HomeMy WebLinkAboutDocumentation_Environmental Advisory Committee_Tab 03_6/9/2021Agenda Item #3.
Environmental Advisory Committee (EAC)
STAFF MEMO
Meeting: Environmental Advisory Committee (EAC) - Jun 09 2021
Staff Contact: Thomas Bradford, EAC Chair Department:
Review of Draft Recommendations to the EAC on the Utilities Element, Sub Element Stormwater
Management, of the Comprehensive Plan for Consideration of the Village Council and Staff
SUMMARY:
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3 Backup Memo Utilities Ele Sub Ele Stormwater Mang. 060921
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Agenda Item #3.
Memo
To: Environmental Advisory Committee Members
From: Thomas G. Bradford, Chair, EAC
cc: NA
Date: June 2, 2021
Re: Review of Draft Recommendations to the EAC on the Utilities Element,
Stormwater Management Sub -Element, of the VOT Comprehensive Plan for
Consideration of the Village Council and Staff
VOT Resolution No. 24-19, which created the EAC, requires the EAC "...to within the bounds of
the Village's Comprehensive Development Plan, develop recommendations for goals, objectives
and policies relative to sustaining and improving the environment of the Village of Tequesta." To
this end, the EAC is now reviewing the Utilities Element of the VOT Comprehensive Plan. The
Utilities Element contains four sub elements entitled Sanitary Sewer, Solid Waste, Potable Water
and Stormwater Management. In order to keep the review process manageable only one or two of
the sub elements will be reviewed at each EAC meeting. This memo addresses the Stormwater
Management Sub -Element. Items highlighted in yellow are noted places where an environmental
matter is stated in the Element or sub element.
You are encouraged to review the Element or sub -element and propose where you see
environmental issues requiring EAC review potentially overlooked in this memorandum or make
suggestions on how to modify or add to the comments and options provided herein to consider for
recommendation to the Village Council and staff. The link to the VOT Comprehensive Plan is as
follows:
http://tequesta.org/84/Communiiy-Development
Pertinent sections pertaining to environmental issues within the Utilities Element, Sub Element
Stormwater Management of the VOT Comprehensive Plan and my comments are as follows:
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Agenda Item #3.
UTILITES ELEMENT, POTABLE WATER SUBELEMENT
Goal 1.0.0. Economical, sustainable, efficient and effective networks stormwater drainage
facilities and services.
TGB Comment: Sustainable stormwater management is an alternative to the traditional piped only
approach. It promotes onsite collection and conveyance of stormwater from roofs, parking lots,
streets, and other surfaces to infiltrate into the ground or collect for reuse, often reducing the need
for costly underground structures. The strategy recognizes the relationship between the natural
environment and the built environment, and manages them as integrated components of a
watershed. The approach relies on things like vegetated natural systems to slow and filter the water.
Vegetation enhances both interception and evaporation of rainfall through its leaves. Vegetation
reduces stormwater runoff volume as well as pollutants in urban runoff.
Studies show that natural landscaping at a residential development can reduce annual stormwater
runoff volume by as much as 65%. Natural drainage and native landscaping areas in residential
developments can remove up to 80% of the suspended solids and heavy metals, and up to 70% of
nutrients like phosphorous and nitrogen from stormwater runoff. 1 Sustainable stormwater
management uses both structural devices such as rain barrels, cisterns, and planters, and non-
structural devices like landscaped swales and infiltration basins. The sustainable approach is cost
effective and attractive. It also addresses erosion, water pollution, combined sewer overflows and
other stormwater runoff problems all at once.
EAC Proposed Options: Options to consider for recommendation to the Village Council and staff
are:
1) Tequesta should mandate more use of natural landscaping on all new developments,
including Village street and right-of-way projects, as a proactive, low cost means of
reducing stormwater runoff and associated pollution. See Policy 1.3.3 below.
2) The Village could mandate or incentivize use of rain barrels, cisterns, and planters, and
non-structural devices like landscaped swales and infiltration basins, with reduced annual
stormwater assessments and reduced permit fees as the incentive.
3) The Village, for all new residential development or for renovations falling within adopted
threshold requirements2, require the first 2 inches of rainfall to be held on the property
1 City of Portland, OR, Department of Environmental Services, Why Sustainable Stormwater Management Matters
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Agenda Item #3.
and/or use of other stormwater on site capture options.3 How they accomplish this may be
up to the property owner, but innovation will result to meet the adopted standard.
Objective: 1.1.0 - The Village shall incorporate and annually update its five-year schedule of
stormwater drainage capital improvement projects into its Capital Improvements Schedule. Capital
Improvements needs are defined as:
(1) those public drainage improvements necessary to correct existing deficiencies in order to
maximize the use of existing facilities while maintaining the adopted Level of Service; or
(2) those public drainage improvements necessary to meet projected future needs based upon the
adopted Level of Service without encouraging urban sprawl, and/or;
(3) improvements that will otherwise assist in the achievement of Comprehensive Plan goals,
objectives and policies.
TGB Comment: See EAC proposed options below.
EAC Proposed Options: Incorporate sustainable stormwater management alternatives to the
traditional piped only approach wherever possible. Options to consider for recommendation to the
Village Council and staff are: See the following Comprehensive Plan, Utilities Element,
Stormwater Management Sub -Element policies enumerated herein, and the options recommended
by the EAC that should also receive 5-Year CIP inclusion, in addition to traditional infrastructure
funding allocations to ensure necessary funding for compliance: Policy 1.2.2; Policy 1.2.5; Policy
1.2.6; Policy 1.2.7; Policy 1.2.8; Policy 1.3.3; and, Policy 1.3.4.
Policy: 1.1.1- The Village Stormwater utility shall maintain a 10-year Capital Improvements
schedule for storm water facilities as a guideline for planning facilities over the long term.
TGB Comment: Admirable, but hard to see beyond 5 years with accuracy. Where is this 10-year
plan?
EAC Proposed Options: Incorporate sustainable stormwater management alternatives to the
traditional piped only approach wherever possible. Options to consider for recommendation to the
Village Council and staff are: See the following Comprehensive Plan policies that should also
receive 5-Year CIP inclusion, in addition to traditional infrastructure funding allocations to ensure
necessary funding for compliance: Policy 1.2.2; Policy 1.2.5; Policy 1.2.6; Policy 1.2.7; Policy
1.2.8.; Policy 1.3.3; and, Policy 1.3.4.
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Agenda Item #3.
Policy: 1.2.2 - The Village shall continue its efforts to increase on -site retention/detention capacity
of drainage basins in order to minimize to the extent possible stormwater runoff to the Loxahatchee
River and Intracoastal Waterway.
TGB Comment: What is the Village currently doing to increase on -site retention/detention
capacity of Village drainage basins?
EAC Proposed Options:
(1) Enforce Policy 1.3.3 below in regard to all development and/or redevelopment activities
associated with onsite drainage facilities that shall be designed and reviewed to maximize
nonstructural techniques (i.e., on -site retention and/or detention, use of pervious surfaces, swale
areas, native vegetation and Xeriscape landscaping).
(2) For all new residential development or for renovations falling within adopted threshold
requirements4, require the first 2 inches of rainfall to be held on the property and/or use of other
stormwater on site capture options.5
Policy: 1.2.3- The Village shall require new developments to limit post -development runoff rates
and volumes to pre -development conditions.
TGB Comment: The Village should enumerate what options are deemed acceptable for meeting
this requirement.
EAC Proposed Options: Options to consider for recommendation to the Village Council and staff
are: To facilitate compliance enumerated in the Code, the following:
(1) Enforce Policy 1.3.3 below in regard to all development and/or redevelopment activities
associated with onsite drainage facilities that shall be designed and reviewed to maximize
nonstructural techniques (i.e. on -site retention and/or detention, use of pervious surfaces, swale
areas, native vegetation and Xeriscape landscaping).
(2) For all new residential development or for renovations falling within adopted threshold
requirements6, require the first 2 inches of rainfall to be held on the property and/or use of other
4
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Agenda Item #3.
stormwater on site capture options.?
Policy: 1.2.4- The Village shall protect and preserve water quality by use of construction site
Best Management Practices;(BMPs) and the incorporation of techniques such as on -site retention
and/or detention, use of pervious surfaces, native vegetation and Xeriscape Landscaping
practices when considering all proposals for development and/or redevelopment.
TGB Comment: Tequesta is required to have a written SOP implementing a pre -construction site
plan review program pertaining to construction site runoff per its MS4 Permit, part of the
NPDES.
The greatest water pollution threat from soil -disturbing activities such as construction is the
introduction of sediment from the construction site into storm drain systems or natural receiving
waters. CALTRAN indicates a three -pronged approach is necessary to combat this stormwater
threat, as follows:
Temporary soil stabilization practices reduce erosion associated with disturbed soil areas
(DSAs).
Temporary run-on control practices prevent storm water flows (sheet and concentrated)
from contacting DSAs.
Temporary sediment control practices reduce sediment caused by erosion from entering a
storm drain system or receiving water.
EAC Proposed Options: Options to consider for recommendation to the Village Council and staff
are:
Adopt and enforce Construction Site BMP's as soon as possible. Sources for such BMP's are listed
below. If the Florida Building Code enumerates BMPs for stormwater runoff and quality control
at construction sites, such code sections should also be placed in the Village Code of Ordinances
for easy public access. Otherwise, use the sources below to develop construction site BMPs for
codification.
http: //64.130.42.93/professional/Stormwater-bmpmanual.pdfpgs.5-44
https://www.sfwmd.gov/sites/default/files/documents/bmp_manual p page 29.
https://www.Wa.gov/sites/production/files/2015-10/documents/sw swppp guide.pdf
Policy: 1.2.5 - The Village shall maintain levels of pollutants at all outfalls within its jurisdiction
into the North and Northwest Forks of the Loxahatchee River as part of its "Wet Weather"
Sampling regulations of the National Pollutant Discharge Elimination System Stormwater
Permitting Program.
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Agenda Item #3.
TGB Comment: Perhaps the Village should consider reducing levels of pollutants at all
referenced outfalls? According to the Tequesta MS4 permit, Part VIII, A, "the stormwater
management program must be designed and implemented to reduce the discharge of pollutants
from each permittee's MS4 to surface waters of the State to the MEP." A copy of the Palm
Beach County MS4 permit, of which Tequesta is a party, can be viewed at the following link:
ht!p://www.pbco-npdes.org/pdf/Cycle4PaImBeachCoun!yPermit.pdf
Wet weather sampling occurs during or immediately after a rain event to assess whether pollutants
are being flushed into a waterway via stormwater runoff. Sampling involves observations of water
color, smell, turbidity, and presence of floating debris. Then water samples are taken to test for
various indicators, such as levels of nitrogen, phosphorus, dissolved oxygen, bacteria, and other
water quality indicators, but this is highly dependent on the impairment and the water quality
indicators of the designated use(s) of the stream.
EAC Proposed Options: Options to consider for recommendation to the Village Council and staff
are:
Reduce the level of pollutants being discharged by establishing, or continuing, a proactive wet
weather sampling program per the terms of the Village MS4 permit.
Policy: 1.2.6 - The Village shall maintain levels of pollutants at all dry weather sampling areas
(area with three (3) days of no rain) as part of its "Dry Weather" Sampling regulations of the
National Pollution Discharge Elimination System Stormwater Permitting Program.
TGB Comment: Perhaps the Village should consider reducing levels of pollutants at all
referenced outfalls? According to the Tequesta MS4 permit, Part VIII, A, "the stormwater
management program must be designed and implemented to reduce the discharge of pollutants
from each permittee's MS4 to surface waters of the State to the MEP." A copy of the Palm
Beach County MS4 permit, of which is a party, can be viewed at the following link:
http://www.pbco-npdes.org//pdf/Cycle4Palm3eachCg ntyPermit.pdf
If one sees a liquid coming from an outlet and it hasn't rained in the past 72 hours, that is likely a
sign of a leak or illicit dumping somewhere in the system. That is why dry weather screening and
sampling is important. It makes it easier to find illicit discharges than during wet weather events.
Dry weather sampling of outfalls is required in priority areas that are classified as high or low
priority (it does not need to be done for catchments in areas that are classified as excluded
outfalls).
For this type of sampling, a local government will generally measure the following if flow is
found:
• Temperature
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Agenda Item #3.
• Conductivity
• pH
• turbidity
• chlorine
• surfactants
• potassium
• ammonia
• fecal and total coliform bacteria
• Any listed impairments
Tequesta's MS4 permit indicates that dry weather testing is no longer beingused. sed. The permit reads
"Florida's hydrologic and water table conditions make dry weather field screening impossible in
many areas. Instead, the Department has concluded that more environmental benefits can be
achieved through the implementation of a proactive illicit discharge detection program, which is
set forth in the remaining sections of Part III.A. 7 of this permit. " This appears to be applicable to
all local governments in Palm Beach County and not just to Tequesta.
EAC Proposed Options: Options to consider for recommendation to the Village Council and staff
are:
Reduce the level of pollutants being discharged by establishing a proactive illicit discharge
detection program forthwith as set forth in Part III.A.7 of the Village's MS4 permit.
Policy: 1.2. 7 - The Village shall maintain water quality standards consistent with the National
Pollutant Discharge Elimination System Program on an ongoing basis.
TGB Comment: This means reducing pollution loads according to the MS4 permit.
EAC Proposed Options: Options to consider for recommendation to the Village Council and staff
are:
Start with a pilot project that captures debris and petroleum -based runoff in selected drainage inlets
discharging into the Loxahatchee River, with discharge water quality testing, before and after, to
see the results of improved capture techniques on discharged pollutant loads.
Policy: 1.2.8 - The Village shall seek funding to evaluate the impact of sea level rise on the storm
water system and adopt environmental, and technically feasible strategies to adapt to sea level
impact and optimize benefits.
TGB Comment: This is a very expensive proposition, but necessary as we are surrounded by water
on three sides.
EAC Proposed Options: Options to consider for recommendation to the Village Council and staff
are:
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Agenda Item #3.
Village Council and staff must be prepared to move aggressively to secure any anticipated
forthcoming State or Federal government grant programs to fund evaluations of the impact of sea
level rise to the Village stormwater system, other Village infrastructure, and property, both public
and private.
Step number 1 is a comprehensive Vulnerability Assessment of the impact of sea level rise on all
interests of the Village of Tequesta, public and private. Firms with experience that can do this
important work will be in short supply once the aforementioned grant programs come to fruition.
Policy:1.3.1 - Protection from the degree of flooding that would result from a twenty-five (25)
year frequency, twenty-four (24) hour duration storm event is hereby adopted as the Village's
Level of Service Standard for stormwater drainage facilities and shall be used as the basis of
estimating the availability of capacity and demand generated by a proposed development project.
TGB Comment: This is fairly standard LOS for drainage in Palm Beach County.
EAC Proposed Options: Options to consider for recommendation to the Village Council and staff
are:
Sea level rise has the potential to negate the ability of Tequesta's storm water drainage facilities
to continue to meet this adopted LOS. A vulnerability assessment should also ascertain the sea
level rise impact on the LOS and provide recommendations for the Village to adapt to any
identified LOS impacts to maintain environment friendly drainage and flood control and the
adopted LOS.
Policy: 1.3.3 - All development and/or redevelopment activities associated with onsite drainage
facilities shall be designed and reviewed to maximize nonstructural techniques (i.e., on -site
retention and/or detention, use of pervious surfaces, swale areas, native vegetation and Xeriscape
landscaping) in combination with structural drainage facilities (i.e. underground drainage
facilities) to reduce storm water runoff, maintain local recharge and protect water quality.
TGB Comment: Absolutely. This should be done as soon as possible.
EAC Proposed Options: Options to consider for recommendation to the Village Council and staff
are: See our previous options for consideration herein, which referenced this Policy 1.3.3 and
stated the following:
1) Tequesta should mandate more use of natural landscaping on all new developments,
including Village street and right-of-way projects, as a proactive, low cost means of
reducing stormwater runoff and associated pollution.
2) The Village could mandate or incentivize use of rain barrels, cisterns, and planters, and
non-structural devices like landscaped swales and infiltration basins, with reduced annual
stormwater assessments and reduced permit fees as the incentive.
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Agenda Item #3.
3) The Village, for all new residential development or for renovations falling within adopted
threshold requirements$, require the first 2 inches of rainfall to be held on the property
and/or use of other stormwater on site capture options.' How they accomplish this may be
up to the property owner, but innovation will result to meet the adopted standard.
Policy: 1.3.4 — The Village shall continue its routine maintenance program through the inspection
of catch basins, culverts, outfalls and retention areas as a preventative measure against any major
system failure, as required by the National Pollutant Discharge Elimination Program Stormwater
Permitting Program.
TGB Comment: This is required per the Village's NPDES MS4 permit.
EAC Proposed Options: Options to consider for recommendation to the Village Council and staff
are:
Swale areas require periodic maintenance that requires scarfing (reducing the grade) of the swale
to remove build up of debris, soils and organic materials, all of which can affect the designed
percolation rates and water flow within the swale. Some swales in the Village (Seabrook Road)
are designed with curb and gutter, with flumes that direct water into the swale. Blockage of these
flumes with swale soil buildup and resulting vegetation can reduce the designed drainage
capability of the system, pooling or ponding and, potentially, downstream flooding. Swale
maintenance should receive an equal focus to that given to catch basins, culverts, outfalls and
retention areas in the routine maintenance program required by the NPDES permitting program
applicable to the Village.
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