HomeMy WebLinkAboutMINUTES - 01072003 - C129 C.129
THE BOARD OF SUPERVISORS OF
CONTRA COSTA COUNTY, CALIFORNIA
Adopted this Order on January 7, 2003, by the following vote:
AYES: Supervisors Uilkema, Gerber, DeSaulnier, Glover& Gioia
NOES: None
ABSENT: None
ABSTAIN: None
SUBJECT: AUTHORIZE the Chair, Board of Supervisors, to sign a letter to the San
Francisco Bay Regional Water Quality Control Board requesting the
Regional Board not amend Contra Costa County's National Pollutant
Discharge Elimination System (NPDES)permit at this time,but to wait
until the permit is to be renewed in 2004.
RELISTED to undetermined date.
I hereby certify that this is a true and correct
copy of an action taken and entered on the
minutes of the Board of Supervisors on the
date shown.
Attested: January 7, 2003
John Sweeten, Clerk of the Board
Of Supervisors and County Administrator
Deputy Clerk
TO: BOARD OF SUPERVISORS V.!
FROM: SUPERVISOR JOHN GIOIA,DISTRICT I
DATE: JANUARY 7, 2003
SUBJECT: CONTRA COSTA COUNTY'S NATIONAL POLLUTANT DISCHARGE ELIMINATION
SYSTEM PERMIT AMENDMENT
I. Recommendation:
AUTHORIZE the Board of Supervisors to sign a letter to the Regional Water Quality Control Board requesting
Contra Costa County's National Pollutant Discharge Elimination System.(NPDE$),permit not be mended at
this time but to wait until the permit is to be reissued in July 2004.
U. Financiallmpact:
The amendment of Contra Costa County's NPDES permit to include new development standards that will have a
significant financial impact on the County and the cities in the County. The exact cost implication to the County
is not known, although experience in other counties in Southern California has indicated the costs to be
significant. These permit requirements were first required in Southern California in the last two years and
communities have been trying to estimate what the costs will be. Earlier this year the City of San Diego
estimated that the cost to comply with their new permit requirements for the first five years would be 27 million
the first year, $55 million the second year,and about$50 million for each of the next three years. The City of
Continued on Attachment: X SIGNATURE: ��A74n= _
RECOMMENDATION OF COUNTY 75MINIST14ATOR
RECOMMENDATION OF BOARD COMMITTEE
—APPROVE OTHER
SIGNATURE(S): -
ACTION OF BO2003 APPROVED AS RECOMMENDED x_OTHER
I hereby certify that this is a true and
correct copy of an action takers and
entered on the minutes of the Board
VOTE OF SUPERVISORS of supervisors on the date shown.
UNANIMOUS(ABSENT 1
AYES: NOES:
ABSENT: ABSTAIN:
ATTESTED: �Ta tam 7,_ tong --
% AAz JOHN SWEETEN Cleric of the
G:\GrpDatolAdmin\Mftch\bo120031Ctean'4Water Permit-410CS
Ori%.Div: Public Works(Adttvn Services) Board of Supervisors and County
Contact: Mitch Avalon(3-2203) Administrator
cc: Don Freitas,Clean Water
John Sweeten,CAD
Dennis Barry,Cbt)
Carlos Baltodano,SiD
Jinn Kennedy,Radevelopment
Ken Stuart,Environmental Stealth By � Deputy
Ed Meyers,Agriculture JJ
Silvano Marchesi.County rnusei
Stan Matsurmto,Flood Control
Joe Calabrigo,Danville Town Manager
John Wolfe,Taxpayers Association
SUBJECT: COMMENTS ON THE SAN FRANCISCO BAY REGIONAL WATER.QUALITY CONTROL
BOARD'S (SFBRWQCB)PROPOSED AMENDMENT TO CONTRA COSTA COUNTY'S
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM(NPDES)PERMIT
DATE; JANUARY 7, 2003
PAGE 2
San Clemente experienced almost a ten-fold increase in costs. Before the new requirements were adapted,the
City's share of their countywide program was$30,000 per year. After the new requirements were adopted,the
City's share of the countywide casts went up to$270,000 per year. Before the new requirements were adopted
the cost of the City's local clean water program was $254,000 per year. After the new requirements were
adopted the City's annual cost for their local program increased to $2 million per year.
The ether aspect of increased costs will be monitoring and maintenance of clean water facilities installed
pursuant to the new requirements. These clean water facilities will be on two different levels. Some facilities
will be constructed within a development and ether facilities will be constructed',as regional facilities. Bath
types of facilities must be monitored and managed for effectiveness to provide flood control protection and
improve water duality while at the same time not create mosquito breeding habitat. As an example of the
potential costs to homeowners for maintaining a private facility,a detention basin was constructed for a 25-lot
project in San Diego that will cost an estimated$22,000 per year to maintain. That equates to$880 per unit per
year to maintain the development's clean water facility. As we gain more experience with these clean water
facilities,we may find that regional facilities are more efficient and cost effective to maintain than a myriad of
on-site clean water facilities.However,establishing funding to maintain regional facilities maybe more difficult
than requiring homeowners to maintain on-site facilities.
The Clean Water Program is an unfunded Federal mandate. We fund our Clean Water activities in the
unincorporated County,and fund our share of the Joint Municipal permit costs,through a local assessment paid
by the property owners in the unincorporated County. The statutory authority to establish and collect the
assessment for the County and the cities is through the County's Flood Control and Water Conservation District.
The County is currently at the maximum assessment that we can charge,and the program costs associated with
the new requirements will require us to increase our existing assessments or develop other revenue sources. The
assessment for a standard residential unit is currently$30 per year. Most ofthe cities in the Contra Costa Clean
Water Program are also at or near their maximum assessments. Increasing the existing assessment will require a
vote in accordance with Proposition 218. The assessment may have to be doubled or tripled(or maybe higher)
to fund the new clean water requirements. If the voters refuse to increase the assessment,then the County will
have to fund the increased casts from another source. Since restricted funds can't be used,as they are restricted
to specific programs,unrestricted revenue would have to be used. This would mean using the County's General
Fund or applying for grant monies. Grant revenue is unpredictable at best, so the primary reliance for funding
would be the General Fund.
III. Reasons for Recommendations and Background
In October of 2001 the San Francisco Bay Regional Water Quality Control Board(SFBR.WQCB)renewed Santa
Clara Valley's NPDES permit. This permit included new development standards. Contra Costa County's
current NPDES permit is not scheduled to be renewed for two more years. However,Santa Clara claimed that
there was an uneven playing field in the Bay Area if they were the only county to have these new clean water
requirements. As a result,the Regional Board is proposing to amend our NPDES permit to include these new
development standards for clean water.
SUBJECT: COMMENTS ON THE SAN FRANCISCO BAY REGIONAL WATER QUALITY CONTROL
BOARD'S (SFBRWQCB)PROPOSED AMENDMENT TO CONTRA COSTA COUNTY'S
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM(NPDES)PERMIT
DATE: JANUARY 7, 2003
PAGE 3
The Regional Board prepared and submitted to Contra Costa County a tentative order for an amendment to our
permit. The Regional Board conducted a hearing on our tentative order on December 18,2002. There were 36
people who commented on our permit amendment. Many of the comments from the cities and the County
stressed the costs associated with these new requirements and concern over the Regional Beard not knowing the
full extent of the financial impacts that would be associated with these new requirements. At the time we were
giving testimony on December 18,2002,the budget deficit at the State was understood to be 21 billion dollars
and the County's budget projections were based upon that amount. Governor Davis has recently announced that
the deficit has increased to 35 billion dollars. This will greatly impact the County's already dismal budget
forecast. Given this tremendous increase in the State deficit, and the certainty that the solution to solving the
State's deficit will fall partly on local government, it would be prudent not to increase costs for cities and
counties at this time.
Attached is a letter to the Regional Water Quality Control Board requesting that they not amend our permit at
this time and that they renew our permit when it is up for renewal in 2004. It should be pointed out that the
Regional Board is under no obligation to amend our permit at this time. The amendment is simply to honor a
commitment to Santa Clara County to even the playing field in the Bay Area. If the Regional Board does not
amend our permit at this time,the County will commit to the following activities between now and the time our
permit is due for renewal.
1. Santa.Clara County Coordination: We will work with Santa Clara County in their efforts to develop a
Hydrograph Modification Management Plan and other activities they are pursuing to address the new clean
water requirements.
2. Hydrograph Modification Management Plan:The County will apply for a grant to perform a Hydrograph
:Modification Management Plan on at least one watershed in the County. Development of this Hydrograph
Modification Management Plan and any lessons that we learn along the way will be shared with the other
counties in the Bay Area. Developing a Hydrograph Modification Management Plan for one of Contra Costa
County's watersheds will greatly facilitate the development of more meaningful permit requirements with
the Regional Board when our permit is up for renewal.
3, Developer Fees: Some of the new permit requirement costs can be passed on in the form of developer fees.
The County will identify what activities can legally be charged against the development of property and
prepare a report to amend developer fees to help fund the new clean water requirements. In the past it has
taken twelve months to go through the process to revise development fees,so the report will be completed in
time for the permit renewal. Once the permit is renewed,the revised fees can immediately be put into place.
4. Program Funding: The County will continue to advocate for and participate in efforts to identify new
sources of funding for clean water activities. Legislation, such as Assembly Bill 104 by Assemblyman Joe
Nation,may provide opportunities to fund clean water activities.
IV.Consequences of Negative Action
A letter to the Regional Water Quality Control Board expressing the Board's position on the County's NPDES
permit amendment would not be sent.
_. .
. ........................................
DRAFT ##2
December 31, 2002
(Note: setter will be finaled
after receiving comments from
cities since any action we
commit to will be expected
of the cities too)
January 7, 2003
San Francisco Bay Regional Water Quality Control Board
1515 Clay Street, Suite 1400
Oakland, CA 94612
SUBJECT: Contra Costa County's NPDES Permit Amendment
Dear Regional Board:
This letter is to formally request that the San Francisco Bay Regional Water Quality Control Board
delay amending Contra Costa County's NPDES permit to add the proposed new development
standards (Section C3). Contra Costa County respectfully requests the Regional Board consider
adopting the new development standards when our current permit is scheduled for re-issuance in July
of 2004.
As you are aware,Contra Costa County's current National Pollutant Discharge Elimination System
(NPDES)permit is scheduled to be re-issued in 2004. The Regional Board is currently considering
an amendment to Contra Costa County's permit to include new development standards(Section C3).
The intent is to make the current Contra Costa permit consistent with the development standards
required in the permit issued to Santa Clara County last year.
Contra Costa County has funded its Clean Water Program through an assessment on each parcel in
the County since 1993.The Flood Control District established this parcel assessment in cooperation
with the County and the incorporated cities to fund the requirements of the Phase I NPDES permit
issued by the San Francisco and Central Valley Regional Boards. The Flood Control District
established the parcel assessment with a range of assessments that could be assessed on the parcels
within each city and the County. The parcel assessments for the first year for each city and the
County were the lowest assessment in the assessment range. Since its inception in 1993, each city
and the County have increased the parcel assessments in their communities to accommodate the
increased costs of the joint program and the increased costs of individual program as a result of the
continually escalating requirements established by the Regional Board and its staff. Today the
County and the cities in the County are at or near their maximum assessment($30 per parcel in the
County). Any new increase in costs to the program as a result of the proposed permit amendment
will need to be funded from some other source. It should be remembered that the County's parcel
assessment was established prior to the passage ofProposition 218 in 1996.Any subsequent increase
in our parcel assessments would have to be approved by the voters. Given the current economy it is
almost certain that any effort to secure voter approval to increase the parcel assessment would be
unsuccessful.
When the Regional Board opened the public hearing on the proposed amendment to Contra Costa
County's permit on December 18,2002,the State budget deficit was estimated to be$21 billion.The
current budget deficit for Contra Costa County stands at $50 million. When the last budget crisis
occurred in California,the State implemented the Education Revenue Augmentation Fund(ERAF)
and began raiding local government revenue to meet State requirements for funding education
programs. This began in 1993 and has resulted in the State taking hundred million in
revenue from Contra Costa County over the last ten years.
We anticipate that to resolve the current State budget crisis, the State will again institute an
"appropriation"of local government revenue to finance State programs. If it is the same magnitude
as it was 1992, it will double the losses the County has suffered since then. The Governor has
recently announced that the State budget deficit has risen from $21 billion to $35 billion. At the
December 18, 2002 bearing before the Regional Board, Contra Costa County and the cities were
extremely concerned about the State budget impact on their city and County finances.The Regional
Board heard a great deal of concern about the costs implicit with the new development standards
required of the NPDES amendment.Now with the State budget deficit almost doubling,the County
and cities have absolutely no flexibility to add any program that increases cost whatsoever,regardless
of hover noble a program it might be.
.The Flood Control District,which is a major participant in the County's Stormwater Management
Programs,can serve as an example of how the vagaries of California fiscal policies can effect local
program funding. When Proposition 13 was passed in 1978, the District's annual revenue was
reduced by 58%, as the tax rates were reduced to accommodate a 1% ceiling on the assessed
valuation of property. In 1992 when the State instituted the ERAF program, the District's annual
revenue was reduced by$500,00(}.The District's annual revenue at that time was ,so the
ERAF"appropriation"represented a %reduction in annual revenue.The Flood Control District
currently receives approximately$4,400,000 in property tax revenue each year for the District and its
Flood Control Zones.If the State institutes an"appropriation"of local revenue equivalent to ERAF
to deal with the current budget crisis, then the District will see an additional $
reduction in annual revenue.
The next two years will be extremely difficult for the County, the cities, and the State to work
through the budget crisis. Given the evolving climate in the State budget and its implications for
local government finances, it is imperative that the Regional Board not amend Contra Costa
County's NPDES permit at this time but instead to consider adding the new development standards
to the permit when it is up for re-issuance in 2004. This sentiment is also shared by the cities in the
County.
At the hearing on December 18,2002,the Regional Board asked what the cities and County would
cut in their budget if they had to reallocate funds to pay for the cost of these new clean water
requirements. For Contra Costa County,the cuts would primarily occur in the Health Services and
Social Services budget,which provides services to the neediest people in the County.This will be on
2
top of lay offs and program reductions that will need to occur in these areas to accommodate a more
than $50 million projected shortfall in Contra Costa County for fiscal year 2003-2004. For our
various cities, you heard testimony that an increase in NPDES program funding would result in
budget cuts in police and fire services.
We request that our permit not be amended at this time, however, we realize the Regional Board
would expect the County to make some progress towards the eventual implementation of the new
development standards. In the meantime, between now and the time our permit is to be reissued,
Contra Costa County will commit to the following:
• Santa Clara County Coordination: We will work with Santa Clara County in their efforts to
develop a Hydrograph Modification Management Plan and other activities they are pursuing to
address the new clean water requirements.
• Hydrograph Modification Management Plan.The County will apply for grant to perform a
Hydrograph Modification Management Plan on at least one watershed in the County.
Development of this Hydrograph Modification Management Plan and any lessons that we learn
along the way will be shared with the other counties in the Bay.Area.Developing a Hydrograph
Modification Management Plan for one of Contra Costa County's watersheds will greatly
facilitate the development of more meaningful permit requirements with the Regional Board.
when our permit is up for renewal.
• Developer Fees. Some of the new permit requirement costs can be passed on in the form of
developer fees. The County will identify what activities can legally be charged against the
development ofproperty and prepare a report to amend developer fees to help fund the new clean
water requirements. In the past, it has taken twelve months to go through the process to revise
development fees, so the report will be completed in time for the permit',renewal. Once the
permit is renewed,the revised fees can immediately be put into place.
• Program Funding: The County will continue to advocate for and participate in efforts to
identify new sources of funding for clean water activities. Legislation, such as Assembly Bill
104 by Assemblyman Joe Nation, may provide opportunities to fund clean water activities.
The County would like to work with Regional Board staff on the above activities between now and
our permit renewal.This will allow the Regional Board to have much more pertinent information in
2044 when it considers Contra Costa County's permit reissuance.
Very truly yours,
John Gioia
3
Supervisor District I
JG:RMA:lz:mw
G:\CxrpDatalA.dmin\Mitch\Clcan Water RequirementswDES permit.doc
c: John Sweeten,County Administrator
Dennis Barry,Community Development
Carlos Baltodano,Building Inspection
Ken Stuart,.Environmental Health
Maurice Shiu,Public Works Director
Mitch Avalon,Public Warks Deputy Director
Stan Matsumoto,Flood Control
Don Freitas,Clean Water Program
Tom Dalziel,Clean Water Program
Joe Calabrigo,Danville Town Manager
Clean Water Program members