The Cost of MS4 Trash Load Reduction
California stormwater programs are facing increasing requirements and responsibilities for trash management. Highly publicized news about trash in our communities and the effects and impacts of trash in the environment has heightened regulatory scrutiny and public concern about this very visible pollutant of our waterways.
At the state level, the State Water Board has been working on the development of proposed trash amendments the California Ocean Plan and the Inland Surface Waters, Enclosed Bays, and Estuaries Plan. The proposed Trash Amendments will include five elements: (1) Water Quality Objective, (2) Prohibition of Discharge, (3) Implementation, (4) Compliance Schedule, and (5) Monitoring. At the local level many Regional Water Boards have already been inserting trash control requirements into Municipal Separate Stormwater Sewer System (MS4) permits. One such set of requirements was included in the regional stormwater permit issued to communities in the San Francisco Bay Region. Section C.10 of the Municipal Regional Stormwater NPDES Permit Order R2-2009-0074 includes Trash Load Reduction. This section requires the reduction of trash loads from MS4s of 40% by 2014; 70% by 2017, and 100% by 2022.
To meet these aggressive reduction goals, MS4s have developed Short-Term and Long-Term Trash Load Reduction Plans. One local agency has initiated the development of a cost assessment tool to best plan for meeting trash reduction requirements. An analysis of the likely control measures for controlling trash in MS4s can serve as a menu of available trash control options and help predict the cost of compliance. Control measures considered include: full trash capture devices, partial trash capture devices, enhanced storm drain maintenance, street sweeping, bin management, uncovered load enforcement, anti-littering and illegal dumping enforcement, community outreach and education, creek/channel/shoreline cleanup, on-land cleanup, code enforcement and product bans. Drawing mostly from California-wide information, spreadsheets of costs estimates have been developed. The spreadsheets can now be used as a calculator, based on curb miles cleaned, number of capture devices installed, pounds of trash removed, crew hours allocated, number of bins, annual program costs, etc.
This presentation will describe the cost assessment approach and include examples of how this approach can be tailored to fit different MS4 resources and needs.