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STAFF REPORT
CITY COUNCIL
DATE: June 20, 2017
TO: Honorable Mayor and City Councilmembers
FROM:
Christopher L. Foss, City Manager
SUBJECT:
Consideration of the City of Dublin’s Framework for Green Infrastructure
Plan Development to Meet Mandates in the Re-issued Municipal Regional
Stormwater National Pollutant Discharge Elimination System Permit
Prepared by: Shannan Young, Environmental Coordinator
EXECUTIVE SUMMARY:
The City Council will consider adopting a Green Infrastructure Frame work that is
required to meet mandates in the re-issued Municipal Regional Stormwater National
Pollutant Discharge Elimination System Permit issued on November 19, 2015 by the
San Francisco Bay Regional Water Quality Control Board. By June 30, 2017, all
permittees must submit a Green Infrastructure Framework, which specifies the timeline
and tasks required to complete a Green Infrastructure Plan.
STAFF RECOMMENDATION:
Adopt the Resolution Approving a Framework for Municipal Regional Stormwater
National Pollutant Discharge Elimination System Permit Green Infrastructure Plan
Development.
FINANCIAL IMPACT:
There are no costs associated with adopting the Green Infrastructure Framework under
consideration in this report. There will be future costs associated with development of
the Green Infrastructure Plan, which is required to be submitted to the San Francisco
Bay Regional Water Quality Control Board in the 2019 Annual Report. Those costs will
be determined as part of that phase of the project, and it is an ticipated that funding for
the Green Infrastructure Plan will come from the Municipal Regional Stormwater
National Pollutant Discharge Elimination System Permit General Fund Assigned
Reserves.
DESCRIPTION:
The re-issued Municipal Regional Stormwater National Pollutant Discharge Elimination
System (NPDES) Permit (MRP 2.0), of which the City of Dublin is a co -permittee,
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became effective on January 1, 2016. MRP 2.0 includes a new requirement for each
permittee to prepare a Green Infrastructure (GI) Plan that demonstrates it can meet
targets for the amount of impervious surfaces to be retrofitted with green infrastructure
by 2020, 2030, and 2040, in accordance with mercury and polychlorinated biphenyls
(PCB) load reduction requirements in Provisions C.11 and C.12 of the MRP 2.0. In
addition to the requirement to reduce mercury and PCB pollutant loading, MRP 2.0 also
requires construction of green infrastructure projects to reduce, over the long term, the
adverse water quality impacts of urbanization and urban stormwater runoff on receiving
waters to the Maximum Extent Feasible.
“Green infrastructure” is a term that refers to engineered structures or features that are
designed to detain stormwater runoff and remove water quality pollutants. In addition to
cleaning stormwater runoff, green infrastructure may be used to alleviate flooding, can
assist in reducing the urban heat island effect, and can be incorporated into the
streetscape in the form of bioretention areas next to streets to enhance the bicycle -
pedestrian environment.
As a milestone in the development of the GI Plan, all permittees must also approve a GI
Framework for the development of the GI Plan by June 30, 2017. The purpose of the
GI Framework is to describe specific tasks and time frames f or development of the
Green Infrastructure Plan required in MRP 2.0 Provision C.3.j..
The Alameda Countywide Clean Water Program, of which the City of Dublin is a
member agency, developed a template GI Framework for use and customization by
member agencies. The template GI Framework includes all of the MRP 2.0 required
milestones, including: 1) MRP 2.0 deadlines, 2) Specific Tasks for GI Plan
Development, 3) Time frame for GI Plan Development, 4) Staffing Assignments, and 5)
Budget. The GI Framework (Attachment 2) is a version of the template modified to
meet the needs of the City of Dublin.
NOTICING REQUIREMENTS/PUBLIC OUTREACH:
None required.
ATTACHMENTS:
1. Resolution Approving a Framework for Municipal Regional Stormwater NPDES
Permit Green Infrastructure Plan Development
2. Exhibit A to the Resolution: Framework for Green Infrastructure Plan Development
RESOLUTION NO. ____ - 17
A RESOLUTION OF THE CITY COUNCIL
OF THE CITY OF DUBLIN
* * * * * * * * *
APPROVING A FRAMEWORK FOR MUNICIPAL REGIONAL STORMWATER NPDES PERMIT
GREEN INFRASTRUCTURE PLAN DEVELOPMENT
WHEREAS, the San Francisco Bay Regional Water Quality Control Board adopted the
Second Municipal Regional Stormwater NPDES Permit (MRP 2.0) on November 19, 2015 as
Order No. R2-2015-0049; and
WHEREAS, the City of Dublin is a permittee under MRP 2.0; and
WHEREAS, Provision C.3.j of MRP 2.0 requires permittees to adopt by June 30, 2017 a
framework that describes specific tasks and timeframes for development of a Green
Infrastructure Plan; and
WHEREAS, a Green Infrastructure Plan describing how MRP 2.0 permittees intend to
include low impact development drainage design into appropriate projects on public and
private lands to meet Total Maximum Daily Load (TMDL) wasteload allocations for mercury
and polychlorinated biphenyls and to reduce to the Maximum Extent Feasible adverse water
quality impacts due to urbanization must be adopted by the City of Dublin City Council by June
30, 2019; and
WHEREAS, the goal of low impact development drainage design is to reduce runof f;
minimize land disturbance; minimize directly connected pavement and other impervious cover
to the storm drain system; and remove pollutants from urban runoff using methods that employ
natural processes of storage, detention, infiltration, evapotranspiration, and filtering of runoff
through soil media as described in Provision C.3.c of MRP 2.0; and
WHEREAS, the City of Dublin has demonstrated its commitment to an environmentally
sustainable future through its policy goals and actions, including maintaining natural hydrologic
systems, and intends to incorporate green infrastructure into projects when doing so will
benefit the environment and when a funding source for construction of green infrastructure has
been identified; and
WHEREAS, in order to be in compliance with MRP 2.0, a Framework for Green
Infrastructure Plan development has been prepared for the City of Dublin.
NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of Dublin
hereby adopts the Framework for Green Infrastructure Plan Development, attached hereto as
Exhibit A, to prepare said Green Infrastructure Plan.
PASSED, APPROVED AND ADOPTED this 20th day of June 2017, by the following vote:
AYES:
NOES:
ABSENT:
ABSTAIN:
___________________________
Mayor
ATTEST:
______________________________
City Clerk
1 June 2017
City of Dublin Framework for
Green Infrastructure Plan Development
This Framework for Green Infrastructure Plan Development is organized as follows.
Section 1: Purpose
Section 2: Municipal Stormwater Permit Deadlines
Section 3: Specific Tasks for Green Infrastructure Plan Development
Section 4: Timeframe for Green Infrastructure Plan Development
Section 5: Staffing Assignments
Section 6: Budget
Section 7: Summary
1. Purpose
The purpose of the Green Infrastructure Framework is to describe specific tasks and timeframes
for development of the Green Infrastructure Plan required in Provision C.3.j of the re-issued
Municipal Regional Stormwater Permit (Regional Water Quality Control Board Order No. R2-
2015-0049, adopted on November 19, 2015), which states in part:
…. The [Green Infrastructure] Plan is intended to serve as an implementation guide and
reporting tool during this and subsequent Permit terms to provide reasonable assurance that
urban runoff TMDL wasteload allocations (e.g., for the San Francisco Bay mercury and PCBs
TMDLs) will be met, and to set goals for reducing, over the long term, the adverse water quality
impacts of urbanization and urban runoff on receiving waters. The Plan is intended to describe
how Permittees will shift their impervious surfaces and storm drain infrastructure from gray, or
traditional, storm drain infrastructure where runoff flows directly into the storm drain and then
to the receiving water, to green….
“Green infrastructure” refers to a sustainable system that: slows runoff by dispersing it to
vegetated areas; promotes infiltration and evapotranspiration; provides for stormwater
collection and use; and incorporates bioretention and other stormwater treatment methods to
clean stormwater runoff and to help mitigate for increased stormwater flows that result from
adding impervious surfaces to watersheds. In addition to cleaning stormwater runoff, green
infrastructure may be used to alleviate flooding, can assist in reducing the urban heat island
effect, and can be incorporated into the streetscape in the form of bioretention areas next to
streets to enhance the bicycle-pedestrian environment. The most common types of green
infrastructure built in Dublin to date include bioretention areas and vegetated swales.
Permittees under the re-issued Municipal Regional Stormwater Permit (MRP 2.0) are required
to incorporate green infrastructure into storm drain design on public and private lands to meet
urban runoff total maximum daily load (TMDL) wasteload allocations for mercury and
polychlorinated biphenyls (PCBs). Mercury is a natural, ubiquitous pollutant that continues to
Framework for
Green Infrastructure Plan Development
2 June 2017
be emitted into the environment through burning of fossil fuels, waste incineration and use in
gold extraction. Mercury is highly volatile and is released to the atmosphere as a gas which is
subsequently deposited on impervious surfaces via air deposition. On the other hand, PCBs are
a class of manmade organic pollutants that were manufactured until they were banned in the
United States in 1979. Due to their non-flammability, chemical stability, high boiling point and
electrical insulating properties, PCBs were used in hundreds of industrial and commercial
applications. Although no longer commercially produced in the United States, PCBs may be
present in products and materials produced before the 1979 PCB ban. The San Francisco Bay
Regional Water Quality Control Board (Water Board) has indicated that the most likely
pathways for PCB contamination of stormwater include building demolition at old urban,
commercial or industrial sites (i.e. pre-1979) when appropriate best management practices are
not used, and sediment movement at contaminated sites. The urban runoff wasteload
allocation included in the TMDLs for both PCBs and mercury is a region-wide allocation;
however, if the PCB and mercury pollutant load reductions are not achieved on a region-wide
basis, the default allocation is based on the population of the permittee, not on the actual
pollutant load located within each jurisdiction.
Population based TMDL determination poses concerns for the City of Dublin. While Dublin will
meet the 2020 wasteload reduction requirements for both mercury and PCBs, Dublin will not
be able to meet the 2030 or 2040 wasteload reduction requirements mandated in MRP 2.0 and
the TMDL even if green infrastructure were incorporated throughout the city. The reason
Dublin will not meet the wasteload reduction requirement is because there are few known
locations of PCB contamination within the city, and potentially the City may not be contributing
to the current loadings under the population based formula. This also poses a concern for
permit non-compliance for Dublin in future re-issuances of the MRP if the population based
formula is not addressed and/or if permittees with known PCB contaminated sites are not able
to install adequate green infrastructure projects such that region-wide, the stormwater
wasteload allocations are met. In contrast, Dublin should be able to meet the 2030 and 2040
wasteload reduction requirement for mercury through the installation of green infrastructure
on planned private development projects and public projects anticipated to be constructed
during this timeframe.
In addition to the TMDLs drivers, construction of green infrastructure projects is also required
to reduce, over the long term, the adverse water quality impacts of urbanization and urban
runoff on receiving waters. The Water Board included green infrastructure mandates in
Provision C.3.j. of MRP 2.0 in lieu of expanding the definition of a C.3 Regulated project to
include all projects that create/replace 5,000 square feet or more of impervious surface area
(the current threshold is 10,000 square feet of impervious surface area) and to road projects
that only replace existing impervious surface area. Urbanization increases both pollutant load
and the volume of flow to local creeks and waterbodies as natural areas are converted to
impervious surfaces. Green infrastructure helps to mitigate the environmental impacts of
urbanization.
The purpose of the Green Infrastructure Plan required under Provision C.3.j.i.(1) of MRP 2.0 is
to guide the identification, implementation, tracking, and reporting of green infrastructure
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projects within the City of Dublin. The adoption of the Green Infrastructure Framework is an
acknowledgement by the City that it anticipates meeting the intent of MRP 2.0, specifically to
reduce pollutant load of Mercury and PCBs to local creeks and San Francisco Bay insofar as
pollutants exist within Dublin, to the extent that it can with the funding available. Funding is
discussed in more detail in Section 6, Budget.
2. Municipal Stormwater Permit Deadlines
Provision C.3.j.i.(1) of MRP 2.0 requires all permittees, including the City of Dublin, to approve a
framework to develop a Green Infrastructure Plan by June 30, 2017. The complete Green
Infrastructure Plan must be submitted to the Regional Water Quality Control Board by
September 30, 2019.
3. Specific Tasks for Plan Development
Preparation of the Green Infrastructure Plan will require the following specific tasks.
Identify Green Infrastructure Projects
Potential future green infrastructure projects will be identified for inclusion in the Green
Infrastructure Plan. This includes documentation of existing proposed plans for private and
public development projects that would be subject to MRP 2.0 Provision C.3.b. requirements to
include stormwater treatment facilities. Projects subject to MRP 2.0 Provision C.3.b.
requirements generally include: 1) new public or private projects that create/replace 10,000
square feet or more of impervious surface area, 2) new road projects that create 10,000 square
feet or more of impervious surface, 3) existing road widening projects which include a new
travel lane and create/replace 10,000 square feet or more of impervious surface area, and 4)
special land use projects (restaurants, automotive service facilities, gas stations, and parking
lots) that create/replace 5,000 square feet or more of impervious surface area. The Green
Infrastructure Plan will also document the continuing implementation and results of the City of
Dublin’s process, initiated in Fiscal Year 2015-16, to review planned capital improvement
projects that are not subject to Provision C.3.b. stormwater treatment requirements, to identify
the potential for incorporating green infrastructure pending identification of funding.
Additionally, a tool developed by the Alameda Countywide Clean Water Program (Clean Water
Program) will be used to identify, map, and prioritize potential green infrastructure projects
that may be included in the Green Infrastructure Plan.
Develop Tracking Procedures
Tools and guidance provided by the Clean Water Program will be used to develop procedures
for estimating the pollutant load reduction benefits of green infrastructure projects, and for
tracking and reporting on completed projects. The procedures will be described in the Green
Infrastructure Plan.
Incorporate Guidelines and Typical Designs
The Green Infrastructure Plan will incorporate guidelines for streetscape and green
infrastructure project design and construction, and green infrastructure typical design drawings
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and specifications. These will be based on example guidelines, typical design drawings, and
specifications provided by the Clean Water Program or other local agencies. The City of Dublin
is currently evaluating local design details and is creating typical design details, standard
specifications, and procedures as needed.
Update Planning Documents
As required, planning documents, including those listed below, will be reviewed and relevant
sections of these documents will be modified, as needed, for implementing green infrastructure
in public and private development projects to support the implementation of the Green
Infrastructure Plan. If the planning documents are not scheduled to be updated prior to Green
Infrastructure Plan development, a schedule for review will be provided in the Green
Infrastructure Plan. The review will include the following planning documents:
• General Plan, specific plans, and area plans
• Streetscape Master Plan
• Bicycle and Pedestrian Master Plan
• Commercial Corridor Design Guidelines
• Scarlett Court Design Guidelines
• Pavement rehabilitation work plan
• Parks and Recreation Master Plan
Evaluate Funding Sources
An evaluation of funding sources for both construction and operations and maintenance of
potential future public green infrastructure projects will be included in the Green Infrastructure
Plan. Guidance provided by the Clean Water Program may be used to develop an in-lieu fee for
private development projects that are constrained from fully meeting Provision C.3.b.
stormwater treatment measures onsite, as a potential funding source for future public green
infrastructure projects. The City may also want to evaluate funding sources such as community-
based public private partnerships or other funding strategies. Currently, green infrastructure
associated with public projects is paid for through the General Fund. Grant will be pursued for
projects when the timing of the project and timing of grant proposals align.
Training and Outreach
Staff will receive training on green infrastructure planning, implementation, design, and
maintenance via training sessions facilitated or provided by the Clean Water Program. Updates
and opportunities for input on the preparation of the Green Infrastructure Plan will be provided
to the City of Dublin City Council and City Manager’s Office on a regular basis. Outreach to the
development community and the general public, as necessary, will be conducted in
coordination with the Clean Water Program.
Compile Green Infrastructure Plan
Documentation of the tasks described above will be compiled into the Green Infrastructure
Plan for review and approval by the City of Dublin City Council.
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Implement the Green Infrastructure Plan
A resolution, policy, or other legal mechanism will be prepared for adoption prior to beginning
implementation of the Green Infrastructure Plan.
Address the Population-Based MRP 2.0 and TMDL Wasteload Allocations
The City of Dublin will coordinate with the Clean Water Program, the Bay Area Stormwater
Management Agencies Association and the San Francisco Bay Regional Water Quality Control
Board (Water Board) to develop a wasteload allocation formula that is based on actual
pollutant loadings rather than the current population based formula.
Submit Plan to the San Francisco Bay Regional Water Quality Control Board
The Plan, and applicable policies or other legal mechanisms for Plan implementation, will be
submitted to the Water Board with the City of Dublin’s 2019 Annual Report of Stormwater
Program Implementation.
4. Timeframe for Plan Development
The schedule for conducting specific tasks is presented below. The Green Infrastructure Plan
must be approved by City Council by June 30, 2019 and reported to the Water Board in the
Annual Report which is due on September 30 each year.
Schedule of Specific Tasks
Task FY 2016-17 FY 2017-18 FY 2018-19 FY 2019-20
Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2
Identify Projects
Develop Tracking Procedures
Incorporate Guidelines
Update Planning Documents
Evaluate Funding Sources
Training and Outreach
Compile Plan
Adopt Plan
Submit Plan to Water Board
5. Staffing Assignments
The Environmental Coordinator in the Public Works Department will direct the preparation of
the Green Infrastructure Plan. The Environmental Coordinator will manage consultants hired to
assist with the effort and will coordinate with the other City Departments/Divisions that will be
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an integral part of the Green Infrastructure Plan development including Planning, Engineering,
Maintenance, and the City Attorney Office.
6. Budget
Development of the Green Infrastructure Plan is estimated to cost approximately $250,000 in
consultant costs. Staff has initiated planning level work on the Green Infrastructure Plan in
order to inform the preparation of the Framework. Additional work will be required to
complete the document.
Estimates for design and construction costs of green infrastructure range between $30,000 to
$400,000 per treated acre for distributed green infrastructure systems. The cost variation is
due to a number of factors such as the location of the project (i.e. if the project is located in a
more or less built-out area), the amount of impervious area draining to the green infrastructure
facility, and the type of green infrastructure incorporated. The cost for regional facilities is
substantially less, ranging between $12,000 - $64,000 per treated acre. The main reason for
the price differential comparing distributed facilities to regional facilities is that economies of
scale can be achieved with regional facilities. Staff intends to purse options for siting regional
facilities in order to manage both construction and on-going operations and maintenance costs.
Estimates for on-going operations and maintenance of green infrastructure facilities range
between $1.50/square foot treatment area (not including replacement costs) and up to 6% of
construction costs. In addition to on-going, regular operations and maintenance, it is
anticipated that green infrastructure may need to be replaced every 10 – 15 years.
Replacement costs are anticipated to be much less than construction costs since the
infrastructure will already have been built; work required will include removing and replacing
vegetation, treatment soil, and underdrain components. The replacement schedule will likely
depend on the location of the green infrastructure facility, which will dictate the sediment and
pollutant load entering the facility.
The cost estimates provided in this section were derived from local Bay Area municipalities,
Southern California municipalities, the City of Portland, the City of Tacoma, WA, and the
Environmental Protection Agency.
Summary
The Environmental Coordinator will manage the Green Infrastructure Planning effort required
under MRP 2.0 on behalf of the City of Dublin. The City of Dublin will endeavor to construct
green infrastructure on public projects where pollutant loads warrant and where funding has
been identified. City staff will continue to require private development projects subject to
Provision C.3.b of MRP 2.0 to incorporate green infrastructure into applicable projects. City
staff will pursue funding options other than the General Fund to assist with Green
Infrastructure implementation. The City of Dublin is not committing any funds towards green
infrastructure construction with the adoption of this Green Infrastructure Framework; rather, it
is committing to initiating the process to complete a Green Infrastructure Plan.