We all support improved water quality and stormwater runoff control, but many of the proposed changes to the proposed Permit are extreme, impractical, in some cases conflict with local regulations, and would add delays and increased costs to schools, roads, businesses and homes. Even the Water Board's own Blue Ribbon panel of stormwater experts agreed that certain requirements in the permit may be impracticable.

We believe there's a better way to accomplish the goal of cleaner water. Instead of making extreme revisions and pursuing stormwater runoff regulation on a project-by-project basis as is currently the case, a better approach would be to build upon proven and more effective Best Management Practices (BMPs), and pursue a big picture framework to improve overall water quality and promote increased cooperation and collaboration among all watershed stakeholders including: regional water boards, local governments and the private sector.

Californians for Improved Water Quality is coalition of business, labor, local government, and others that supports tough standards for water quality and stormwater runoff but believes the proposed Permit goes in the wrong direction.

Here are a few reasons why we oppose the proposed Permit:

Increased Costs for New Roads, Schools, Homes and Businesses

• It's estimated the cost to comply with the proposed Permit would run as high as $30,000 to $50,000 per acre - adding hundreds of millions of dollars onto the cost of building roads, schools and other infrastructure, and tacking tens of thousands of dollars onto the cost of every new home and business.

Increased Costs Will Negatively Impact Voter-Approved Infrastructure Bonds

• The proposed Permit would put at risk more than $30 billion of voter-approved funding for building schools, roads, levees and water systems - causing delays and increasing taxpayer costs. Successful Current Practices Replaced Without Evidence They Are Ineffective
  
  
• The Water Board proposes overhauling 15 years of successful BMPs without presenting any evidence the current system is deficient.
  
  
• The proposed Permit mandates costly procedures, whether needed or not. And in some cases, complying with provisions of the proposed Permit could actually be in conflict with local regulations.
  
  
• The proposed Permit also goes against the recommendations of a state-commissioned Blue Ribbon panel of stormwater experts which cited the impracticality of the some of the proposals made by the Water Board.

Steps Must be Taken Before Final Permit is Proposed

Clearly, there is widespread and diverse concern with proposed Permit.
Before finalizing the permit, the Water Board should:

• conduct an economic-impact analysis which includes an assessment of the effect of these regulations on infrastructure and other public works projects;
  
  
• report its findings on the economic-impact analysis as well as its progress in working with stakeholders to the Legislature and the Governor; and
  
  
• bring all affected stakeholders to the table to a) discuss the perceived deficiencies of the current system; and b) work on the development of improved stormwater runoff management procedures, as appropriate.

Public Agencies, Business & School Groups Have Strong Concerns About the Preliminary Draft Stormwater Construction General Permit
The quotes below are from letters submitted to the State Water Resources Control Board. Letters were submitted at the request of the Water Board to provide comment on the Preliminary Draft Stormwater General Construction Permit.

Increased Costs for New Roads, Schools, Homes & Businesses

"...we are concerned that the Preliminary Draft will result in significant and unwarranted delays in the construction of private and public projects throughout the Los Angeles area, including the many major infrastructure improvements planned and needed for the region, without any commensurate benefit to water quality."
              --Los Angeles Area Chamber of Commerce

Increased Costs Will Negatively Impact Voter-Approved Infrastructure Bonds

"...the Department is concerned about increased costs and potential delays to construction that may result from the adoption of this preliminary draft permit."
              --California Department of Transportation (CalTrans)

"[The Draft Permit] will result in an increase in the time and cost of construction for school districts, making it difficult for some schools to meet their student housing needs. C.A.S.H. believes that an Œenhanced BMP' approach would be more effective than the approach proposed in the revised CGP."
              --Coalition for Adequate School Housing
              (Representing nearly 500 California school districts)

Successful Current Practices Replaced Without Evidence They Are Ineffective

"The Preliminary draft suggests that the regulation of stormwater from construction sites has been a failure, when the reality is one of notable success. The challenge for the State Board is to bring about more uniform performance of existing best practices - not to scrap the current program which has proven effective when implemented properly."
              --Orange County Business Council

"One concern is the introduction of major changes to the way construction projects are managed without first demonstrating how these same problems are not adequately addressed by the current general permit."
              --California Department of Transportation (CalTrans)

Steps Must be Taken Before Final Draft Permit is Proposed

"While CASQA agrees that elements of stormwater programs can be improved and has suggestions for doing so, the regulatory approach utilized by the state must be carefully considered and developed within an overarching statewide policy so that there is clear direction instead of a permit by permit ad hoc approach."
              --California Stormwater Quality Association

"A statewide stormwater policy is needed before changing the course of regulation with this permit."
              --Coachella Valley Water District

Californians Against Costly and Inconsistent Stormwater Regulations
1121 L Street, Suite 803 | Sacramento, CA 95814 | Phone: 916-443-0872 | Fax: 916-442-3510