Sarah Holcomb Environmental Scientist New Mexico Environment Department

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1 Sarah Holcomb Environmental Scientist New Mexico Environment Department

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3 The Land of Enchantment

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5 Stats about MRG Rainfall 9.47 inches/year Monsoon July-October Population 794,125 people in Bernalillo/Sandoval Counties One of 4 states without NPDES Primacy

6 Current Albuquerque Area MS4s One Phase 1 permit City of Albuquerque NM Dept of Transportation University of New Mexico AMAFCA (Albuquerque Metro Arroyo Flood Control Authority) Nine Phase 2 entities Kirtland Air Force Base NM Dept. of Transportation City of Rio Rancho Village of Los Ranchos de Albuquerque Village of Corrales Town of Bernalillo Bernalillo County Sandoval County SSCAFCA (Southern Sandoval County Arroyo Flood Control Authority)

7 Current MS4 Status Albuquerque Phase 1: Applied for their permit in 1991, received it in Still waiting for second issuance of their permit, which expired in EPA Audit Albuquerque Phase 2s: Started permitting process in 2007 KAFB received coverage immediately NMDOT, Rio Rancho, Los Ranchos, Bernalillo County, Sandoval County and SSCAFCA just received their coverage in May Town of Bernalillo may need individual permit Corrales is working on NOI issues.

8 March 2010 The MS4 permittees in the MRG have a conference call with EPA. EPA Region 6 announces that they ve nominated and received HQ approval for the area for a permitting pilot. After some initial discussions, the group and its purpose slowly started to take shape.

9 How did we get here? EPA commissioned National Academy of Sciences to review National Stormwater Program in NRC Report October 15, 2008 Urban Sprawl/Flood management approach. Regs leave compliance discretion to permittee. Discharges regulated as individual, not part of a whole. NPDES relies heavily on paperwork. Limited information available on BMP effectiveness Lack of staff to actually implement the program. Recommendations

10 Pilots Ramsey Washington Watershed District Milwaukee Metro Watershed Middle Rio Grande, Albuquerque, NM 10

11 What does Watershed Permitting mean? Geographically Based Outside the Box approach Benefits Basin wide permit synchronization Staff and resources Enhances efficiency More effective and equitable permit limits because of cooperation between agencies Challenges Non-point sources TMDL issuance timelines Initial permit development costs and time allocation Cooperation in general

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13 3 Tribal Entities Urbanized Areas 2 Counties Watershed Boundary Watershed bounded by Angostura diversion, Isleta Pueblo, Sandia Mountains, and Rio Puerco Drainage. 3 Flood Control 6 Municipalities Rural Areas Federal Facilities

14 Permittees City of Albuquerque City of Rio Rancho Bernalillo County Sandoval County UNM Dept. of Safety, Health and Environmental Affairs AMAFCA (ABQ Metro Arroyo Flood Control Authority) SSCAFCA (Southern Sandoval County Arroyo Flood Control Authority) ESCAFCA (East Sandoval County Arroyo Flood Control Authority) * NM Department of Transportation District III Town of Bernalillo Village of Tijeras Village of Carnuel (Bern Co) * Los Ranchos de Albuquerque Village of Corrales Village of Placitas (Sandoval County) * Pueblo of Sandia * Pueblo of Isleta * Pueblo of Santa Ana * State Fairgrounds/EXPO NM * Sandia National Labs/USDOE * Kirtland AFB MRGCD * 14

15 Coordination Efforts 14 presentations to City Councils, County Commissions, other organized boards Monthly meetings with potential permittees to discuss permit/what needs to be done. State of NM and a hired facilitator run the meetings.

16 Issues to Address TMDLs, 303(d) list pollutants Implementation of arid-appropriate Green Infrastructure/LID Techniques Water Rights Issues Contribution of unregulated areas outside the urbanized boundary, estimating their stormwater contribution to the TMDL/303(d) pollutants Discharge to drinking water areas Endangered and Threatened Species Discharge to Tribal waters EPA 2012 Stormwater Rulemaking

17 TMDL MRG fecal coliform TMDL (2002) MRG Microbial Source Tracking Study (2005) WQS changed in 2005 MRG E. coli TMDL (2010)

18 Arid Appropriate GI/LID

19 Water Rights Compact Obligations 8 interstate compacts NM must comply with, plus Mexico. Surface runoff is part of NM s water supply. All surface water in NM is fully appropriated. Impoundments NMAC Rainwater harvesting

20 Unregulated Areas Baseline Study Determine 303(d) pollutants coming into the watershed

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22 EPA s 2012 Stormwater Rulemaking Green Infrastructure/LID Infiltration/Evapotranspiration/Reuse Performance Standards (GI/LID) Expanding the Universe of MS4s Exploring different requirements for transportation facilities Exploring options for establishing municipal retrofit requirements for MS4s. Additional provisions for the Chesapeake Bay.

23 More Issues: COOPERATION! Funding agreements Sampling/Baseline Study Green Infrastructure/Water Rights Enforcement/Ordinances Stormwater Utility? Equity amongst permittees Storm Water Management Program (SWMP)

24 Permit Issuance Goal: July 2012 General Permit Each jurisdiction submits an NOI Joint SWMP (or two?) Joint and Individual Actions on 6 Minimum Measures Monitoring Requirements most likely carried over from traditional Phase 1/Phase 2.

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