SWRCB adopts IGP Amendment, pushes out effective date

By Dawn Koepke

Capitol Update, Nov. 19, 2018 Share this on FacebookTweet thisEmail this to a friend

Earlier this month, the State Water Resources Control Board (SWRCB) voted to adopt the proposed amendments to the Industrial General Permit (IGP) that incorporate total maximum daily loads (TMDL) in four regions; update monitoring requirements per the federal Sufficiently Sensitive Methods Rule; and provide two new alternative compliance options to incentivize stormwater capture and regional collaboration. Notably, significant challenges may lie ahead for responsible dischargers in the four regions covered by the IGP Amendment – San Francisco Bay, Los Angeles, Santa Ana and San Diego.

As you may recall, SWRCB staff released the proposed IGP Amendment for public review and comment December 2017 through February 14, 2018. CMTA submitted comments during that period in conjunction with the WATER Coalition that focused on a host of issues, including but not limited to:

  •  The need for an extended timeline for implementation and compliance; 
  •  Appreciation for the development of tools to assist with determining TMDL applicability and compliance, but concerns about the timing of when the tools would be available;
  • Concerns regarding the inclusion of Numeric Effluent Limits (NEL) and ability to achieve compliance; 
  • Concerns about the inclusion of Table B in Attachment 1 related to constituents of emerging concern (CEC) whereby the discharger would have to “ensure” the listed CECs are not causing a threat to the attainment of groundwater’s beneficial uses; 
  • Concerns with the design storm and drawdown requirements as being too stringent and not flexible enough to utilize the compliance options; 
  • Widespread concerns with regard to primary and secondary maximum contaminant levels (MCL) being incorporated for stormwater and groundwater infiltration; and more. 

And while staff and the Board made some revisions to the proposal, they were not responsive to all of the concerns raised and ultimately the Board moved forward with adoption. The most positive of changes was the Board’s decision to set the effective date of the TMDL requirements at July 1, 2020.

More information can be found here.

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