium periods:the period when the City’s local moratorium was in place
and the period from when the state’s moratorium took over up until when it will expire on June 30,
2021.
From March 16,2020 through September 30,2020,the City’s local moratorium protected tenants
from evictions based on the non-payment of rent due to financial impacts related to COVID-19.When
California’s residential eviction moratorium was enacted on August 31,2020,it allowed the City’s
local moratorium to remain in effect until it expired September 30,2020,but also set a local
repayment period for deferred rent.
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From October 1,2020 through June 30,2021,the period governed by the state moratorium,tenants
were and are required to follow the state’s preconditions for eviction protection.These include
providing a declaration of financial hardship to the landlord within 15 days of its receipt and payment
of partial (25%) rent no later than June 30, 2021.
If the City Council wishes to enact a new residential moratorium it must do so with caution.New
legislative findings will need to be made demonstrating how present-day conditions justify the
moratorium, and the moratorium protections will need to be tailored to those conditions.
Repayment Period: October 1, 2020 - March 31, 2021
When the state eviction moratorium was enacted,it set a repayment period of October 1,2020
through March 31,2021.Despite the March 31 deadline having passed,state law prevents courts
from ordering tenants protected under the state’s eviction moratorium to pay rental debt until July 1,
2021 at the earliest.
With respect to commercial and residential repayment periods,nothing in state law or the City’s
moratorium prohibits landlords and tenants from negotiating payment amounts and periods suited to
their circumstances.They are strongly encouraged to do so,as they are in the best position to
balance their individual hardships to the extent they have received PPP loans or other financial
assistance from the state or federal government.
Eviction Protections for Demolition and Substantial Remodeling of Property
To supplement its commercial eviction moratorium and the state’s residential eviction moratorium,the
City instituted protections that require residential and commercial landlords to obtain building permits
before evicting tenants to demolish or substantially remodel their properties.These protections will
expire on June 30, 2021.
Past Council Actions
Meeting Date Description
March 16, 2020
Resolution No. 20-7230 Confirming the Proclamation of a Local
Emergency and Initiating Commercial and Residential Eviction
Moratoriums
March 24, 2020
Urgency Ordinance No. 20-1406U, Temporary Moratorium on Evictions
for Nonpayment of Rent by Residential Tenants and Commercial Tenants,
and Temporary Suspension on Residential and Commercial
Foreclosures
April 14, 2020
Urgency Ordinance No. 20-1407U, To Amend the Temporary Moratorium
on Foreclosures and Evictions Due to Non-Payment of Rent by
Residential and Commercial Tenants Impacted by COID-19. Amended
the Eviction Moratorium in 20-1406U in its entirety in light of Governor
Newsom’s Financial Relief Package announced on March 25, 2020.
May 26, 2020 Urgency Ordinance No. 20-1409U, Extending the Temporary Moratorium
on Evictions
July 28, 2020 Urgency Ordinance No. 2020-1414U, Extending the Temporary
Moratorium on Evictions During the COVID-19 Pandemic
September 22, 2020 Urgency Ordinance No. 20-1417U, Clarifying the Temporary Moratorium
on Evictions During the COVID-19 Pandemic
November 24, 2020 Urgency Ordinance No. 20-1420U, Temporary Moratorium on
Commercial Evictions During the COVID-19 Pandemic
December 8, 2020 Urgency Ordinance No. 20-1422U, Amending the Temporary Moratorium
on Residential Evictions During the COVID-19 Pandemic
January 26, 2021
Urgency Ordinance No. 21-1425U, Clarifying and Extending the
Temporary Commercial and Residential Moratorium on Evictions During
the COVID-19 Pandemic
February 9, 2021
Urgency Ordinance No. 21-1426U, Extending Portions of and Clarifying
the Temporary Moratorium on Residential Evictions to Comport with
Recent Changes in State Law
March 23, 2021
Urgency Ordinance No. 1428U, Extending the Temporary Moratorium on
Commercial Evictions During the COVID-19 Pandemic, Extending
Commercial Tenant Protections from Premature Eviction Based on
Landlord Intent to Demolish or Substantially Remodel
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Meeting Date Description
March 16, 2020
Resolution No. 20-7230 Confirming the Proclamation of a Local
Emergency and Initiating Commercial and Residential Eviction
Moratoriums
March 24, 2020
Urgency Ordinance No. 20-1406U, Temporary Moratorium on Evictions
for Nonpayment of Rent by Residential Tenants and Commercial Tenants,
and Temporary Suspension on Residential and Commercial
Foreclosures
April 14, 2020
Urgency Ordinance No. 20-1407U, To Amend the Temporary Moratorium
on Foreclosures and Evictions Due to Non-Payment of Rent by
Residential and Commercial Tenants Impacted by COID-19. Amended
the Eviction Moratorium in 20-1406U in its entirety in light of Governor
Newsom’s Financial Relief Package announced on March 25, 2020.
May 26, 2020 Urgency Ordinance No. 20-1409U, Extending the Temporary Moratorium
on Evictions
July 28, 2020 Urgency Ordinance No. 2020-1414U, Extending the Temporary
Moratorium on Evictions During the COVID-19 Pandemic
September 22, 2020 Urgency Ordinance No. 20-1417U, Clarifying the Temporary Moratorium
on Evictions During the COVID-19 Pandemic
November 24, 2020 Urgency Ordinance No. 20-1420U, Temporary Moratorium on
Commercial Evictions During the COVID-19 Pandemic
December 8, 2020 Urgency Ordinance No. 20-1422U, Amending the Temporary Moratorium
on Residential Evictions During the COVID-19 Pandemic
January 26, 2021
Urgency Ordinance No. 21-1425U, Clarifying and Extending the
Temporary Commercial and Residential Moratorium on Evictions During
the COVID-19 Pandemic
February 9, 2021
Urgency Ordinance No. 21-1426U, Extending Portions of and Clarifying
the Temporary Moratorium on Residential Evictions to Comport with
Recent Changes in State Law
March 23, 2021
Urgency Ordinance No. 1428U, Extending the Temporary Moratorium on
Commercial Evictions During the COVID-19 Pandemic, Extending
Commercial Tenant Protections from Premature Eviction Based on
Landlord Intent to Demolish or Substantially Remodel
Policy Setting
CA COVID-19 Rent Relief - Residential Tenants Only
When the Legislature extended the state residential eviction moratorium early this year,it established
the CA COVID-19 Rental Relief program.Under this program,a landlord who rents to a lower income
tenant (80 percent AMI or below)may apply to receive 80 percent of rental debt incurred by that
tenant from April 2020 through March 2021 if the remaining 20 percent is forgiven.Tenants may also
apply if the landlord declines to participate,but can only receive 25 percent.For assistance with rentCity of Hermosa Beach Printed on 6/3/2021Page 4 of 5
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REPORT 21-0350
apply if the landlord declines to participate,but can only receive 25 percent.For assistance with rent
due in April 2021 and after,lower income tenants can receive 25 percent of their monthly rent.
Governor Newsom is now considering covering 100 percent of rental debt and simplifying the
application process to remedy the slow disbursement of funds.
There is no specified end date to this program.Funds administrated through the program come from
the $2.6 billion in federal assistance the state received.The state is expected to receive an
additional $2.2 billion from the American Rescue Plan.Therefore,the program should presumably
continue until these funds are depleted.
AB 255 COVID-19 Emergency Small Business Eviction Relief Act
Small businesses may be seeing some help from the state soon as well.There is pending legislation,
Senate Bill 255,that would apply to commercial tenants that employ 50 or less employees,operate
an independently owned and operated business or nonprofit organization,and had an average
annual gross revenue no greater than $2,500,000 between January 1,2018 and January 1,2021.
This bill would require landlords to conduct a good faith negotiation to form a plan to allow these
commercial tenants a reasonable opportunity to repay COVID-19 lease debt if the tenants suffered a
decrease of at least 50 percent in average monthly gross revenue during the COVID-19 pandemic.
Failure of landlords to comply would be an affirmative defense to eviction.
Reopening California on June 15, 2021
On June 15,California will fully open its economy if vaccine supply remains sufficient,and if
hospitalization rates are stable and low.The Los Angeles County Department of Public Health has
confirmed that the Health Officer Orders restricting capacity and activity for businesses will also be
lifted on June 15,following the State’s guidance.Commercial tenants will be able to operate at full
capacity with no restrictions on their operations.
Fiscal Impact:
There is no fiscal impact to the City associated with the recommended action.
Attachments:
1. Table of Covid-19 Related Items
Respectfully Submitted by: Michael Jenkins, City Attorney
Legal Review: Monica Castillo, Assistant City Attorney
Approved: Suja Lowenthal, City Manager
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DATE ORDINANCE/RESOLUTION EXPIRATION DATE
March 16,
2020
Resolution No. 20-7230 Confirming the Proclamation of a Local Emergency.
Pursuant to Section 5: Pursuant to the authority prescribed by Hermosa Beach Municipal Code Section
2.56.090, the City Council hereby orders as follows (the “Order”), to take effect immediately and
remain in effect until March 28, 2020, unless extended by the City Council or City Manager:
A. All restaurants, alcohol beverage establishments and snack shops in the City are hereby
ordered closed to onsite patronage; provided, however, that take-out orders and delivery of meals are
permitted provided that take-out orders are picked up by a single person and the establishment
maintains social distance in any necessary queuing of patrons.
B. All formal and informal organized and group activities, games and sports, with the
exception of family outings, are hereby prohibited in all City parks and the beach;
C. The City shall prohibit access to play structures at all City parks;
D. The City shall post signs at all City parks advising that:
i. COVID-19 is known to survive on various surfaces such as children’s play
equipment, bathroom surfaces, tables, benches, railings, and other fixtures, for 72 or
more hours; and
ii. Park users shall maintain social distance as prescribed by Beach Cities Health
District, as provided in Exhibit 1 attached hereto;
iii. Park users with symptoms consistent with COVID-19 infection are encouraged to
isolate themselves at home and contact their health care provider or, if they do not
have a health care provider, the Los Angeles County Department of Health to assist
with receiving prompt diagnosis and care.
Pursuant to Section 6:
A. Commercial landlords in the City are hereby prohibited from (I) charging rent and (II)
evicting commercial tenants for nonpayment of rent with respect to tenants whose businesses are
subject to the Order or are otherwise limited or closed (voluntarily or by mandate) to prevent or reduce
the spread of COVID-19 and who demonstrate lost income and inability to pay rent as a result of such
limitation or closure. A landlord knows of a tenant’s lost income and inability to pay rent within the
meaning of this Order if the tenant, within 30 days after the date rent is due, notifies the landlord in
Section 5 requirements: until March
28, 2020, unless extended by the
City Council or City Manager.
No expiration date set for Section 6
Measures.
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writing of the lost income and inability to pay rent due to a limitation or closure of the tenant’s business
related to COVID-19, with appropriate supporting documentation. If a tenant suffers only a partial loss
of income, the tenant shall pay the pro-rated share of their rent that corresponds to the income they
generated during the period of loss.
B. Residential landlords in the City are hereby prohibited from (I) charging rent and (II)
evicting residential tenants for nonpayment of rent with respect to tenants whose income is reduced or
eliminated as a result of efforts to prevent or reduce the spread of COVID -19 and who demonstrate lost
income and inability to pay rent as a result of such loss. A landlord knows of a tenant’s lost income and
inability to pay rent within the meaning of this Order if the tenant, within 30 days after the date rent is
due, notifies the landlord in writing of the lost income and inability to pay rent due to such loss, with
appropriate supporting documentation. If a tenant suffers only a partial loss of income, the tenant shall
pay the pro-rated share of their rent that corresponds to the income they generated during the period of
loss.
March 24,
2020
Urgency Ordinance No. 20-1406U, Temporary Moratorium on Evictions for Nonpayment of Rent by
Residential Tenants and Commercial Tenants, and Temporary Suspension on Residential and
Commercial Foreclosures
This Moratorium replaced the eviction moratorium in Resolution No. 20-7230
May 31, 2020
April 14, 2020 Urgency Ordinance No. 20-1407U, To Amend the Temporary Moratorium on Foreclosures and
Evictions Due to Non-Payment of Rent by Residential and Commercial Tenants Impacted by COID-19.
Amended the Eviction Moratorium in 20-1406U in its entirety in light of Governor Newsom’s
Financial Relief Package announced on March 25, 2020.
May 31, 2020
April 22, 2020 City Manager/Director of Emergency Services Executive Order No. 2020-01
Pursuant to Section 2:
1. Cancellation of non-essential large public events, senior and community programs, and
limitations on public access to some City facilities (effective March 12, 2020).
2. Cancellation of P.A.R.K. After School Program (effective March 13, 2020).
3. Closure of City Hall (effective March 16, 2020).
Shall continue until the earlier to
occur of: (1) the conclusion of the
local emergency; (2) its termination
is ordered by the City
Manager/Director of Emergency
Services; or (3) it is duly terminated
by the City Council. The Order may
also be superseded by a duly enacted
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4. Cancellation of Wednesday Farmers Market (effective March 18, 2020) and Friday
Farmers Market (effective March 20, 2020).
5. Business License renewal dates extended to May 31, 2020 (effective March 25, 2020).
6. Parking Permit renewal dates extended to May 31, 2020 (effective March 25, 2020).
7. Parking citation unbilled late fees delayed until May 31, 2020 (effective March 25,
2020).
8. Parking citation DMV holds delayed until May 31, 2020 (effective March 25, 2020).
9. Temporary banner permit requirements waived through May 31, 2020 (effective March
25, 2020).
10. Closure of beach and Strand (effective March 27, 2020).
11. Closure of City parks on Easter Sunday (effective April 9, 2020).
*This order was confirmed at the April 28th meeting.
ordinance or order of the City
Council expressly superseding this
Order.
April 27, 2020 City Manager/Director of Emergency Services Executive Order No. 2020-02
Pursuant to section 2:
1. The ten cents ($0.10) per recycled paper carryout bag charged to customers by affected retail
establishments provided by Hermosa Beach Municipal Code Section 8.68.040 is hereby suspended.
2. All restaurants, snack shops and similar businesses that serve food (and, optionally, groceries)
and alcohol via delivery, pick-up or drive-thru shall not provide any alcohol to a customer prior to
providing the entire food/meal order; i.e. all alcohol shall be provided to the customer concurrently with
the delivery of food. All such establishments shall monitor customers waiting for food to ensure that
no one is consuming alcohol on or adjacent to the premises.
*This Order was confirmed at the May 12th meeting.
Shall continue until the earlier to
occur of: (1) the conclusion of the
local emergency; (2) its termination
is ordered by the City
Manager/Director of Emergency
Services; or (3) it is duly terminated
by the City Council. The Order may
also be superseded by a duly enacted
ordinance or order of the City
Council expressly superseding this
Order.
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May 14, 2020 City Manager/Director of Emergency Services Executive Order No. 2020-03
Pursuant to Section 2:
Consistent with the provisions of the County Health Officer’s May 13, 2020 Revised Order, the beach
will be open from 6:00 a.m. to 9:00 p.m. subject to the following:
1. Only the following limited activities are allowed:
i. Individual or household ocean activities such as surfing, swimming, kayaking,
paddle boarding, and body surfing.
ii. Individual or household active recreation and exercise such as walking and running
where the participants do not remain in a stationary location.
2. The following activities are prohibited:
i. Sunbathing, sitting, lying on the sand and other stationary activities (such as yoga,
calisthenics, or meditation).
ii. Picnicking.
iii. Use of chairs, canopies or coolers.
iv. Biking.
v. Group or organized sports such as volleyball
vi. Gatherings or events.
vii. Fishing.
3. Individuals/households must exit the beach immediately after they recreate.
4. All beachgoers must follow the following safety requirements:
i. Maintain more than 6 feet physical distance from others at all times (except between
members of same household).
ii. Wear face coverings, when out of the water and around others (except for children
under age 2 and children with breathing problems).
5. All City parks and the beach are closed daily from 9:00 p.m. to 6:00 a.m.
6. The Strand and Pier remain closed.
7. City parking facilities are subject to the following regulations, subject to further modification
by the City Manager/Director of Emergency Services as may be required to maintain public
safety and order and to enforce the City’s emergency orders:
Shall continue until the earlier to
occur of: (1) the conclusion of the
local emergency; (2) its termination
is ordered by the City
Manager/Director of Emergency
Services; or (3) it is duly terminated
by the City Council. The Order may
also be superseded by a duly enacted
ordinance or order of the City
Council expressly superseding this
Order.
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i. All, or parts of, Lot A, Lot B, Lot C, and Lot D will be closed.
ii. Temporary short-term parking spaces will be established in Lot A and Lot D.
iii. Monthly permit parking spaces will be provided in Lot D.
iv. Temporary parking spaces will be designated at various locations on City streets.
8. Consistent with the provisions of the County Health Officer’s May 13, 2020 Revised Order,
all Lower Risk retail Businesses that sell goods and services to the public may only provide
these goods and services to the public via curbside, doorside, or other outdoor or outside
pickup, or via delivery. Members of the public are not permitted inside a retail Low-Risk
Retail Business. Lower Risk Businesses may set up a table or shade structure in a manner to
accommodate pickup, provided that patrons practice social distancing as provided in the May
13, 2020 Revised Order and provided that minimum 5-foot clearance is maintained along
public walkways. Outdoor display of merchandise is prohibited.
9. In addition to enforcement remedies available to the City as provided in the Hermosa Beach
Municipal Code, emergency executive orders issued by the City Manager/Director of
Emergency Services and emergency resolutions adopted by the City Council shall be
enforceable by way of:
i. Imposing an administrative citation pursuant to HBMC Chapter 1.10.
ii. Prosecuting a misdemeanor, punishable by a fine of not to exceed one thousand
($1,000) dollars or by imprisonment for not to exceed six months, or both.
*This Order was confirmed during the May 26th meeting as amended by Resolution 7236.
May 21, 2020 City Manager/Director of Emergency Services Executive Order No. 2020-04
Pursuant to Section 3. The City Manager and Director of Emergency Services now seeks to extend the
duration of the emergency orders listed in Section 5 of Resolution No. 20-7230, as revised and restated
below. The following emergency orders are issued effective as of the date set forth below and shall
supersede any previous emergency orders inconsistent herewith:
A. All restaurants, alcohol beverage establishments and snack shops in the City are hereby
ordered closed to onsite patronage; provided, however, that (i) take-out orders and delivery of meals are
permitted, provided that take-out orders are picked up by way of a drive-through window or by a single
person and the establishment maintains social distance in any necessary queuing of patrons, and (ii)
outdoor dining will be permitted upon issuance of and as provided in Executive Order 2020-05.
B. All gyms and fitness centers are hereby ordered closed in accordance with the March 16,
2020 Order of the Health Officer of the Los Angeles County Department of Public Health.
The Order may be superseded by a
duly enacted ordinance or order of
the City Council expressly
superseding this Order.
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C. All formal and informal organized and group activities of any size, including but not
limited to all games and sports, with the exception of family outings and use of the City’s tennis and
pickleball courts in accordance with City regulations, are hereby prohibited in all City parks, the beach,
Pier Plaza and other public spaces.
D. Access to play structures and exercise equipment in all City parks, the beach, and the
Greenbelt is hereby prohibited.
E. The City shall post signs at all City parks, the Greenbelt, the beach, Pier Plaza and the
Strand advising that:
I. COVID-19 is known to survive on various surfaces such as children’s play equipment,
bathroom surfaces, tables, benches, railings and other fixtures, for 72 or more hours;
II. Users of public spaces shall maintain social distance as prescribed by Beach Cities
Health District, as provided in Exhibit 1 attached hereto; and
III. Users of public spaces with symptoms consistent with COVID -19 infection are
encouraged to isolate themselves at home and contact their health care provider, or if
they do not have a health care provider, the Los Angeles County Department of Health
to assist with receiving prompt diagnosis and care.
Pursuant to Section 4:
In addition to the emergency orders listed in Section 3 above, the City Manager and Director of
Emergency Services further orders that:
A. The enforcement of City street sweeping restrictions suspended on March 16, 2020, as a
part of the City’s effort to combat COVID-19, shall resume on June 8, 2020.
*This Order was confirmed at the May 26th meeting.
May 21, 2020 Resolution No. 7236, Rescinding Portions of Executive Order Nos. 2020-01 and 2020-03 to reopen the
Strand:
Pursuant to Section 2:The Strand is re-open for public use effective 6:00 a.m. on Saturday, May 23,
2020; Section 2, paragraph 10 of Executive Order No. 2020-01 and Section 2, paragraph 3 of Executive
Order No. 2020-03 are hereby rescinded.
No expiration date stated.
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May 26, 2020 Urgency Ordinance No. 20-1409U, Extending the Temporary Moratorium on Evictions
Pursuant to Section 2:
Ordinance No. 20-1407U will remain in effect until July 31, 2020. All other provisions of Ordinance
No. 20-1407U remain the same.
Eviction Moratorium Period
extended to July 31, 2020.
May 26, 2020 Executive Order No. 2020-05, Implementing a Temporary Permit for Outdoor Dining/Seating and
Outdoor Retail Display to Assist in the Reopening of Restaurants, and Food and Retail Establishments.
Pursuant to Section 2:
A. Established a temporary permit program for outdoor dining/seating.
B. Established a temporary permit program to permit City businesses to display
merchandise on the street.
C. Provisions of HBMC §§ 17.26.050(B), (C),and 17.44.030 regarding off-street parking
requirements for commercial and business uses are temporarily suspended to allow for the
implementation of the above.
*This Order was confirmed at the June 9th meeting.
Shall continue until the earlier to
occur of: (1) the conclusion of the
local emergency; (2) its termination
is ordered by the City
Manager/Director of Emergency
Services; or (3) it is duly terminated
by the City Council. The Order may
also be superseded by a duly enacted
ordinance or order of the City
Council expressly superseding this
Order.
June 9, 2020 Urgency Ordinance No. 1410U, Implementing a Temporary Permit for Outdoor Dining/Seating and
Outdoor Retail Display to Assist in the Reopening of Restaurants, Food, and Retail:
Section 2 reiterates subsection (A) and (C) in Executive Order No. 2020-05 above, and suspends these
additional HBMC §§ 17.38.550(B), 12.16.090 and 12.16.100.
No expiration date stated.
June 15, 2020 City Manager/Director of Emergency Services Order No. 2020-06
Pursuant to Section 2. The following emergency order shall supersede Section 2, paragraphs 1 and 2
(only as applied to the beach) of Executive Order No. 2020-03:
The beach will be open from 6:00 a.m. to 12:00 a.m. subject to the following:
a. The following activities are allowed:
Shall continue until the earlier to
occur of: (1) the conclusion of the
local emergency; (2) its termination is
ordered by the City Manager/Director
of Emergency Services; or (3) it is
duly terminated by the City Council.
The Order may also be superseded by
a duly enacted ordinance or order of
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i. Individual or household ocean activities such as surfing, swimming, kayaking,
paddle boarding, and body surfing.
ii. Individual or household active recreation and exercise such as walking and
running.
iii. Sitting, lying, picnicking or otherwise congregating or engaging in stationary
activities (such as yoga, calisthenics, or meditation on the sand individually or
with members of the same household.
iv. Use of chairs, canopies or coolers.
b. The following activities are prohibited:
v. Group or organized sports such as volleyball.
vi. Gatherings or events.
c. All beachgoers must follow the following safety requirements:
i. Maintain more than 6 feet physical distance from others at all times (except
between members of same household)
ii. Wear face coverings, when out of the water and in contact with others who do
not belong to the same household (except for children under age 2 and children
with breathing problems).
Pursuant to Section 3. The following emergency order shall supersede Section 2, paragraph 3 of
Executive Order No. 2020-03:
The City Pier will re-open on June 15, 2020 for normal operational hours of 6:00 AM to 10:00
PM. Pier users must maintain physical distance, avoid gatherings and wear a face covering
when physical distance cannot be maintained.
Pursuant to Section 4. The following emergency order shall supersede Section 2, paragraph 5 of
Executive Order No. 2020-03 and Section 3, paragraph A of Executive Order No. 2020-04:
A. Lower risk retail businesses may open for business in accordance with Appendix B of
the June 11 Revised Order.
B. Non-retail lower risk manufacturing and logistics sector business that supply low-risk
retail business may open for business in accordance with Appendix C of the June 11 Revised Order.
the City Council expressly
superseding this Order.
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C. Non-essential office-based businesses may open for business in accordance with
Appendix D of the June 11 Revised Order.
D. Hair salons and barbershops may open for business in accordance with Appendix H of
the June 11 Revised Order.
E. Art galleries and museums may open for business in accordance with Appendix M of
the June 11 Revised Order.
Pursuant to Section 5. Section 3, Paragraph B of Executive Order No. 2020-04 pertaining to gyms and
fitness centers is rescinded and those businesses may re-open in compliance with Gym and Fitness
Establishments Protocols (Appendix L) of the June 11 Revised Order.
Pursuant to Section 6. Notwithstanding the provisions of Section 3, paragraph C of Executive Order
No. 2020-04 to the contrary:
A. Day Camps and Camp Permits. City run and City-permitted day camps are permitted to
resume operations. Camp operators must comply with the Los Angeles County Health Department Day
Camp Protocol (Appendix K) and submit the completed protocol checklist to the City prior to issuance
of a permit.
B. Outdoor Fitness Permits. Outdoor fitness instruction will be permitted to resume only
for activities that are specifically allowed within the June 11 Revised Order. Operators must comply
with the Los Angeles County Public Health Department Gym and Fitness Protocol (Appendix L) and
submit the completed protocol checklist to the City prior to issuance of a permit.
Pursuant to Section 7. Notwithstanding the provisions of Section 2, paragraph 4 of Executive Order No.
2020-03 to the contrary:
A. Parking Lot A is reopened for use for non-permit holders with a new time limit of 3
hours per day, and for use by monthly permit holders.
B. Parking Lot B is reopened for use for non-permit holders.
C. Parking Lot D temporary restrictions are removed.
*This Order was confirmed at the June 23rd meeting.
June 24, 2020 City Manager/Director of Emergency Services Executive Order No. 2020-07 Shall continue until the earlier to
occur of: (1) the conclusion of the
local emergency; (2) its termination is
ordered by the City Manager/Director
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Pursuant to Section 2. The following emergency order shall supersede Section 3, paragraph A of
Executive Order No. 2020-04:
Bars, wineries and brewery tasting rooms may open for business in accordance with Appendix
S of the County Health Officer’s June 18, 2020 Revised Order.
of Emergency Services; or (3) it is
duly terminated by the City Council.
The Order may also be superseded by
a duly enacted ordinance or order of
the City Council expressly
superseding this Order.
June 29, 2020 City Manager/Director of Emergency Services Executive Order No. 2020-08.
Pursuant to Section 2:
Bars, wineries, breweries and wine tasting rooms are closed in accordance with paragraph
7, subsections (b) and (c) of the Revised Order (Revised Order refers to LA County Health
June 29, 2020 Health Order)
Pursuant to Section 3:
Restaurants and food facilities must abide by paragraph 18, subsection (l) of the County
Health Officer’s Revised Order and Appendix I, to establish a “reservation only” system to
notify patrons of seating availability and to allow for the collection of contact information
to be utilized for contact-tracing if needed.
*This Order was confirmed at the July 1st meeting.
Shall continue until the earlier to
occur of: (1) the conclusion of the
local emergency; (2) its termination is
ordered by the City Manager/Director
of Emergency Services; or (3) it is
duly terminated by the City Council.
The Order may also be superseded by
a duly enacted ordinance or order of
the City Council expressly
superseding this Order.
July 1, 2020 Resolution No. 20-7249, Temporarily Suspending for the Duration of the Fourth of July Holiday
Weekend Specified City Manager Orders and City Council Resolutions
Pursuant to Section 2:
A. Notwithstanding Section 2(4) of Executive Order No. 2020-03, the following City
parking facilities are closed from12:01 a.m. July 3, 2020 through 5:00 a.m. on the
morning of July 6, 2020:
a. Parking Lot A; and
b. Parking Lot B spaces will be reassigned for use by monthly permit holders
only.
B. Notwithstanding Executive Order No. 2020-05 and any ordinance or permit
entitlement to the contrary, all dine-in restaurants in the City shall close for
These are temporary measures and
shall expire on the BOLD dates to the
left.
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business at 11:00 p.m. each evening until 5:00 a.m. the following morn ing from
July 3, 2020 to and including July 5, 2020.
C. Notwithstanding any ordinance or permit entitlement to the contrary, all off-sale
alcohol establishments, including but not limited to liquor stores and grocery
stores, shall cease all sales of alcoholi c beverages at 11:00 p.m. each evening until
6:00 a.m. the following morning from July 3, 2020 to and including July 5, 2020.
D. Lower Pier Plaza is closed from 12:01 a.m. through 5:00 a.m. the same morning from
July 4, 2020 to and including July 6, 2020.
July 17, 2020 City Manager/Director of Emergency Services Executive Order No. 2020-09, Implementing
Emergency Measures to Temporarily Permit Gyms, Fitness Facilities, Hair Salons and Barbershops to
Operate Outdoors During the COVID-19 Crisis.
Pursuant to Section 2:
Hermosa Beach Municipal Code sections 17.26.050(B), 17.44.030 and 17.38.550 are
temporarily suspending during the term of City State and LA County COVID-19
emergency orders to temporarily permit gyms, fitness facilities, hair salons and barbershops to
operate outdoors.
*This Order was confirmed at the July 28th meeting.
Shall continue until the earlier to
occur of: (1) the conclusion of the
local emergency; (2) its termination is
ordered by the City Manager/Director
of Emergency Services; or (3) it is
duly terminated by the City Council.
The Order may also be superseded by
a duly enacted ordinance or order of
the City Council expressly
superseding this Order.
July 28, 2020
Urgency Ordinance No. 20-1415U, Temporarily Suspending Local Zoning to Permit Specified
Businesses to Operate Outdoors, Permit Certain Home occupations to Operate without a Commercial
Business Location and Require Members of the Public to wear a Face Covering.
Pursuant to Section 2. Hermosa Beach Municipal Code Sections 17.26.050 (B), 17.44.030,
17.38.550(B) and 17.08.020(D)(14) regarding uses permitted within commercial zones, off-street
parking requirements for commercial and business uses within commercial zones, and home occupation
permits are temporarily suspended to allow for the implementation of items A and B below on a
temporary basis during the term of the City, State and Los Angeles County COVID-19 emergency
orders:
A. Gyms, fitness centers, hair salons, barbershops and personal care establishments (to the
extent permitted by the State Board of Barbering and Cosmetology) may operate outdoors to assist in
their economic recovery in accordance with the “Outdoor Commercial Uses Operational Standards”
attached hereto as Exhibit A and incorporated herein by reference.
The measures adopted in Section 2,
are temporary and shall continue
during the term of the City, State and
Los Angeles County COVID-19
emergency orders
No specific expiration date set for
Section 3.
No specific expiration date set for
Section 4.
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B. Consistent with the Los Angeles County Health Officer Reopening Protocol for
Personal Care Establishment in Appendix R, “personal care services” shall include: nail salons,
tanning salons, esthetician, skin care, cosmetology services and massage therapy (in a non-healthcare
setting). Electrology, tattooing, microblading, permanent make-up and piercing may not operate
outdoors because they are invasive procedures that require a controlled hygienic environment to be
performed safely. Mobile or in-home personal care services are not allowed.
C. Professional offices, including but not limited to the healing arts, law, accounting, real
estate, clergy, insurance and similar professional or semiprofessional offices may render their services
from their residence with a home occupation permit regardless if they c omply with Municipal Code
section 17.08.020(D)(14), to allow them to continue to operate and pursue their livelihoods while
complying with California and Los Angeles County Health orders in response to COVID-19.
Pursuant to Section 3. The following emergency measures are adopted:
A. All persons shall wear a face covering over both the nose and mouth whenever they are
present in the following locations within the City:
a. The Beach.
b. Downtown Hermosa Beach, defined as (i) the area bounded by the southerly
edge of the 10th Street right-of-way on the south, the northerly edge of the
14th Street right-of-way on the north, the easterly edge of the Strand on the
west and the easterly edge of the Hermosa Avenue right-of-way on the east,
and (ii) Upper Pier Avenue (inclusive of sidewalks) from Hermosa Avenue to
Valley Drive.
c. The Greenbelt.
d. All City parks.
e. Pier Plaza.
f. The Strand.
B. All persons shall wear a face covering over both the nose and mouth whenever they leave
their place of residence and are or can be in contact with or walking near or past others who are non-
household members in both public and private places whether indoors or outdoors, in all locations in the
City other than those locations described in and subject to the proscription set forth in paragraph A o f
this Section 3.
C. Paragraphs A and B of this Section 3 shall not apply to:
a. Persons younger than two years old;
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b. Persons who have been instructed by a medical provider not to wear a face covering
due to a medical condition, mental health condition, or disability that prevents
wearing a face covering;
c. Persons who are hearing impaired, or communicating with a person who is hearing
impaired, where the ability to see the mouth is essential for communication;
d. Persons who are swimming or engaged in other water-based activities; and
e. Healthcare workers, first responders, and others whose work requires close contact
with people who are ill.
D. For purposes of this Ordinance, “face covering” shall mean: fabric coverings, such as
cloth masks, scarves, bandanas, tightly woven fabric such as cotton t-shirt, and some types of towels
that cover the nose and mouth. Medical-grade masks and N-95 respirators are not required.
E. Persons who are seated at a restaurant or other establishment that offers food or
beverage service shall wear a cloth face covering over both the nose and mouth unless they are eating
or drinking.
F. With respect to persons on the beach, this Ordinance supersedes Section 2(c)(ii) of City
Manager Executive Order No. 2020-06.
G. The provisions of this Section 3 shall be enforced by way of issuance of administrative
citations pursuant to HBMC Chapter 1.10.
Pursuant to Section 4. In addition to enforcement remedies available to the City as provided in the
Hermosa Beach Municipal Code, emergency executive orders issued by the City Manager/Director of
Emergency Services and confirmed by City Council, and emergency ordinances, orders and resolutions
adopted by the City Council shall be enforceable by way of:
A. Imposing an administrative citation pursuant to HBMC Chapter 1.10.
B. Prosecuting a misdemeanor, punishable by a fine of not to exceed one thousand
($1,000) dollars or by imprisonment for not to exceed six months, or both.
July 28, 2020. Urgency Ordinance No. 2020-1414U, Extending the Temporary Moratorium on Evictions During the
COVID-19 Pandemic
Pursuant to Section 2.
Moratorium period for both
commercial and residential tenants is
March 16 through September 30,
2020
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A. During the moratorium period declared in response to COVID-19, no landlord shall
endeavor to evict a tenant for nonpayment of rent if the tenant demonstrates that the tenant is unable to
pay rent due to financial impacts related to COVID-19. The moratorium period is March 16, 2020
through September 30, 2020.
B. Nothing in this ordinance shall relieve the tenant of liability for the unpaid rent, which
the landlord may seek after expiration of the moratorium period and the tenant must repay within six
months of the expiration of the moratorium period. A landlord may not charge or collect a late fee or
interest for rent that is delayed for the reasons stated in this ordinance; nor may a landlord seek rent that
is delayed for the reasons stated in this ordinance through the eviction process. A landlord shall not
commence an eviction during the six months after the end of the moratorium period so long as the
tenant pays rent in a timely manner after the moratorium period and is repaying the past due rent that
accrued during the moratorium period. Nonpayment of rent in accordance with the terms of this
ordinance shall not be grounds for eviction of a tenant even after expiration of the moratorium period.
Pursuant to Section 3.
A. During the moratorium period declared in response to COVID-19, no commercial
landlord shall endeavor to evict a tenant for nonpayment of rent if the tenant demonstrates that the
tenant’s businesses is subject to the Orders referenced in Section 1 of this Ordinance or is otherwise
limited or closed (voluntarily or by mandate) to prevent or reduce the spread of COVID-19 and the
tenant demonstrates lost income and inability to pay rent as a result of such limitation or closure or
other demonstrated financial impact related to COVID-19. The moratorium period is March 16, 2020
through September 30, 2020.
B. Nothing in this ordinance shall relieve the tenant of liability for the unpaid rent, which
the landlord may seek after the expiration of the moratorium period and the tenant must pay within six
months of the expiration of the moratorium period. A landlord may not charge or collect a late fee or
interest for rent that is delayed for the reasons stated in this ordinance; nor may a landlord seek rent that
is delayed for the reasons stated in this ordinance, through the eviction process during or after the
moratorium period. A landlord shall not commence an eviction during the six months after the end of
the moratorium period for non-payment of rent, so long as the tenant pays rent in a timely manner after
the moratorium period and is repaying the past due rent that accrued during the moratorium period.
Nonpayment of rent in accordance with the terms of this ordinance shall not be grounds for eviction of
a tenant even after expiration of the moratorium period.
Pursuant to Section 4.
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A. For mortgagors that are not eligible for financial relief under Governor Newsom’s
Financial Relief Package, no foreclosure action against a property owner shall be initiated or proceed
during the moratorium period in the City for any mortgagor with a demonstrated financial impact
related to COVID-19. Nothing in this ordinance shall relieve the mortgagor of liability for any unpaid
mortgage payments, which the mortgagee may seek after expiration of the moratorium period and the
mortgagor must pay within six months of the expiration of the moratorium period unless a different
time is agreed to between the parties. A mortgagee may not charge or collect a late fee or penalty for
payments that are delayed for the reasons stated in this ordinance. The moratorium period is March 16,
2020 through September 30, 2020.
August 13,
2020 City Manager\Director of Emergency Services Executive Order No. 2020-10, Implementing
Emergency Measures to Temporarily Permit Places of Worship to Operate outdoor During the COVID -
19 Pandemic.
Pursuant to section 2. The provisions of Hermosa Beach Municipal Code Sections 17.26.050 (B),
17.44.030, 17.38.550(B) and 17.40.020 regarding uses permitted within commercial zones, off-street
parking requirements and uses for which a conditional use permit is required are hereby temporarily
suspended, to the extent they conflict with this Order, to allow for the implementation of item A below
on a temporary basis during the term of the City, State and Los Angeles County COVID-19 emergency
orders:
A. Places of worship and providers of religious services and cultural ceremonies (referred
to collectively as “Places of Worship”), may operate outdoors in accordance with Appendix F of the
County’s July 18th Order, as that protocol may be updated from time to time by the County Health
Officer.
*This Order was confirmed at the Aug. 25th meeting.
Shall continue until the earlier to
occur of: (1) the conclusion of the
local emergency; (2) its termination is
ordered by the City Manager/Director
of Emergency Services; or (3) it is
duly terminated by the City Council.
The Order may also be superseded by
a duly enacted ordinance or order of
the City Council expressly
superseding this Order.
August 25,
2020
Urgency Ordinance No. 1416U, to Temporarily Permit Places of Worship to Operate Outdoors During
the COVID-19 Pandemic.
Pursuant to section 2. The provisions of Hermosa Beach Municipal Code Sections 17.26.050 (B),
17.44.030, 17.38.550(B) and 17.40.020 regarding uses permitted within commercial zones, off-street
parking requirements and uses for which a conditional use permit is required are hereby temporarily
suspended, to the extent they conflict with this Ordinance, to allow for the implementation of item A
below on a temporary basis during the term of the City, State and Los Angeles County COVID-19
emergency orders:
On a temporary basis during the term
of the City, State and Los Angeles
County COVID-19 emergency
orders:
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A. Places of worship and providers of religious services and cultural ceremonies (referred
to collectively as “Places of Worship”), may operate outdoors in accordance with Appendix F of the
County’s Health Officer Order, as that protocol may be updated from time to time by the County Health
Officer.
August 25,
2020 City Manager Executive Order No. 2020-11, Implementing Temporary Lane Closures on Hermosa
Ave. to Facilitate Outdoor Recreation and Economic Recovery in Accordance with Health officer
Orders for Control of COVID-19.
1. Beginning August 20, 2020, the City in consultation with the City’s traffic consultant,
may temporarily close to vehicular traffic the northbound and southbound # 2 travel lanes (closest to
the curb) on Hermosa Avenue from the 800 block at 8th Street to the 1300 block at 14th street. Lane
closures will continue for 6 months following the complete implementation of the traffic control
measures approved by the City Council on Aug. 11, unless the closures are extended for a longer
period or sooner terminated by the City Council or Director of Emergency Services.
2. Beginning Aug. 20, 2020, the City in consultation with the City’s traffic consultant,
may temporarily close to vehicular traffic the right turn lanes from westbound Greenwich Village to
northbound Hermosa Ave. and the part of Hermosa Ave. immediately adjacent to 2626 Hermosa Ave.
The lanes may remain closed until Jan 13, 2021, unless the closures are extended for a longer
period or sooner terminated by the City Council.
3. The City shall post signs giving notice of these temporary measures.
4. Use of the closed lanes or parking spaces for any commercial purpose requires a
Temporary Permit for Outdoor Dining/Seating and Outdoor Retail Display, as set out in the recitals of
this Order.
*This Order was confirmed at the Aug. 25th meeting
The duration of each measure is
specified in BOLD to the left.
September 10,
2020 City Manager Executive Order No. 2020-12, Implementing Emergency Measures to Temporarily Defer
Payment of City Business Taxes During the COVID-19 Pandemic
Pursuant to Section 2: Hermosa Beach Municipal Code Sections 5.04.190, 5.04.200 and 5.04.240
regarding City business taxes are hereby temporarily suspended to the extent they conflict with this
Order, to allow for implementation of the following:
A. The business tax due and payable on and after March 31, 2020 shall be deferred and
interest and penalties waived for any business that ceased all business operations between March 16
and 31, 2020, has been entirely closed and remains closed as of the date of this Order due to the
Shall continue until the earlier to
occur of: (1) the conclusion of the
local emergency; (2) its termination is
ordered by the City Manager/Director
of Emergency Services; or (3) it is
duly terminated by the City Council.
The Order may also be superseded by
a duly enacted ordinance or order of
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COVID-19 pandemic.
B. Business taxes deferred pursuant to paragraph A above are deferred until the business
resumes operation, at which time the tax due will be prorated until the business’ next tax payment
anniversary date.
C. In order to be eligible for the deferral provided for in paragraph A above, the business
owner must sign a statement under penalty of perjury that provides dates of closure supported by
documentation of the closure satisfactory to the City. If the foregoing statement is found to be untrue,
the past due business tax, including penalties and interest, shall become payable immediately.
D. A business that is eligible for the deferral provided for in paragraph A and that paid a
business tax on or after March 31, 2020 is entitled to and may apply to the City for a refund of the tax.
* This order was confirmed at the Sep. 22nd meeting
the City Council expressly
superseding this Order.
September 22,
2020 Urgency Ordinance No. 20-1417U, Clarifying the Temporary Moratorium on Evictions During the
COVID-19 Pandemic
Pursuant to Section 2.
A. During the moratorium period declared in response to COVID-19, no commercial
landlord shall endeavor to evict a tenant for nonpayment of rent if the tenant demonstrates that the tenant’s
businesses is subject to the Orders referenced in Section 1 of this ordinance or is otherwise limited or
closed (voluntarily or by mandate) to prevent or reduce the spread of COVID-19 and the tenant
demonstrates lost income and inability to pay rent as a result of such limitation or closure or other
demonstrated financial impact related to COVID-19. For purposes of this Section 2, the moratorium
period is March 16, 2020 through January 31, 2021.
B. A landlord knows of a tenant’s lost income and inability to pay rent within the meaning
of this Section 2 if the tenant, within 30 days after the date rent is due, notifies the landlord in writing of
the lost income and inability to pay rent due to a limitation or closure of the tenant’s business related to
COVID-19, and provides appropriate supporting documentation within 30 days of providing the notice.
If a tenant suffers only a partial loss of net income, the tenant shall pay the pro-rated share of their rent
that corresponds to the net income they generated during the period of loss.
C. Nothing in this Section 2 shall relieve the tenant of liability for the unpaid rent, which
the landlord may seek after expiration of the moratorium period, and which tenant must pay within six
months of the expiration of the moratorium period (i.e. no later than July 31, 2021). A landlord may not
For commercial tenants, the eviction
moratorium period for commercial
tenants is March 16, 2020 through
January 31, 2021.
For residential tenants, the
“repayment period” for deferred rent
that came or will come due between
March 1, 2020 through January 31,
2021 inclusive, is October 1, 2020
through March 31, 2021.
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charge or collect a late fee or interest for rent that is delayed for the reasons stated in this Section 2; nor
may a landlord seek rent that is delayed for the reasons stated in this Section 2, through the evictio n
process during or after the moratorium period. A landlord shall not commence an eviction during the six
months after the end of the moratorium period for non-payment of rent, so long as the tenant pays rent in
a timely manner after the moratorium period and is repaying the past due rent that accrued during the
moratorium period
Pursuant to Section 3.
A. With respect to residential evictions for non-payment of rent due to financial impacts
from COVID-19, the following applies:
1. The “repayment period” for deferred rent that came or will come due between March 1,
2020 through January 31, 2021 (defined under the Act as “COVID-19 rental debt”), inclusive, is
October 1, 2020 through March 31, 2021.
2. For the period of time of March 16, 2020 through September 30, 2020 (the “moratorium
period”), no residential landlord shall endeavor to evict a tenant for nonpayment of rent, if the tenant
demonstrates that the tenant is unable to pay rent due to financial impacts related to COVID-19, subject
to subparagraphs (a) and (b) of Section 3(A)(2) of this Ordinance. A landlord shall not commence an
eviction during the six months after the end of the moratorium period, so long as the tenant pays rent in
a timely manner after the moratorium period and is repaying the past due rent that accrued during the
moratorium period. A landlord may not charge or collect a late fee or interest for rent that is delayed for
the reasons stated in this Paragraph 2.
October 27,
2020
Resolution No. 20-7262, Implementing Emergency Measures to Prevent Customers Queuing for Outdoor
Dining at Sit-Down Restaurants
Pursuant to Section 2.
A. No dine-in restaurant shall permit the congregating or lining up of customers in any
public right-of-way. The congregating or lining up of customers outside a dine-in restaurant, in any
manner, on sidewalks or other public rights of way is prohibited.
B. Unless no table is available, a dine-in restaurant must immediately seat customers in its
outdoor dining area if the customer is dining on-site. In the event no table is available, the restaurant
staff shall ask the customer to wait in a vehicle or at a location away from the restaurant premises.
Shall remain in effect until repealed
or superseded.
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C. Dine-in restaurants shall implement a phone reservation or call-back system that
notifies customers via text, phone call, or other method once a table has become available. No
customer shall be permitted in the dining area until the customer has been notified by the restaurant that
he or she can be seated.
D. Restaurant staff shall be responsible for instructing dine-in customers not to form lines
or congregate in abutting public areas while waiting to be seated.
November 24,
2020
Urgency Ordinance No. 20-1420U, Temporary Moratorium on Commercial Evictions During the
COVID-19 Pandemic
Pursuant to Section 2: Section 2 of Ordinance No. 20-1417U (The Temporary Moratorium on Evictions
for Non-Payment of Rent by Commercial Tenants Impacted by the COVID -19 Crisis) is amended by
renumbering Subsection “E” as Subsection “F” and adding a new Subsection E to read as follows.
Subsection A, B, C and D of Section 2 remain unchanged.
E. During the moratorium period declared in response to COVID-19, no commercial landlord shall
terminate a tenancy to demolish or substantially remodel the commercial real property unless and until
the landlord secures all permits necessary to perform the work. For purposes of this Subsection,
“substantially remodel” means to make a modification of the property that requires a permit from the
City. This ordinance shall apply to tenancy termination notices, notices to quit and other eviction notices,
and the unlawful detainer actions based on such notices, served or filed on or before the effective date of
this ordinance; but, where the time to vacate the property has not passed.
F. No other legal remedies available to a commercial landlord are affected by this ordinance.
The eviction moratorium period for
commercial tenants is March 16,
2020 through January 31, 2021.
December 8,
2020
Urgency Ordinance No. 20-1422U, Amending the Temporary Moratorium on Residential Evictions
During the COVID-19 Pandemic
Pursuant to 2: Section 3 of Ordinance No. 20-1417U (The Temporary Moratorium on Evictions for Non-
Payment of Rent by Residential Tenants Impacted by the COVID-19 Crisis) is amended by adding
Paragraph 7 to Subsection A to read as follows. All other provisions of Subsection A remain unchanged.
7. Starting on the effective date of this ordinance through January 31, 2021, no residential landlord
shall terminate a tenancy to demolish or substantially remodel the residential real property unless and until
the landlord secures all permits necessary to perform the work. For purposes of this Section, “substantially
remodel” means to make a modification of the property that requires a permit from the City. This ordinance
shall apply to tenancy termination notices, notices to quit and other eviction notices, and the unlawful
The “repayment period” for deferred
rent that came or will come due for
residential tenants between March 1,
2020 through January 31, 2021
inclusive, is October 1, 2020
through March 31, 2021.
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detainer actions based on such notices, served or filed on or before the effective date of this ordinance;
but, where the time to vacate the property has not passed.
(a) To the extent applicable, landlords must provide relocation assistance and satisfy other
requirements in accordance with the Tenant Protection Act of 2019 (Cal. Civil Code § 1496.2) for a no -
fault just cause eviction.
(b) No other legal remedies available to landlords are affected by this Paragraph 7.
January 26,
2021 Urgency Ordinance No. 21-1425U, Clarifying and Extending the Temporary Commercial and
Residential Moratorium on Evictions During the COVID-19 Pandemic
Pursuant to Section 2: The Temporary Moratorium on Evictions for Non-Payment of Rent by
Commercial Tenants Impacted by the COVID-19 Crisis, as most recently amended in Urgency Ordinance
No. 20-142OU was amended to make the following changes:
A. During the moratorium period, no commercial landlord shall evict a tenant for nonpayment
of rent provided the tenant demonstrates that (1) the tenant’s businesses is subject to the Orders referenced
in Section 1 of this Ordinance or is otherwise limited or closed (voluntarily or by mand ate) to prevent or
reduce the spread of COVID-19, and (2) the tenant demonstrates lost income and inability to pay rent as
a result of such limitation or closure or other demonstrated financial impact related to COVID -19. The
moratorium period is March 16, 2020 through March 31, 2021.
D. Nothing in this Section 2 shall relieve the tenant of liability for the unpaid rent, which
the landlord may seek after expiration of the moratorium period, and which tenant must pay within six
months of the expiration of the moratorium period (i.e. no later than September 31, 2021). A landlord
may not charge or collect a late fee or interest for rent that is delayed for the reasons stated in this Section
2; nor may a landlord seek rent that is delayed for the reasons stated in this Section 2, through the eviction
process during or after the moratorium period. A landlord shall not commence an eviction during the six
months after the end of the moratorium period for non-payment of rent, so long as the tenant pays rent in
a timely manner after the moratorium period and is repaying the past due rent that accrued during the
moratorium period.
E. During the moratorium period, no commercial landlord shall terminate a tenancy to demolish
or substantially remodel the commercial real property unless and until the landlord secures all permits
necessary to perform the work.
The moratorium period for
commercial tenants is March 16,
2020 through March 31, 2021.
The “repayment period” for deferred
rent that came or will come due for
residential tenants between March 1,
2020 through January 31, 2021, or
any later date as may be determined
by applicable state law (defined under
the Act as “COVID-19 rental debt”),
inclusive, is October 1, 2020
through March 31, 2021.
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21
Pursuant to Section 3. The Temporary Moratorium on Evictions for Non-Payment of Rent by Residential
Tenants Impacted by the COVID-19 Crisis, as most recently amended in Urgency Ordinance No. 20-
1422U, was clarified to comport with state law restated to include the following (See link to ordinance
for all amendments made):
A. With respect to residential evictions for non-payment of rent due to financial impacts from
COVID-19, the following applies:
1. The “repayment period” for deferred rent that came or will come due between March 1, 2020
through January 31, 2021, or any later date as may be determined by applicable state law (defined under
the Act as “COVID-19 rental debt”), inclusive, is October 1, 2020 through March 31, 2021.
2. For the period of time of March 16, 2020 through September 30, 2020 (the “local
moratorium period”), no residential landlord shall endeavor to evict a tenant for nonpayment of rent, if
the tenant demonstrates that the tenant is unable to pay rent due to financial impacts related to COVID -
19, subject to subparagraphs (a) and (b) of Section 3 of this Ordinance.
3. For the period of time of October 1, 2020 through January 31, 2021, or any later date as
may be determined by applicable state law, tenants shall follow the preconditions for eviction protection
under the Act to receive eviction protection, which include providing a declaration of hardship to their
landlord within 15 days of receipt of an eviction notice and payment of partial rent (25% of all rent that
came due from October 1, 2020 through January 31, 2021, or any later date as may be determined by
applicable state law). Tenants shall repay the remaining rent due by the end of the repayment period.
4. Tenants may draw down on a security deposit at any time to pay back rent and such security
deposit shall be replenished by the end of the repayment period on March 31, 2021 upon mutual
agreement of the parties
5. For the period of December 8, 2020 through March 31, 2021, no residential landlord shall
terminate a tenancy to demolish or substantially remodel the residential real property unless and until the
landlord secures all permits necessary to perform the work.
February 9,
2021 Urgency Ordinance No. 21-1426U, Extending Portions of and Clarifying the Temporary Moratorium on
Residential Evictions to Comport with Recent Changes in State Law
For residential tenants, the repayment
period for deferred rent that came or
will come due between March 1,
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Pursuant to Section 2. The Temporary Moratorium on Evictions for Non-Payment of Rent by Residential
Tenants Impacted by the COVID-19 Crisis, as most recently amended in Urgency Ordinance No. 21-
1425U is clarified as needed to comport with state law, to include the following (See link to ordinance
for all amendments made):
A. With respect to residential evictions for non-payment of rent due to financial impacts from
COVID-19, the following applies:
1. The “repayment period” for deferred rent that came or will come due between March 1, 2020
through September 30, 2020, inclusive, is October 1, 2020 through March 31, 2021.
2. For the period of time of March 16, 2020 through September 30, 2020 (the “local moratorium
period”), no residential landlord shall endeavor to evict a tenant for nonpayment of rent, if the tenant
demonstrates that the tenant is unable to pay rent due to financial impacts related to COVID-19, subject
to subparagraphs (a) and (b) below. The protections in Paragraph 2 pre-dated AB 3088 and SB 91. State
law may provide additional protections against eviction for nonpayment of rent due to financial impacts
related to COVID-19 during this local moratorium period.
3. For the period of time of October 1, 2020 through June 30, 2021, tenants shall follow the
preconditions for eviction protection under the Act to receive eviction protection, which include
providing a declaration of hardship to their landlords within 15 days of receipt of an eviction notice and
payment of partial rent (25% of all rent that came due from October 1, 2020 through June 30, 2021 ).
Tenants shall repay the remaining rent due by the end of the repayment period unless earlier forgiven by
landlords through the State Rental Assistance Program created by the Act.
4. For the period of December 8, 2020 through June 30, 2021, no residential landlord shall
terminate a tenancy to demolish or substantially remodel the residential real property unless and until
the landlord secures all permits necessary to perform the work
2020 through September 30, 2020,
inclusive, is October 1, 2020
through March 31, 2021 .
For residential tenants, for the period
of time of March 16, 2020 through
September 30, 2020 (the “local
moratorium period”), no residential
landlord shall endeavor to evict a
tenant for nonpayment of rent, if the
tenant demonstrates that the tenant is
unable to pay rent due to financial
impacts related to COVID-19.
For residential tenants, for the period
of time of October 1, 2020 through
June 30, 2021, tenants shall follow
the preconditions for eviction
protection under the Act to receive
eviction protection
March 23,
2021 Urgency Ordinance No. 1428U, Extending the Temporary Moratorium on Commercial Evictions During
the COVID-19 Pandemic, Extending Commercial Tenant Protections from Premature Eviction Based on
Landlord Intent to Demolish or Substantially Remodel
For commercial tenants, the
moratorium period is March 16,
2020 through June 30, 2021
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Pursuant to Section 2. The Temporary Moratorium on Evictions for Non-Payment of Rent by
Commercial Tenants Impacted by the COVID-19 Crisis, as most recently amended in Urgency Ordinance
No. 21-1425U, is amended to include the following (See link to ordinance for all amendments made):
A. During the moratorium period, no commercial landlord shall evict a tenant for nonpayment of
rent provided the tenant demonstrates that (1) the tenant’s businesses is subject to the Orders referenced
in Section 1 of this Ordinance or is otherwise limited or closed (voluntarily or by mandate) to prevent or
reduce the spread of COVID-19, and (2) the tenant demonstrates lost income and inability to pay rent as
a result of such limitation or closure or other demonstrated financial impact related to COVID-19. For
purposes of Section 2 of this Ordinance, the moratorium period is March 16, 2020 through June 30,
2021.
B. Nothing in Section 2 of this Ordinance shall relieve the tenant of liability for the unpaid rent,
which the landlord may seek after expiration of the moratorium period, and which tenant must pay within
six months of the expiration of the moratorium period (i.e. no later than December 31, 2021). A landlord
may not charge or collect a late fee or interest for rent that is delayed for the reasons stated in this Section
2; nor may a landlord seek rent that is delayed for the reasons stated in Section 2, through the eviction
process during or after the moratorium period. A landlord shall not commence an eviction during the six
months after the end of the moratorium period for non-payment of rent, so long as the tenant pays rent in
a timely manner after the moratorium period and is repaying the past due rent that accrued during the
moratorium period.
C. During the moratorium period, no commercial landlord shall terminate a tenancy to demolish
or substantially remodel the commercial real property unless and until the landlord secures all permits
necessary to perform the work.
April 27, 2021
Urgency Ordinance No. ___, Temporarily allowing Limited Music at Commercial Establishments during
the COVID-19 Crisis
Pursuant to Section 2:
A. The following provisions of the Hermosa Beach Municipal Code are temporarily suspended a
they apply to music played both indoors and outdoors at commercial establishments on the
establishment’s own property or permitted encroachment areas: Sections 8.24.040 (A), (J), 8.24.045 and
8.24.060.
See Section 2(D) to the left reiterated
here: This ordinance and any action
by the City Manager or designee
pursuant to this ordinance shall be in
effect until the earlier of: (i)
termination of the City’s COVID-19
local emergency or (ii) until
terminated or superseded by action of
the City Council.
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24
B. Music shall only be permitted during the hours of 9:00 AM through 9:00 PM and shall be limited
to a noise level that is needed solely for the establishment’s customers.
C. The City Manager, or designee, is authorized to waive any applicable Conditional Use Permit
restrictions inconsistent with this ordinance and is authorized to promulgate any regulations or waive
enforcement of any applicable authority to implement this ordinance.
D. This ordinance and any action by the City Manager or designee pursuant to this ordinance shall
be in effect until the earlier of: (i) termination of the City’s COVID -19 local emergency or (ii) until
terminated or superseded by action of the City Council.
E. Any activity permitted under this ordinance is temporary and does not create a vested right.
April 30, 2021
Executive Order No. 2021-13, Implementing Emergency Measures to Terminate and Supersede
Regulations Requiring Members of the Public to Wear Face Coverings to Align with the Regulations
Issued by the Los Angeles County Public Health Department
Pursuant to Section 2: Pursuant to the authority granted to the City Manager under Section 2.56.060 of
the Hermosa Beach Municipal Code (HBMC), the following emergency orders are effective as of the
date set forth below:
A. The face covering requirements of the Los Angeles County Public Health Order, dated April
29, 2021 and effective April 30, 2021 (“County Health Order”) shall apply to the City and supersede any
conflicting provisions relating to face coverings in Urgency Ordinance No. 20-1415U, Executive Order
No. 2020-03, and Executive Order No. 2020-06.
B. Any subsequent amendments to the face covering requirements set forth in the County Health
Order shall apply in the City as of their respective effective dates.
Pursuant to Section 3: In addition to enforcement remedies available to the City as provided in the
Hermosa Beach Municipal Code, Section 2 shall be enforceable by way of imposing an administrative
citation pursuant to HBMC Chapter 1.10 upon the date that the City Council confirms this Order.
This Order shall become effective
immediately and shall continue until
the earlier to occur of: (1) the
conclusion of the local emergency;
(2) its termination is ordered by the
City Manager/Director of Emergency
Services; or (3) it is duly terminated
by the City Council. The Order may
also be superseded by a duly enacted
ordinance or order of the City Council
expressly superseding this Order.
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May 7, 2021
Executive Order No. 2021-14, To Reopen City Facilities to Members of the Public
A. Section 2(1) of Executive Order No. 2020-01 with respect to City facilities is
hereby rescinded.
B. Section 2(3) Executive Order No. 2020-01 is hereby rescinded.
C. Commencing May 17, 2021, the following City facilities shall reopen to members
of the public by appointment only subject to the occupancy limits and other
requirements set forth in “Appendix D: Office Based Protocols” of the Los
Angeles County Health Officer’s Order (“County Health Officer Order”), as the
County Health Officer Order and Appendix D may be updated from time to time:
a. City Hall which houses the following City Departments: City Manager,
City Clerk, Finance Administration and Cashiers, Community
Development, Code Enforcement, Building Inspection, Public Works
Administration and the Human Resources Department.
D. Commencing on July 1, 2021, the City’s Community Center shall reopen to
members of the public by appointment only subject to Appendix D of the County
Health Order, as the County Health Officer Order and Appendix D may be
updated from time to time.
This Order shall become effective
immediately and shall continue until
the earlier to occur of: (1) the
conclusion of the local emergency;
(2) its termination is ordered by the
City Manager/Director of Emergency
Services; or (3) it is duly terminated
by the City Council. The Order may
also be superseded by a duly enacted
ordinance or order of the City Council
expressly superseding this Order.
May 7, 2021
Executive Order No. 2021-15, To Provide Relief to Local Businesses Associated with the Payment of
City Business Taxes
Pursuant to Section 2. Pursuant to authority granted to the City Manager/Director of Emergency Services
under Section 2.56.060 of the Hermosa Beach Municipal Code (HBMC), the following emergency orders
are issued:
A. City Manager Executive Order. No. 2020-12 is hereby rescinded and superseded.
This Order shall become effective
immediately and shall continue until
the earlier to occur of: (1) the
conclusion of the local emergency;
(2) its termination is ordered by the
City Manager/Director of Emergency
Services; or (3) it is duly terminated
by the City Council. The Order may
also be superseded by a duly enacted
ordinance or order of the City Council
expressly superseding this Order.
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26
B. The provisions of HBMC Sections 5.04.190, 5.04.200 and 5.04.240 regarding City
business taxes are hereby temporarily suspended to the extent they conflict with this
Order, to allow for the implementation of the following:
1. The business tax due and payable on and after March 31, 2020 shall be
deferred and interest and penalties waived for any business that ceased all
business operations after March 16, 2020 and has been entirely closed and
remains closed as of the date of this Order due to the COVID-19 pandemic.
2. A business that paid business tax due on a business license with an expiration
date of March 31, 2020 or later, and that ceased all business operations after
March 16, 2020 due to the COVID-19 pandemic, and does not re-open, is
entitled to and may apply to the City for a pro rata refund of the tax for the
period during which the tax was paid and the business was closed.
3. A business that paid business tax due on a business license with an expiration
date of March 31, 2020, or later, and that ceased all business operations after
March 16, 2020 due to the COVID-19 pandemic, and resumes business
operations, is entitled to and may apply to the City for a business tax credit
that shall be prorated based on the number of months during which the tax
was paid and the business was closed as a result of the COVID-19 pandemic.
4. In order to be eligible for the refund or business tax credit pursuant to this
Order, the business owner must sign a statement under penalty of perjury that
provides dates of closure supported by documentation of the closure
satisfactory to the City. If the foregoing statement is found to be untrue, the
business shall not be entitled to a refund or business tax credit, and any past
due business tax including penalties and interest, shall become payable
immediately.
811
From:noreply@granicusideas.com
To:Eduardo Sarmiento; Suja Lowenthal; City Council; Angela Crespi
Subject:New eComment for City Council Virtual Meeting Closed Session - 5:00 PM=0ARegular Meeting - 6:00 PM=0ADuly
Posted on June 3, 2021 at 8:30 p.m. by E.S.
Date:Friday, June 4, 2021 8:26:59 AM
SpeakUpNew eComment for City Council Virtual MeetingClosed Session - 5:00 PM Regular Meeting - 6:00PM Duly Posted on June 3, 2021 at 8:30 p.m. byE.S.
David Grethen submitted a new eComment.
Meeting: City Council Virtual Meeting Closed Session - 5:00 PM Regular Meeting - 6:00 PM Duly
Posted on June 3, 2021 at 8:30 p.m. by E.S.
Item: e. REPORT 21-0350 UPDATE TO COMMERCIAL AND RESIDENTIAL EVICTION
MORATORIUMS (City Attorney Michael Jenkins) (Assistant City Attorney Monica Castillo)
eComment: For Agenda Item XIV.e Eviction Moratoriums, please adopt (not just consider) the
specified recommendation Suboption 2.d to extend the requirement that commercial landlords
obtain building permits before evicting tenants to demolish or substantially remodel property.
David Grethen - Hermosa Beach Resident
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812
From:noreply@granicusideas.com
To:Eduardo Sarmiento; Suja Lowenthal; City Council; Angela Crespi
Subject:New eComment for City Council Virtual Meeting (Closed Session - 5:00 PM and Regular Meeting - 6:00 PM), Duly
Posted on June 3, 2021 at 8:30 p.m. by E.S.
Date:Friday, June 4, 2021 4:33:03 PM
SpeakUpNew eComment for City Council Virtual Meeting(Closed Session - 5:00 PM and Regular Meeting -6:00 PM), Duly Posted on June 3, 2021 at 8:30p.m. by E.S.
Eric Jones submitted a new eComment.
Meeting: City Council Virtual Meeting (Closed Session - 5:00 PM and Regular Meeting - 6:00
PM), Duly Posted on June 3, 2021 at 8:30 p.m. by E.S.
Item: e. REPORT 21-0350 UPDATE TO COMMERCIAL AND RESIDENTIAL EVICTION
MORATORIUMS (City Attorney Michael Jenkins) (Assistant City Attorney Monica Castillo)
eComment: Hey there, I just found your site, quick question… My name’s Eric, I found
granicusideas.com after doing a quick search – you showed up near the top of the rankings, so
whatever you’re doing for SEO, looks like it’s working well. So here’s my question – what
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814
From:Karynne Thim
To:Eduardo Sarmiento; City Council
Subject:Opposed to extension of eviction moratorium
Date:Monday, June 7, 2021 4:16:07 PM
I am opposed to an extension of the eviction moratorium. It makes no
sense given the state will be fully open next week.
--
815
From:Bill Morris
To:Eduardo Sarmiento
Subject:Please DO NOT reestablish the residential moratorium
Date:Monday, June 7, 2021 6:00:49 PM
I live and work in Hermosa Beach and I truly love this City. The home that I live in since 1994 on 21st
Street just west of PCH is 1,104 sq. ft. so don’t get the idea that I am some out of touch got rich
quick dude or a trust fund baby. On the contrary, I saved every nickel and dime when I was in my
thirty’s to invest in real estate and like every one of my real estate acquaintances I NEVER got rich
quickly. Rather, like them I got to where I am today very slowly, ploddingly slowly, resolutely slowly,
30 years slowly (often times feeding money to my properties from my regular earnings as a real
estate agent………..it WAS and IS very, very tough at times being a landlord)…………………..so I hope
they are teaching our kids in school nowadays about stories like my friends and me. There was a TV
show on Friday nights I used to watch when I was young, it was called ‘Wall Street Week with Louis
Rukeyser” and at the ending of every show he’d close with this remark “Get Rich Slowly My Friend”
and somehow that struck me so I hope the kids of today are hearing that as I did.
Instead schools today are pushing “Critical Race Theory” and the “1699 Project” that propose that
America has a horrible history and is even now a horrible place. Then there is this new
Transgenderism thing and how its ok for a 6 year old to decide their gender as if looking down their
pants don’t tell them enough about what nature gave them. Cursive writing, Art, Industrial Arts,
even critical thinking are gone from our schools. Instead teachers are not teaching kids WHAT to
think instead of teaching kids HOW to think on their own.
Yes, America (like me) has many, many warts, but America and it’s Capitalist roots are the Light of
the World when it comes to lifting people out of poverty, defeating enemies with the crimson red
blood of Americans fighting to end tyranny and then giving that precious land taken back to the
defeated enemies and helping rebuild that same land with the financial resources of whom?
America!! Yeah, there a lot of work to be done at home but America is not a BAD
country………..anyone who reads or travels that will learn that rapidly.
Oh, so I’ve digressed a bit, please forgive me but the world has over time (but somehow so much
more suddenly) has become a very strange place for what were once considered “Normal” folks. I
own smallish rental properties in Long Beach, Lynwood, Los Angeles, Dallas and Atlanta and I know
from personal experience how hard it is to be a landlord and this government overreach has been,
well, just out of touch. So, please don’t do it.
Thank you for your patience in reading my diatribe, Bill.
Bill Morris
703 Pier Ave., Ste. B611
Hermosa Beach, CA 90254
Cell: 310-367-1169
wjmrealestate@verizon.net
Agent CDRE# 01150909
816
817
From:Alya lucas
To:Eduardo Sarmiento
Subject:URGENT: We strongly oppose to adoption of a new residential eviction moratorium.
Date:Monday, June 7, 2021 7:36:20 PM
Dear City Council,
We have invested in heavily in the city we love, and own mulitple properties on the
Hermosa Beach Strand. The over yearlong COVID-19 pandemic and related
government response has had devastating impacts on the multifamily rental housing
industry. As the State is reopening and businesses are resuming regular operations,
small business rental housing providers must also be allowed to resume normal
operations.
It is time to reopen and to take steps in support of the economic recovery not to back
track by reinstating or extending interim emergency measures. We strongly support
the City’s promotion of the State’s COVID-19 Rent Relief Program. Ask the City
Council to seek budgetary solutions to bridge the gap and provide rental housing
providers with the 20% rental debt not covered by the State’s program and financial
support for rental housing providers and renters who are not eligible under the
program.
Alya Lucas
This communication is intended only for the use of the individual or entity to which it is addressed and may contain
information that is privileged, confidential and exempt from disclosure under applicable law. If the reader of this
communication is not the intended recipient or the employee or agent responsible for delivering this message to the
intended recipient, you are hereby notified that any discrimination, distribution or copying of this communication is
strictly prohibited. If you received this communication in error, please notify me immediately. All real estate terms,
conditions, and amounts mentioned herein are non-binding. All parties understand and acknowledge that sender is
not qualified to provide and has not been contracted to provide legal, financial or tax advice and that any such advise
must be obtained from their attorney, accountant or tax professional.
Do not conform to the pattern of this world, but be transformed by the renewing of your mind. Then you will be able to test and approve
what God’s will is—his good, pleasing and perfect will. Romans 12:2
818
From:James Rodney
To:Eduardo Sarmiento
Subject:Please End the Eviction Moratorium
Date:Monday, June 7, 2021 7:33:22 PM
The over yearlong COVID-19 pandemic and related government response my
financial security has been destroyed as a real estate owner in Hermosa Beach. I
had been saving money to remodel my property but now am in economic danger
of losing them. Some of my tenants have not paid rent even though they still work
and have purchased brand new Tesla vehicles. They have been invited but have not
followed through on applying for rent relief through the state.
As the State is reopening and businesses are resuming regular operations, it is
financial suicide for you to continue emergency measures of any type especially a
new evicton moratorium. The "emergency" is over as should the emergency
measures that are putting me in dire financial straits.
Sincerely,
James Pousson
819
From: Dan Inskeep <daninskeep@hotmail.com>
Sent: Monday, June 7, 2021 6:07 PM
To: City Council <citycouncil@hermosabeach.gov>
Subject: please reject an extension of any Residential Eviction Moratorium
Dear Hermosa Beach City Council,
Please reject the extension of any Residential Eviction Moratorium. The State's Residential
Eviction Moratorium has already put an inequitable burden on those who support their
families and livelihoods through residential property rentals. Residential Eviction Moratoriums
unfairly place the burden of our difficult economic times on property owners. If Government
feels the need to support citizens that are struggling to pay rent, then establish subsidies or
other programs to help those people live up to their financial obligations.
Please do not attack property owners and expect them to provide social services that are the
responsibility of all society.
Thank you for your time and service for our City!
Dan Inskeep
daninskeep@hotmail.com
820
View this email in your browser
Attention Southern Cities Members:
From: Fred Nichols <fredcnichols@yahoo.com>
Sent: Tuesday, June 8, 2021 1:21 PM
To: City Council <citycouncil@hermosabeach.gov>; City Council <citycouncil@hermosabeach.gov>
Subject: Fw: ❗RED ALERT: Hermosa Beach City Council to Consider Reestablishment of Residential Eviction
Moratorium( From Holmes)
to: Members of Hermosa Beach City Council
Please do not support the reestablishment of a Residential Eviction Moratorium in Hermosa Beach. Many landlords, like
myself are already dealing with significant losses to our rental properties due to the pandemic.
Fred Nichols
Mobile 310 351-4636
----- Forwarded Message -----
From: Fred Nichols <fredcnichols@yahoo.com>
To: esarmiento@hermosabeach.gov <esarmiento@hermosabeach.gov>
Sent: Tuesday, June 8, 2021, 01:17:23 PM PDT
Subject: Fw: ❗RED ALERT: Hermosa Beach City Council to Consider Reestablishment of Residential Eviction Moratorium(
From Holmes)
Mr. Esarmiento,
I am a 42 year resident and landlord in Hermosa Beach.
My wife and I currently own/manage 5 rentals in Hermosa.
We concur with the referenced letter from Ms. Leidner-Pereta on AAGLA.
Fred Nichols
Mobile 310 351-4636
-----Original Message-----
From: Apartment Association of Greater Los Angeles <info@aagla.org>
To: Sent: Mon, Jun 7, 2021 4:59 pm
Subject: ❗RED ALERT: Hermosa Beach City Council to Consider Reestablishment of Residential Eviction Moratorium
Potentially Detrimental Changes Affecting Your Property! Just as California is about to reopen on June 15th, at the June 8th Hermosa City Council...
821
AAGLA is taking a strong position against a proposal that may be adversely
impacting housing providers in your area. Where is AACSC when it comes to
protecting the South Bay’s landlords? Apparently nowhere... Fortunately, AAGLA has
it covered! Join AAGLA today, the leading Apartment Association in California.
CLICK HERE to learn more about AAGLA membership benefits.
RED ALERT
Monday, June 7, 2021
Hermosa Beach City Council
to Consider Reestablishment
of Residential Eviction
Moratorium
Potentially Detrimental Changes
Affecting Your Property!
822
Just as California is about to reopen on June 15th, at the June 8th Hermosa City
Council meeting, the Council will be considering three options that include
adoption of a new residential eviction moratorium and extension of the
requirement that housing providers obtain building permits prior to issuing a
tenancy termination to demolish or substantially remodel their property,
(agenda item XIVe). The Council will also consider aggressive promotion of the
State’s rental assistance program. The Association is strongly opposed to
adoption of a new residential eviction moratorium.
The over yearlong COVID-19 pandemic and related government response has
had devastating impacts on the multifamily rental housing industry. As the
State is reopening and businesses are resuming regular operations, small
business rental housing providers must also be allowed to resume normal
operations.
CALL TO ACTION
We urge members with property in the City of Hermosa to call into the City Council
meeting tomorrow at 6pm and provide public comment. Express your strong
opposition to adoption of a new residential eviction moratorium. Call on the Council
to take action to support rental housing providers and to facilitate the City’s
economic rebound.
Let the City Council know that it is time to reopen and to take steps in support
of the economic recovery not to back track by reinstating or extending interim
emergency measures. Support the City’s promotion of the State’s COVID-19
Rent Relief Program. Ask the City Council to seek budgetary solutions to bridge
the gap and provide rental housing providers with the 20% rental debt not
covered by the State’s program and financial support for rental housing
providers and renters who are not eligible under the program.
To view the letter we wrote to the Hermosa Beach City Council, please click the
button below:
AAGLA LETTER TO CITY COUNCIL
823
MEETING INFORMATION
Date: Tuesday, June 8, 2021
Time: 6:00 PM
How to View the Meeting:
Public meetings are broadcast live on Spectrum Channel 8 and Frontier
Channel 31 in Hermosa Beach. Additional viewing options:
YOUTUBE CHANNEL: www.youtube.com/channel/UCaiZxw06ue-
Tgc8DmXYzh2Q
CITY WEBSITE: www.hermosabeach.gov and visit the Agendas/Minutes/Videos
page
How to Provide a Public Comment:
JOIN THE VIRTUAL MEETING AT:
https://us02web.zoom.us/j/87032785286?
pwd=RGVVZnduNGVIVGJLOFlvaFNuYTBlUT09
or PARTICIPATE BY PHONE:
• Toll Free: 877-853-5257
• Meeting ID: 870 3278 5286
• Participant ID: 513185
Attendees will be muted until public participation period.
If you are joining by phone, press * 6 to unmute your line. Comments
from the public are limited to 3 minutes per speaker.
How to Provide a Written Comment:
Members of the public may email comments to
Esarmiento@hermosabeach.gov.
Written materials pertaining to matters listed on the posted agenda received
after the agenda has been posted will be added as supplemental materials
under the relevant agenda item on the City's website at the same time as they
AGENDA
STAFF REPORT
824
are distributed to the City Council by email. Supplemental materials may be
submitted via email to esarmiento@hermosabeach.gov. Supplemental
materials must be received before 4:00 p.m. on the date of the meeting to
ensure Council and staff have the ability to review materials prior to the
meeting. Supplemental materials submitted after 4:00 p.m. on the date of the
meeting or submitted during the meeting will be posted online the next day.
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825
From:Joann Jacobs
To:Eduardo Sarmiento
Subject:Vote No on extending the Residential Eviction Moratoriums
Date:Tuesday, June 8, 2021 3:59:00 PM
Dear Honorable Mayor Massey and Members of the Hermosa Beach City Council:
We are Mom & Pop owners of rental units near the beach. We only have a small residential apartment building.
We bought this property years ago to provide income for us when we are retired. At 75 & 80 we depend on the
income from these units to provide our daily needs. We have seen our neighbors being taken advantage of during
this moratorium.
Eviction Moratorium is not an equitable approach and is extremely unfair to us ‘Mom & Pop’ owners who
purchased in this wonderful city many, many years ago as an investment to provide for our future.
Employment is now opening up to many. If you feel a need to help, please offer Rental Assistance. We won’t be
able to survive without getting our rent from our tenants.
Please Don’t Extend the Eviction Moratorium.
Warmly,
Don & Joann
826
City of Hermosa Beach
Staff Report
City Hall
1315 Valley Drive
Hermosa Beach, CA 90254
Staff Report
21-0351
Honorable Mayor and Members of the Hermosa Beach City Council
Regular Meeting of June 8, 2021
MAYOR MASSEY REQUESTS THE CITY COUNCIL DIRECT STAFF TO PLACE ON THE CITY
COUNCIL’S NEXT REGULAR SESSION AGENDA A LETTER OF SUPPORT FOR THE HERMOSA
BEACH CITY SCHOOL DISTRICT’S EFFORTS TO IMPLEMENT ITS EQUITY AND INCLUSION
GOALS
City of Hermosa Beach Printed on 6/7/2021Page 1 of 1
powered by Legistar™827
City of Hermosa Beach
Staff Report
City Hall
1315 Valley Drive
Hermosa Beach, CA 90254
Staff Report
21-0347
Honorable Mayor and Members of the Hermosa Beach City Council
Regular Meeting of June 8, 2021
TENTATIVE FUTURE AGENDA ITEMS
Attached is the current list of tentative future agenda items for Council’s information.
Attachments:
Tentative Future Agenda Items
City of Hermosa Beach Printed on 6/3/2021Page 1 of 1
powered by Legistar™828
June 3, 2021
Honorable Mayor and Members Regular Meeting of
of the Hermosa Beach City Council June 8, 2021
TENTATIVE FUTURE AGENDA ITEMS
JUNE 22, 2021 @ 5:00 PM INITIAL
DATE CLOSED SESSION
JUNE 22, 2021 @ 6:00 PM
PRESENTATIONS
COVID-19 HEALTH UPDATE FROM BEACH CITIES HEALTH DISTRICT
SOUTHERN CALIFORNIA EDISON ANNUAL RELIABILITY REPORT
CITY MANAGER REPORTS
COVID-19 Update
Update from Chief LeBaron on enforcement measures
CITY COUNCILMEMBER COMMENTS
Updates from City Council Ad Hoc Subcommittees and Standing Committee Delegates/Alternates
CONSENT CALENDAR
City Council Minutes City Clerk Ongoing
Check Registers Finance Director Ongoing
Revenue Report, Expenditure Report and CIP Report by Project Finance Director Ongoing
City Treasurer’s Report and Cash Balance Report City Treasurer Ongoing
Cancellation of Certain Checks City Treasurer Ongoing
Public Works Project Status Report Interim Public Works Director Ongoing
Recommendation to receive and file the action minutes of the Planning
Commission meeting of June 15, 2021
Community Development Director Ongoing
Planning Commission Tentative Future Agenda Items Community Development Director Ongoing
Annual Financial Report Finance Director Annual
Adoption of the 2021–22 Appropriations Limit Finance Director Annual
Approval of Professional Services Agreement for on-call consulting services
related to compliance with the California Environmental Quality Act
Community Development Director Staff Request
June 2, 2021
PUBLIC HEARINGS – 6:30 PM
Adoption of Fiscal Year 2021–22 Budget Finance Director Annual
Ordinance amending Chapter 8.60 of the Hermosa Beach Municipal Code to
comply with the Department of Water Resources’ Model Water Efficient
Landscape Ordinance
Environmental Programs Manager Staff Request
May 24, 2021
Consideration of adding a chapter to Title 8 of the Hermosa Beach Municipal
Code to establish standards for outdoor lighting on residential properties
Community Development Director Staff Request
June 3, 2021
MUNICIPAL MATTERS
Participation in Beach Cities Transit (BCT) Line 109 Agreement, with no
required financial contribution from the City for Fiscal Year 2021–2022, with
the Cities of El Segundo, Manhattan Beach and Redondo Beach, funded from
Proposition A Funds
Community Development Director Annual
Return to Council to discuss a full ban on tobacco sales and to include all
available data related to other communities who have adopted complete bans
Community Development Director Council Direction
Jan. 28, 2020
Consideration of Options for Downtown Lane Reconfigurations, and Outdoor
Dining and Retail Programs
Environmental Programs Manager Staff Request
Apr. 7, 2021
Award of Construction Contract for CIP 669—City Park Restrooms Interim Public Works Director Staff Request
Apr. 22, 2021
Award of Construction Contract for CIP 186 and CIP 190 – Street
Improvements, Various Locations
Interim Public Works Director Staff Request
Apr. 22, 2021
FUTURE AGENDA ITEMS
Tentative Future Agenda Items City Manager Ongoing
829
2
TENTATIVE – JULY 13, 2021 @ 4:00 PM
APPLICANT INTERVIEWS FOR
PARKS, RECREATION & COMMUNITY RESOURCES ADVISORY COMMISSION
JULY 13, 2021 @ 5:00 PM INITIAL
DATE CLOSED SESSION
JULY 13, 2021 @ 6:00 PM
CANVASS OF VOTES AND INSTALLTION OF OFFICER
TENTATIVE - CERTIFIED RESULTS OF THE CANVASS OF VOTES FOR THE SPECIAL ELECTION OF
MAY 11, 2021, AND CEREMONIAL SWEARING-IN OF NEW COUNCILMEMBER
PRESENTATIONS
COVID-19 HEALTH UPDATE FROM BEACH CITIES HEALTH DISTRICT
CITY MANAGER REPORTS
COVID-19 Update
Update from Chief LeBaron on enforcement measures
CITY COUNCILMEMBER COMMENTS
Updates from City Council Ad Hoc Subcommittees and Standing Committee Delegates/Alternates
CONSENT CALENDAR
City Council Minutes City Clerk Ongoing
Check Registers Finance Director Ongoing
Recommendation to receive and file the action minutes of the Parks,
Recreation and Community Resources Advisory Commission meeting of June
1, 2021
Community Resources Manager Ongoing
Los Angeles Fire Services and McCormick Ambulance Monthly Report for
May 2021
Emergency Management
Coordinator
Ongoing
Approval of Special Event Long Term Agreement with Shakespeare by the
Sea for its Annual Events Held at Valley Park
Community Resources Manager Staff Request
June 1, 2021
Community Development Director
PUBLIC HEARINGS – 6:30 PM
Approval of the Cypress Block Party to the 2021 Special Events Calendar Community Resources Manager Staff Request
May 26, 2021
Public Hearing to review delinquent solid waste collection (refuse) charges
for consideration of placing said charges on the property tax rolls as a special
assessment. The assessment would affect only those properties with refuse
bills delinquent as of March 31, 2021.
Environmental Programs Manager
Doug Krauss
Annual
Public Hearing – Hermosa Beach Landscaping and Street Lighting District
Fiscal Year 2021–2022
Interim Public Works Director Annual
City Council review and reconsideration of the April 20, 2021 Planning
Commission decision to deny a request for a Conditional Use Permit
amendment to provide onsite sale, service, and consumption of general
alcohol indoors only within the hotel lounge for registered guests only, seven
days a week 7:00 A.M. To 10:00 P.M. at an existing hotel (H2o Hermosa) at
1429 Hermosa Avenue, and determination that the project Is categorically
exempt from the California Environmental Quality Act (CEQA) – Continued
from May 25, 2021
Community Development Director Council Direction
April 27, 2021
Housing Element Community Development Director Staff Request
May 19, 2021
MUNICIPAL MATTERS
Vacancies – Boards and Commissions – Parks, Recreation & Community
Resources Advisory Commission
City Clerk 4-Year Term
FUTURE AGENDA ITEMS – CITY COUNCIL
Future Agenda Items City Manager Ongoing
830
3
TENTATIVE - THURSDAY, JULY 22, 2021 @ 6:00 PM
JOINT MEETING WITH ALL BOARDS/COMMISSIONS
JULY 27, 2021 @ 5:00 PM INITIAL
DATE CLOSED SESSION
JULY 27, 2021 @ 6:00 PM
PRESENTATIONS
COVID-19 HEALTH UPDATE FROM BEACH CITIES HEALTH DISTRICT
CITY MANAGER REPORTS
COVID-19 Update
Update from Chief LeBaron on enforcement measures
Update from Jim Fasola – City Delegate to the Los Angeles County West Vector & Vector-Borne Disease Control
District Board of Trustees
CITY COUNCILMEMBER COMMENTS
Updates from City Council Ad Hoc Subcommittees and Standing Committee Delegates/Alternates
CONSENT CALENDAR
City Council Minutes City Clerk Ongoing
Check Registers Finance Director Ongoing
Revenue Report, Expenditure Report and CIP Report by Project Finance Director Ongoing
City Treasurer’s Report and Cash Balance Report City Treasurer Ongoing
Cancellation of Certain Checks City Treasurer Ongoing
Public Works Project Status Report Interim Public Works Director Ongoing
Recommendation to receive and file the action minutes of the Public Works
Commission meeting of May 19, 2021
Interim Public Works Director Ongoing
Recommendation to receive and file the action minutes of the Planning
Commission meeting of July 20, 2021
Community Development Director Ongoing
Planning Commission Tentative Future Agenda Items Community Development Director Ongoing
FUTURE AGENDA ITEMS
Tentative Future Agenda Items City Manager Ongoing
831
4
AUGUST 10, 2021 @ 5:00 PM INITIAL
DATE CLOSED SESSION: Frilot v. City of Hermosa Beach, et al.
AUGUST 10, 2021 @ 6:00 PM
PRESENTATIONS
COVID-19 HEALTH UPDATE FROM BEACH CITIES HEALTH DISTRICT
LOS ANGELES COUNTY FIRE SERVICES AND MCCORMICK AMBULANCE SEMI-ANNUAL UPDATE
CITY MANAGER REPORTS
COVID-19 Update
Update from Chief LeBaron on enforcement measures
CITY COUNCILMEMBER COMMENTS
Updates from City Council Ad Hoc Subcommittees and Standing Committee Delegates/Alternates
CONSENT CALENDAR
City Council Minutes City Clerk Ongoing
Check Registers Finance Director Ongoing
Recommendation to receive and file the action minutes of the Parks,
Recreation and Community Resources Advisory Commission meeting of July
6, 2021
Community Resources Manager Ongoing
Los Angeles Fire Services and McCormick Ambulance Monthly Report for
June 2021
Emergency Management
Coordinator
Ongoing
FUTURE AGENDA ITEMS – CITY COUNCIL
Future Agenda Items City Manager Ongoing
MONDAY, AUGUST 16, 2021 @ 5:00 PM
TRI-AGENCY MEETING WITH HBCSD AND BCHD
NO MEETING AUGUST 24, 2021
(DARK)
832
5
PENDING STRATEGIC PLAN ITEMS STATUS /
TENTATIVE MEETING DATE
Update Personnel Policies Human Resources
Manager
Beach Policy/Regulations (Continued from meeting of October 27, 2016) Community Resources
Manager On hold by Council
Alternative Fuel Transportation Report, Nov. 2016 Environmental Analyst
CCA Direction, Dec. 2016 Environmental
Programs Manager
PENDING NEW ITEMS STATUS /
TENTATIVE MEETING DATE
Consideration of re-establishing, on an as needed basis, both funding and
discretion for the director of Public Works to contract services to pump major
beach storm outfalls drains prior to anticipated major storm events (supported
by Duclos, Armato and Petty)
Initiated by: Other Matters Feb. 14, 2017
Public Works Director Staff to provide an update
on storm drain maintenance
and provide details on
hydrodynamic separators
(CIP 435) at the following
CIP study session
Policy discussion regarding city responsibilities and expectations when
donations are made to City
Initiated by: Council Direction May 24, 2017
Finance Director Will be discussed at the
Revenue Strategy Study
Session
Approval of the Municipal Lease Policy
Initiated by: Staff Request Jun. 12, 2018
Community Resources
Manager
Document Retention Policy
Initiated by: Staff Request Nov. 28, 2018
City Clerk Pending Deputy City Clerk
Appointment
Consent for use of “Lot B” for construction staging area for Pier/Strand
project
Initiated by: Staff Request Dec. 17, 2018
Community
Development Director On hold per developer
Landscape and Street Lighting District Assessment Adjustment (mail-in
election authorization)
Initiated by: Council Direction Jul. 9, 2019
Public Works Director Add to Revenue Strategy
Study Session
Final Parcel Map No. 82295 for a two-unit residential condominium project at
1602 Loma Drive.
Initiated by: Staff Request Oct. 10, 2019
Community
Development Director Pending Coastal Development
Permit
Public Records Request Guidelines
Initiated by: Staff Request Oct. 14, 2019
City Clerk/Assistant to
the City Manager
Pending Deputy City Clerk
Appointment
Emergency Services Municipal Code Chapter 2.56 Update
Initiated by: Staff Request Jan. 15, 2020
Emergency
Management
Coordinator
Waiting for State to review
proposed language changes
Consideration of licensing agreement/fees for use of City logo
Initiated by: Council Direction Jun. 9, 2020
City Attorney
Discussion on Potential Establishment of a City Council Subcommittee
Regarding City Finances (supported by Detoy, Armato, Fangary)
Initiated by: Other Matters Jun. 9, 2020
Finance
Director/Assistant to the
City Manager
Request to Renew the Agreement to Purchase Parking Meter Equipment and
Related Services
Initiated by: Staff Request August 11, 2020
Police Chief
Follow-up on Mayor’s Pledge
Initiated by: Council Direction August 25, 2020
City Manager’s
Office/Police Chief
Approval of First Amendment to Agreement with the Hermosa Beach
Education Foundation for its Annual “Hearts of Hermosa” Event
Initiated by: Staff Request December 7, 2020
Community Resources
Manager
Updating Resolution 15-6988, Rules for the Conduct of City Council
Meetings.
Initiated by: Staff Request December 12, 2020
City Attorney/City
Clerk
Resolution of the City Council of the City of Hermosa Beach Approving the
Grant of Funds from the State Coastal Conservancy for Hermosa Beach
Parking Lot Greening Project
Initiated by: Staff Request April 12, 2021
Environmental
Programs Manager
833