Industrial General Permit Implementation at 25 School District Bus Maintenance Facilities; A Group Effort
Twenty-five school districts across San Diego, Imperial, and Orange Counties currently comprise the Industrial Stormwater Management Group, a collaboration led by the San Diego County Office of Education. Industrial General Permit (Permit) compliance at school district bus maintenance facilities can be challenging, particularly given limited resources. With the issuance of a more stringent Industrial General Permit, school districts are preparing to meet the new requirements by sharing ideas and pooling resources to develop comprehensive compliance strategies.
Recognizing that under the new Permit it is much easier to go up to higher compliance levels than to come back down, the group has been helping member districts evaluate their monitoring results in light of the new NALs and begin making changes now, before exceedances start triggering increases in compliance level. With a year, and a wet season, to go before the new Permit goes into effect, school districts are taking the opportunity to implement targeted changes to facility maintenance practices and minor structural adjustments. The monitoring results for the past year and for the upcoming year will be used to assess the effectiveness of these relatively cost-effective measures now, providing valuable information for adaptive management and SWPPP updates going into the new Permit. This strategy aims to keep the districts at a baseline compliance level once the new Permit becomes effective and allows the limited resources of the districts to be allocated directly to the most effective methods to improve water quality, and not spent on the additional costs associated with Exceedance Response Actions.
Working collaboratively, districts are able to streamline reporting and other requirements, and build upon the experiences of other group members to select a path to compliance that best meets their needs. Based on an analysis of group data, the key constituents expected to be a challenge at school district bus maintenance facilities will be presented. The remainder of the presentation will then utilize case studies as examples of effective facility maintenance BMP implementation, investments in simple structural improvements, and low impact development designs that together comprise a cache of resources for districts to draw from as they tailor their approach to Industrial General Permit compliance.