Issues

CICWQ White Paper:

Is the General Industrial Permit for Stormwater Discharges Applicable to Your Facility and Property?





Current Advocacy Efforts and Accomplishments

CICWQ Water Quality Policy Directives in Little Hoover Commission Report

CICWQ played a major role in 2008 in advocating for improved performance of state and regional water quality control boards. In January 2009, The Little Hoover Commission released its long-awaited report entitled "Clearer Structure, Cleaner Water: Improving the performance and outcomes at the State Water Boards." The report describes multiple directives and includes several recommendations for improving the structure and function of the Water Boards and validates many of the criticisms made by CICWQ. Notable are the report's recommendations concerning the need for consistent policy implementation among Regional Boards in areas such as low impact development, stream channel degradation control, and the use of numeric performance measurements in stormwater permit enforcement. CICWQ prepared testimony for the Commission, and CICWQ participated in multiple stakeholder meetings organized by the Commission where issues were discussed and debated.

6-month Grading Ban in Ventura County Stopped
After heavy pressure from CICWQ, the Los Angeles Regional Water Quality Control Board dropped a proposal to ban soil grading in Ventura for half the year. CICWQ used state-of-the-art graphical information system (GIS) analysis and mapping to show that more than 50% of potentially developable properties in Ventura County would be affected by the proposed ban. The Regional Board had maintained that the ban would only affect 8% of developable land.

Inclusion of Flexible MS4 Permit Provisions for Low Impact Development
A new generation of municipal separate storm sewer permits (known as MS4 permits) is under revision in California and CICWQ has led the industry and municipal permittees in advocating for flexible engineering design standards to implement new storm water control strategies called Low Impact Development site design. CICWQ has pushed hard for the full use of LID compliance measures and gained good success in getting these measures adopted in permits.

State Water Board General Construction Permit Mandate to Use Advanced Sediment Treatment Removed
Again, after heavy pressure from CICWQ, the State Water Resources Control Board removed a mandate to use expensive and often unnecessary use of advanced sediment treatment systems for handling construction site stormwater. The current Draft Construction Permit treats ATS as another tool in the contractor compliance toolbox.

Los Angeles Regional Board Triennial Review Litigation Successful
CICWQ, working with BILD (Building Industry Legal Defense Foundation) and the Coalition for Practical Regulation (CPR) successfully challenged the adequacy of the Los Angeles Regional Board's Basin Plan. The Plan was never properly updated after 1987 when the Clean Water Act was amended to include storm water control. An administrative record review performed by CICWQ clearly showed the Regional Board never considered the dynamic nature of stormwater in setting Basin Plan water quality standards and the regulations based on these standards.