City of Los Angeles Bureau of Sanitation
LWA has provided the City of Los Angeles (City) Bureau of Sanitation (LASAN) with regulatory consulting services since the late 1990s. LWA has supported the City develop effective policy and technical solutions for their wastewater and stormwater programs, including the following stormwater program support:
- Reviewed, commented, and supported negotiations on the following TMDLs developed by the State and/or USEPA: Machado Lake Toxics TMDL, Santa Monica Bay Marine Debris TMDL, and Los Angeles Area Lakes TMDLs.
- Developed alternative approaches to for Dominguez Channel and LA/Long Beach Harbors Toxics TMDLs. Identified solutions to address LASAN concerns with the TMDL that were acceptable to the State and resulted in revisions to the TMDL that support development of additional science for the TMDL reopener while maintaining compliance with interim requirements. Supported negotiations with the State, USEPA, and other dischargers and provided support developing testimony for the adoption hearing.
- Supported LASAN during negotiations with the State on revisions to the Santa Monica Bay Dry and Wet Weather Bacteria TMDLs and the Marina del Rey Bacteria TMDL. Conducted analysis of bacteria data, proposed updates for consistency with the latest available science, reviewed and commented on draft TMDL documents, and provided support developing testimony for the State adoption hearing.
- Developed strategy and conducted technical analysis in support of TMDL revisions for the Ballona Creek Toxics, Metals, and Bacteria TMDLs. Analysis included evaluating compliance with current TMDL targets, proposing revisions to targets based on the latest available data, proposed updates to compliance language to allow for multiple methods for compliance, and developed information to support the extension of the Toxics TMDL compliance deadline. Supported negotiations with the State, including developing testimony for the State adoption hearing.
- Managed and conducted monitoring to evaluate bacteria loading in three watersheds from urban runoff. The monitoring included up to three teams deploying during dry weather to monitor all flowing outfalls for flow rates and coli concentrations to determine loadings to support implementation planning.
- During the development and adoption of the 2012 Los Angeles County MS4 Permit, LWA provided regulatory support to the majority of the Permittees in the County via contracts with the City of Los Angeles, Los Angeles Permit Group, and County of Los Angeles. LWA participated from the beginning of the adoption process and developed several approaches that were utilized by the Regional Board as the basis for key permit sections, including (1) the watershed-based permit structure, (2) BMP-based compliance options for interim TMDL wasteload allocations, (3) utilizing the Watershed Management Programs as a compliance option for the Receiving Water Limitations provisions, and (4) the development of the Watershed Management Program concept that incorporates all elements of the Permit, but allows Permittees to focus efforts on identified water quality issues in the watershed by prioritizing and modifying certain Permit requirements. LWA identified modifications to the current stormwater management programs, developed the suggested framework and content for the watershed plans, and provided justification to modify the previous permit structure to accommodate the proposed watershed based approach via modifiable minimum control measures and monitoring requirements. LWA’s development of materials demonstrating the proof of concepts and incorporating the range of Permittee perspectives enabled the Permittees and RWQCB to find common ground on difficult issues.