Trash Amendments Cost Compliance Considerations for San Francisco
The recent approval and adoption of the Statewide Water Quality Control Plans for Trash have pressured many permittees to start to think about their compliance Track selection. The Amendments to the Water Quality Control Plan for Ocean Waters of California (Ocean Plan) and Part 1 Trash Provisions of the Water Quality Control Plan for Inland Surface Waters, Enclosed Bays, and Estuaries of California (ISWEBE Plan), collectively called “Trash Amendments,” identify two compliance Tracks to control trash. Utilization of green infrastructure is welcomed in Track II, albeit green infrastructure units are part of a larger implementation plan to capture the full capture system equivalency (FCSE) for trash. For Track I compliance, however, green infrastructure designs are not included in the current list of full capture devices. These units would need to be certified by the State Water Board before implementation.
In the City and County of San Francisco (San Francisco), San Francisco Public Utilities Commission (SFPUC) is the Municipal Separate Storm Sewer System (MS4) Phase II permit holder. SFPUC has explored the implementation of both Track I and Track II through a Cost-Compliance analysis. Per this analysis, Track I is a favorable option for compliance with the Trash Amendments as it best serves SFPUC’s unique MS4 jurisdictional setting which consists of small, discontinuous areas throughout San Francisco’s larger combine sewer system.
The installation of full capture systems throughout SFPUC’s MS4 areas would set back the Low Impact Development (LID) and green infrastructure movement that has become an integral part of stormwater management within San Francisco. In order to take advantage of the investment and advancements of green infrastructure in San Francisco, SFPUC’s Wastewater Enterprise Planning and Regulatory Compliance Division and Urban Watershed Management Division are investigating green infrastructure design considerations that would qualify as full capture systems, given certification by the State Water Board. Green infrastructure design considerations and retrofits under consideration include, but are not limited to, enhancements to forebays and overflow components to serve as cigarette butt filters.
This presentation would present the SFPUC cost-compliance analysis between Track I and Track II which led to the discussion of green infrastructure integration, and primarily focus on the actions to date, including review of current San Francisco local design regulations, to identify design criteria suitable for Track I implementation. This presentation would serve as a guide for audience members who are also interested in looking to utilize green infrastructure in complying with Trash Amendments. It will present design criteria or potential retrofit options that can elevate green infrastructure units to full capture systems as well as identify outstanding areas of study. Shedding light on the capacity of green infrastructure to control trash reinforces the 2016 CASQA conference theme, since these practices are not only necessary in converting stormwater from a source to resource, but may also be used as a regulatory compliance mechanism.