Letter to the Regional Water Board on impervious surfaces

CGF received a grant from the Santa Clara Valley Water District to analyze the need under the California Environmental Quality Act to monitor cumulative impacts from impervious surfaces. Meanwhile, the San Francisco Bay Regional Water Board is considering similar issues under different laws that regulate water quality. Below is a letter we sent today asking for improved monitoring, which will take us well on the way towards getting improved mitigation.

-Brian
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August 1, 2005

Mr. Bruce H. Wolfe
Executive Officer
Regional Water Quality Control Board
1515 Clay Street, Suite 1400
Oakland, CA 94612

Dear Mr. Wolfe,

The Committee for Green Foothills believes that the success of the stormwater program as it currently exists and as it could improve in the future relies upon an effective program to monitor changes in impervious surface. We write you today to request that the Regional Board take the necessary action to clarify the monitoring requirements of all the existing stormwater programs in the Bay Area.

The essential elements of an effective monitoring program would be:

1. Annual reporting on the increase and decrease in impervious surface in each community, the volume of stormwater detention storage provided and an estimate of the degree to which this storage would provide detention for the 2 year, the 10 year and the 50 year storm. The data should be in spreadsheet/database and report format that identify the type of development, the status under the permit (i.e. exempt, subject only to treatment requirements,etc) and the watershed to which each development is tributary.

2. A report on developments over 5 acres approved by each municipality, the amount of impervious surface added or reduced by the development, the volume of stormwater storage/detention provided, an estimate of whether this storage will contain the 2 year, the 10 year and the 50 year storm. the the percentage of the increase for which the 2 year, the 10 year and the 50 year storm are being captured by flow detention facilities. This report should be quarterly during the first two years of the permit and annually thereafter in order to assure that the program is being effectively implemented during the startup period.

The quarterly report should be due 45 days after the end of each quarter and the annual report should be submitted with the regular Annual Report for the Stormwater Program.

We would appreciate your thoughtful consideration to this proposal. This request is substantially similar to a suggestion I made in oral comments at the July 20, 2005 meeting. In a sidebar conversation I had Board Chairman Muller at the meeting, he said he would request that you respond to my suggestion. I hope you can do so by replying to this letter.

Please contact me if you have any questions.

Sincerely,


Brian A. Schmidt
Legislative Advocate, Santa Clara County