Innovations in Stormwater Capture Incentivization: LADWP's Plan for an Industrial Stormwater Rebate Program
Statewide agencies are increasingly seeking innovative ways to encourage stormwater capture for water supply augmentation. The SWRCB recently proposed an amendment to the statewide industrial general permit for stormwater discharges, which would allow an alternative compliance pathway for onsite retention of industrial stormwater. Consistent with this statewide direction, the Los Angeles Department of Water and Power (LADWP) recently developed a strategic plan to encourage and incentivize industrial stormwater dischargers through a rebate program to implement infiltration or capture/re-use projects in order to promote achievement of LADWP’s stormwater capture and water supply goals. LADWP worked with Ortega Strategies Group, Geosyntec Consultants, and Waterkeeper to outline the framework for such a plan and program and to engage the Non-governmental organizations (NGO) and the industrial community while doing so. Key components to the development of this plan included outlining and implementing a communications and outreach strategy, evaluating the opportunities and constraints of the rebate program, identifying potential industrial stormwater dischargers that may be interested in the program, quantification of the potential water supply augmentation benefit available through the program, cost and rebate implication comparisons of hypothetical discharger site scenarios, stakeholder and regulatory outreach public meetings, and final synthesis of the gathered information and data into a cohesive strategic plan outlining how the plan will be implemented and how interested parties will apply. The focus of this presentation will be on the technical evaluations performed including:
- an evaluation of the quantity of industrial stormwater sites (and their acreage) that may be eligible for the proposed rebate based on geophysical land categories identified in the LADWP stormwater capture master plan;
- a SMARTS data analysis to identify pollutants of concern that may exceed groundwater quality objectives even when accounting for pretreatment;
- an estimation of the potential water supply benefit available through the potential rebate program; and
- a cost comparison of hypothetical structural BMP planning options (e.g, infiltration basins, active and natural flow through treatment BMPs, treatment and injection drywells, capture/re-use, and offsite regional BMP contribution).
In addition to the above, additional constraints will also be identified along with potential mitigation strategies including program provisions to support verification and monitoring, as well as groundwater and surface water protection. This presentation will be relevant and engaging to the industrial stormwater community as it presents an opportunity for those within LADWP’s jurisdiction that are currently engaged in structural BMP planning under the statewide industrial general permit (for example, for the Level 2 Exceedance Response Action process) and because many of the technical evaluations performed are relevant to other municipalities or water purveyors that may be considering means to promote alternative water sources. Furthermore, the propose incentive program is a model for other water agencies across the state. Finally, this presentation ties directly into the conferences theme as LADWP is trying to capture every drop of water from “summit to sea” and provide innovative methods for encouraging infiltration and water reuse.LADWP staff will also be available to provide an overview of the program, a schedule for possible implementation, and answer technical and policy questions.