City of Lubbock

Municipal Separate Storm Sewer System

TPDES Permit No. WQ0004773000

INTERIM BACTERIA REDUCTION PLAN (IBRP)

Revised April 20, 2021 Table of Contents

Introduction ...... 1 Watershed Description ...... 2 Watershed information ...... 2 Water bodies information ...... 2 Infrastructure description ...... 2 Water Quality – Sources and Trends ...... 3 Sources of Bacteria...... 3 Local Watershed Trends...... 3 Regulatory Background ...... 10 Bacteria Reduction Elements ...... 11 MCM-1 – MS4 Maintenance Activities ...... 11 MCM-3 - Illicit Discharge Detection and Elimination ...... 12 MCM-4 - Pollution Prevention and Good Housekeeping ...... 15 MCM-6 - Construction Site Stormwater Runoff Strategies ...... 16 MCM-7 - Public Education, Outreach, Involvement and Participation ...... 18 MCM-8 - Monitoring, Evaluation and Reporting ...... 20 References ...... 23

City of Lubbock Interim Bacteria Reduction Plan Page x Introduction Every two years, the Texas Commission on Environmental Quality (TCEQ) publishes an Integrated Report of Surface Water Quality. The Texas Integrated Report evaluates the quality of surface waters in the state and provides resource managers with a tool for making informed decisions when directing agency programs. This report includes the 303(d) list, which identifies water bodies in or around Texas for which effluent limitations are not stringent enough to implement water quality standards. This list identifies bodies of water using unique segment identification values. The City of Lubbock contributes to the North Fork Double Mountain Fork Brazos River, known as segment 1241A. The 2020 Texas Integrated Report lists Segment 1241 and 1241A as impaired for bacteria. Therefore, according to Permit Part III, Section B.3, an Interim Bacteria Reduction Plan (IBRP) must be implemented into the SWMP.

City of Lubbock Interim Bacteria Reduction Plan Page 1 Watershed Description Watershed information The City of Lubbock is located on the Southern High Plains of Texas. The flat topography of Lubbock, with its mild slopes, scattering of playa lakes, and limited number of drainage ways, encourages the use of surface flow of runoff rather than the use of storm sewers. Storm water in Lubbock is collected through two separate drainage systems. Most of the drainage from the City is conveyed through the City street system that discharges into the many playa lakes. The subsurface drainage via storm sewer pipes with curb inlets conveys storm water to two small dry streams (Blackwater Draw and Yellow House Draw) that converge and become the North Fork Double Mountain Fork Brazos River (NFDMF), also known as the Yellow House Canyon. Water bodies information A portion of the City of Lubbock drainage system contributes storm runoff to the North Fork Double Mountain Fork Brazos River (NFDMF) (Segment ID 1241A). This segment was listed as impaired for bacteria in water (recreation use) in the 2020 Texas Integrated Report – Texas 303(d) List (Category 5). Infrastructure description The City of Lubbock’s M84 is composed of the following components: • 1208 linear miles of paved streets • 59 linear miles of unpaved streets • 134 linear miles of paved alleys • 502 linear miles of unpaved alleys • 1353 storm sewer inlets • 126 miles of subsurface storm sewer pipe • 162 playa lakes.

City of Lubbock Interim Bacteria Reduction Plan Page 2 Water Quality – Sources and Trends Sources of Bacteria Potential sources contributing to the high bacterial loads in the watershed may include but are not limited to: sanitary sewer systems; on-site sewage facilities; illicit discharges and dumping; and animal sources. By identifying the major contributing sources of bacteria, the City can implement a plan to control them and reduce their impact on the North Fork Double Mountain Fork Brazos River. Stormwater testing in the city has shown elevated e. coli and fecal streptococci contaminant levels in vaults which are contributed to primarily by playa lakes. The playas in the city are attractive to avian wildlife, including migratory geese, and many are in city parks, where citizens may take pets for recreation. Animal waste, primarily from birds and pets, may be a large contributor to bacteria loads in stormwater passing through the playa lake drainage system. Bacteria may also enter the storm drain system in the form of human waste in areas with concentrated homeless populations. Local Watershed Trends Storm water quality testing is performed as part of the SWMP at various locations. The maps below show stormwater outfalls, water bodies, testing locations, as well as the impaired water body, NFDMF.

City of Lubbock Interim Bacteria Reduction Plan Page 3 FIGURE 1: CITY OF LUBBOCK PHASE 1 MS4 PERMIT WQ0004773000 MAJOR OUTFALLS AND WATER BODIES

City of Lubbock Interim Bacteria Reduction Plan Page 4 C i t y o f L u b b o c k P h a s e I M S 4 P e r m i t W Q 0 0 0 4 7 7 3 0 0 0 M a j o r O u t f a l l s a n d W a t e r B o d i e s ²

!. !. !. !.!.!.!. !. !.!.!.!. !.!. L e g e n d !. !.!. !.!. !. S tt o r m w a tt e r !. !. O u tt ff a ll ll s !. !. !. W a tt e r B o d ii e s !. !. !. L u b b o c k C ii tt y L ii m ii tt s

Digital Orthoimagery June 2016 0 1 2 3 4 5 Miles As required by SECTION 1. Chapter 2051, SUBCHAPTER D. GEOSPATIAL DATA PRODUCTS of the Government Code, the City of Lubbock hereby provides notice that the data on this map was created by the City of Lubbock. Any data that appears to represent property boundaries is for informational purposes and may not have been prepared for or be suitable for legal, engineering, or surveying purposes. It does not represent an on-the-ground survey and represents only the approximate relative location of property boundaries. FIGURE 2: STORM WATER TESTING LOCATION MAP

City of Lubbock Interim Bacteria Reduction Plan Page 5 INTERIM BACTERIA REDUCTION PLAN

FIGURE 2: STORM WATER TESTING LOCATION 4 (! MAP

KEY TO FEATURES TCEQ Testing Locations (! COL Testing Vaults River Segments Impaired Segment Flood Zone A 3 (! Flood Zone AE Flood Way Lakes Lubbock City Limit

2 (! 1 (!

¬ 0 2,500 5,000 10,000

5 Feet (! 1 inch = 5,000 feet

W:\Citrix\32000s\32199\003\IBRP\GIS\MXD\IBRP_Figure2.mxd The results found from testing in locations shown in Figure 2 are reported annually in the City’s SWMP annual report. The 2020 results are shown in the tables below:

TABLE 1: 2020 WET SEASON MONITORING DATA

47th & 44th & 26th & 98th & 1st & Ave J Vanda MLK Ivory Guava ANALYTE UNITS 05/05/19 05/05/19 05/05/19 05/05/19 05/05/19 004-S 001-S 002-S 003-S 005-S

Temperature Deg C 9.0 22.3 19.9 21.3 10.6

BOD, 5-Day mg/L 10 13 11 3 12

Chemical Oxygen Demand (COD) mg/L 72 89 78 58 58 pH Std. Units 8.42 7.02 8.11 7.80 8.58

Total Suspended Solids (TSS) mg/L 221 142 11 10 49

Oil and Grease mg/L 1.54 2.44 0.806 <4.60 <4.44

Total Ammonia Nitrogen mg/L <0.030 <0.030 0.214 0.123 0.059

Total Kjeldahl Nitrogen (TKN) mg/L 1.07 1.76 1.14 1.04 1.72

Total Nitrite plus Nitrate mg/L 0.674 0.665 1.261 0.931 0.12

Total Phosphorus mg/L 0.288 0.573 0.880 0.354 0.249

Dissolved Phosphorus mg/L 0.199 0.459 0.728 0.225 0.035

Total Hardness mg/L 530 230 90 360 110

Total Arsenic ug/L 0.0069 0.00303 0.00124 0.00542 0.00238

Total Cadmium (MAL 0.001) ug/L 0.00047 <0.000095 <0.000186 <0.000186 <0.000095

Total Chromium (MAL 0.003) ug/L 0.0106 0.00852 0.00138 0.00142 0.00213

Total Copper (MAL 0.002) ug/L 0.0123 0.0163 0.00765 0.00637 0.00447

Total Lead (MAL 0.0005) ug/L 0.0116 0.0147 0.00185 0.00122 0.00193

Total Nickel (MAL 0.002) ug/L 0.00891 0.00714 0.00165 0.00334 0.00308

Total Silver ug/L 0.0000635 0.0000682 <0.00011 <0.00011 <0.0000628

Total Zinc (MAL 0.005) ug/L 0.0698 0.136 0.0302 0.0227 0.0186

cfu Fecal Streptococci 58,500 5,000 42,000 7,400 11,200 MPN/100ml

Atrazine ug/L <0.000521 <0.000522 <0.000548 <0.000549 <0.000515

E. coli cfu/100ml 49,000 46,500 69,000 6,800 4,450

Total Dissolved Solids (TDS) mg/L 146 302 296 1130 126

City of Lubbock Interim Bacteria Reduction Plan Page 6 TABLE 2: 2020 DRY SEASON MONITORING DATA

47th & 98th & 44th & MLK 26th & Ivory 1st & Ave J Vanda Guava ANALYTE UNITS 11/07/19 11/07/19 11/07/19 11/07/19 11/07/19 002-S 003-S 004-S 001-S 005-S

Temperature Deg C 25 25 25 25 25

BOD, 5-Day mg/L 7 19 17 8 7

Chemical Oxygen Demand (COD) mg/L 41 77 70 35 40 pH Std. Units 8.09 7.91 7.96 7.18 8.43

Total Suspended Solids (TSS) mg/L 44 52 30 10 240

Oil and Grease mg/L 1.14 <4.76 1.24 1.67 <4.82

Total Ammonia Nitrogen mg/L 0.245 0.475 0.751 0.345 <0.030

Total Kjeldahl Nitrogen (TKN) mg/L 0.891 1.95 1.99 1.09 7.83

Total Nitrite plus Nitrate mg/L 0.645 0.851 1.443 1.191 0.815

Total Phosphorus mg/L 0.207 8.79 2.07 0.302 0.256

Dissolved Phosphorus mg/L 0.068 2.89 0.522 0.089 0.097

Total Hardness mg/L 50 40 60 70 73.9

Total Arsenic ug/L 0.00174 0.00172 0.0008 0.00148 0.00452

Total Cadmium (MAL 0.001) ug/L <0.000095 <0.000095 <0.000095 <0.000095 0.000174

Total Chromium (MAL 0.003) ug/L 0.00411 0.00426 0.00313 0.00204 0.0184

Total Copper (MAL 0.002) ug/L 0.00706 0.00961 0.0105 0.00963 0.0104

Total Lead (MAL 0.0005) ug/L 0.00556 0.00368 0.0038 0.00177 0.00786

Total Nickel (MAL 0.002) ug/L 0.00309 0.00335 0.00202 0.00214 0.00983

Total Silver ug/L <0.0000628 <0.0000628 <0.0000628 <0.0000628 <0.0000628

Total Zinc (MAL 0.005) ug/L 0.0603 0.165 0.0878 0.0494 0.0673

cfu 5,600 Fecal Streptococci 1,360 9,800 24,000 3,500 MPN/100ml

Atrazine (MAL 0.0005) ug/L <0.000567 <0.000553 <0.000563 <0.000547 <0.000544

E. coli cfu/100ml 1,280 13,697 14,788 602 11,515

Total Dissolved Solids (TDS) mg/L 146 186 168 278 230

City of Lubbock Interim Bacteria Reduction Plan Page 7 The results show elevated e. coli and fecal streptococci for some of the locations tested. These water contaminants are known contributors of bacteria to storm water. The charts below show e. coli and fecal streptococci concentrations over the recent years of testing.

Fecal Streptococci Load Over Time 400000

350000

300000

250000 Vault 1 200000 Vault 2 Vault 3 150000 Vault 4

100000 Vault 5 FecalStreptococci (CFU/100ml) 50000

0 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 Year

FIGURE 3: FECAL STREPTOCOCCI CONCENTRATIONS OVER TIME

E. Coli Load Over Time 250000

200000

150000 Vault 1 Vault 2

100000 Vault 3 Vault 4 E. Coli(MPN/100ml) Vault 5 50000

0 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 Year

FIGURE 4: E. COLI CONCENTRATIONS OVER TIME

City of Lubbock Interim Bacteria Reduction Plan Page 8 These charts indicate that the concentrations of these contaminants vary year by year but are generally showing an increase over time. The City of Lubbock will investigate if there are significant correlations between spikes in bacteria loads and other environmental factors, such as rainfall totals and migratory bird populations in a given year.

City of Lubbock Interim Bacteria Reduction Plan Page 9 Regulatory Background The Texas Commission on Environmental Quality (TCEQ) provides standards of water quality for storm water and other surface waters in the state under the authority of the federal Clean Water Act (CWA). Section 303(d) of the CWA authorizes the EPA to assist TCEQ in listing impaired waters and developing Total Maximum Daily Loads (TMDLs) for these waterbodies. The Texas Pollutant Discharge Eliminations System (TPDES) is a regulatory program to control discharges of pollutants to surface waters. The TCEQ has permitted the City of Lubbock and Texas Tech University to discharge stormwater meeting other environmental requirements to the NFDMF under TPDES Permit WQ0004773000. As part of this permit, the City of Lubbock has implemented a Stormwater Management Plan (SWMP). According to the permit, the SWMP is required to include an Interim Bacteria Reduction Plan (IBRP) when a water body that is being contributed to is identified as being impaired for bacteria in the latest CWA 303(d) list.

City of Lubbock Interim Bacteria Reduction Plan Page 10 Bacteria Reduction Elements MCM-1 – MS4 Maintenance Activities Due to the limited topographic relief available within the City, stormwater conveyance facilities are comprised primarily of the city streets, which carry the stormwater to the nearest playa lake, subsurface storm sewer inlet, or canyon within the City. The nature of this surface flow enables stormwater to encounter bacterial contaminants on the roadway surface, including but not limited to avian waste. Frequent roadway maintenance and sweeping can therefore reduce the bacteria contaminant levels in stormwater by removing these contaminants from the street surface. The Lubbock SWMP (2020) has implemented a Roadway Maintenance program as Part C of MCM1 – MS4 Maintenance Activities. Program Components The City of Lubbock owns and operates street sweeping equipment and conducts a regular street sweeping program. Program Schedule The activities associated with maintenance of roadways within the City are ongoing and will be continued for the life of the permit. Performance Measures for MCM1 The following performance measures will be recorded during the life of the MS4 permit by the responsible departments listed below: • Street Maintenance o Number of inlets inspected o Number of channels inspected o Estimate of debris/sediment removed from subsurface storm sewer system o Estimate of materials collected from detention basins o Number of lane miles of streets swept o Estimate of materials removed from street sweeping

City of Lubbock Interim Bacteria Reduction Plan Page 11 MCM-3 - Illicit Discharge Detection and Elimination Sanitary sewer seepage and overflows are two ways that bacteria in the sanitary sewer system may enter the storm sewer system. Detecting and eliminating these illicit discharges can reduce the loads of bacteria in the storm sewer. The Lubbock SWMP (2020) has implemented an Overflow and Infiltration program as Part C of MCM3 – Illicit Discharge Detection and Elimination Program Components The City will continue to work at identifying and limiting infiltration of seepage between sanitary sewers and the storm sewer system. The City will work to reduce line stoppages associated with grease buildup that might result in overflows by requiring new kitchens and food preparation businesses to install grease interceptors/traps of a type in which separation is accomplished by differential gravity methods and which is approved by the City. Wastewater Collections currently inspects sanitary sewer lines with the use of CCTV during line blockages and routine maintenance to prevent infiltration of seepage between sanitary and storm sewer systems. Line breaks and repairs will continue to be logged and evaluated to determine when lines should be repaired or replaced, and to anticipate the likelihood of needed repairs and investigation of other lines of the same basic type and age. Sewer line blockages reported by individuals will be given high priority. Sewer lines will continue to be cleaned annually, with known problem areas receiving priority. Program Schedule The City is currently performing all of the components of this program and will continue to do so for the life of the MS4 permit. The Lubbock SWMP (2020) has implemented a MS4 Screening and Illicit Discharge Inspection program as Part E of MCM3 – Illicit Discharge Detection and Elimination Program Components The City has developed and implemented the following measures to identify illicit discharges. • Illicit discharges, illicit connections, and improper disposals within the MS4 will be identified through the combination of efforts. o The City conducts a Dry Weather Screening Program in which approximately twenty percent of the playa lakes will be monitored each year for the life of the permit, with all major outfalls monitored annually. The details, schedule and performance measures for this program are discussed further in the MCM8 – Monitoring, Evaluation and Reporting. o Citizens and city employees will be educated per the MCM7 by Stormwater Compliance concerning illicit discharges.

City of Lubbock Interim Bacteria Reduction Plan Page 12 o Stormwater Compliance will conduct inspections of industrial facilities for illicit discharges, illicit connections and improper disposals. Environmental Health performs inspections on pools, restaurants, septic systems, and other facilities that have potential for illicit discharges, illicit connections, and/or improper disposal. Wastewater Collections respond to sanitary sewer overflows and coordinates clean-up. Industrial Waste Monitoring & Pretreatment (IWMP) regulates grease/grit traps to prevent sanitary sewer overflows at restaurants, car washes, etc. • If a potential illicit discharge, illicit connection, or improper disposal is identified, the Stormwater Compliance will investigate the discharge. If the discharge is on the surface, such as in a street or an alley, it will be visually traced back to its apparent source. If the suspect discharge is located in a subsurface storm sewer, the inspector will trace it back through the storm sewer system via the use of GIS mapping. Once the suspect discharge has been isolated to a specific location, the City will respond with enforcement actions or arrange to clean-up the discharge. If the suspect discharge cannot be traced back to a discrete source, the City will respond by arranging clean-up of the discharge. • Stormwater Compliance developed a list of priority areas likely to have illicit discharges and will evaluate and update this list each year and report the results in the annual report. Program Schedule The City is currently performing all of the components of this program and will continue to do so for the life of the MS4 permit. Performance Measures for MCM3 The following performance measures will be recorded during the life of the MS4 permit by the responsible departments listed below: • Solid Waste Management o Number of informational brochures distributed o Number of inquiries regarding household hazardous waste o Number of inquiries regarding assistance provided • Stormwater Compliance o Number of enforcement actions taken for IDDE o List of techniques used to detect illicit discharges, revised as necessary o Number of informational brochures distributed o Number of field screening reports of playa lakes o List of current known TPDES dischargers o The number of outfalls designated on the MS4 map o The number of outfall inspections conducted o The number of detention pond inspections conducted • Wastewater Collections o Number of sanitary sewer overflows reported o Number of sanitary sewer line blockages

City of Lubbock Interim Bacteria Reduction Plan Page 13 o Number of miles of sanitary sewer lines inspected o Number of miles of sanitary sewer lines cleaned o Number of miles of sanitary sewer line videotaped (CCTV) o Number of sewer service main breaks repaired/reported o Number of miles of sanitary sewer lined repaired As part of the sanitary sewer overflow reporting and tracking program that is already in place, the City tracks the number of overflows reported, as well as approximate volume, clean-up procedure, and potential environmental impacts of each overflow. The City also has an existing and ongoing program of tracking and permitting new on-site sewer facilities within the city limits. The program includes tracking of location, installation date, and installer name, along with some specifics about the type of system installed. The City works with Lubbock County’s Sanitation Department who investigates OSSF complaints, maintains records of actions taken, and reports the number of open investigations and sights brought into compliance.

City of Lubbock Interim Bacteria Reduction Plan Page 14

MCM-4 - Pollution Prevention and Good Housekeeping Avian waste in playa lake watersheds is a contributor to bacteria loads in the storm water system. The city will implement as part of this plan a program to control avian populations near playa lakes as Part F of MCM 4 - Pollution Prevention/Good Housekeeping for Municipal Operations. Program Components The City has developed and implemented the following measures to control and limit avian populations at and near playa lakes. • Signs prohibiting feeding of geese and other waterfowl shall be placed around playa lakes where feeding is shown to encourage higher populations of these species. • No-mow zones or vegetative buffers may be implemented along the perimeters of the playa lakes water surface. Special care will be taken with vegetation in these zones to ensure plant survivability. Program Schedule • Year 1-2 o Study effectiveness of no feeding signs and vegetative buffers at reducing avian populations near playa lakes • Year 3 o Develop a City avian deterrent program • Year 4 o Implement City avian deterrent program • Year 5+ o Continue to implement City avian deterrent program Performance Measures MCM4 The following performance measures will be recorded during the life of the MS4 permit by the responsible department: • Parks & Recreation o Quantity of pesticide, herbicide, and fertilizer applied at city-owned facilities o Quantity of educational and feeding prohibited signs implemented at playa lakes o Quantity of city-owned facilities with vegetative buffers installed at perimeter of playa lakes

City of Lubbock Interim Bacteria Reduction Plan Page 15 MCM-6 - Construction Site Stormwater Runoff Strategies Construction site stormwater runoff may contain higher bacterial contaminants due to increased sediment loads that contain naturally occurring bacteria. The City has implemented a Waste Control program for construction sites to address these sources of bacteria to the storm sewer system. Structural and non-structural BMPs are effective practices to remove certain pollutants, including bacteria, from storm water. The city has implemented a program to remove pollutants from construction site stormwater with the use of these BMPs. The use of BMPs that are effective at removing bacteria will reduce bacteria that leaves these construction sites and enters the storm drain system and the impaired water body. The Lubbock SWMP (2020) has implemented a Waste Control program as Part B of MCM6 – Construction Site Stormwater Runoff All sites that disturb one acre or greater are required to implement appropriate controls to reduce sediment and other pollutants from being discharged from the construction site to the MS4. In addition, appropriate pollution prevention and good housekeeping measures to address litter, waste materials, concrete truck washouts, chemicals, and sanitary waste are required for every site, regardless of size. The Lubbock SWMP (2020) has a Program to Implement and Maintain Structural and Non- Structural BMPs as Part H of MCM6 – Construction Site Stormwater Runoff The City has a program to implement and maintain structural and non-structural best management practices to reduce pollutants in stormwater runoff from construction sites to the MS4. Stormwater Compliance informs construction site operators in the Site Plan Review Committee meetings of the need to meet the TPDES requirements, specifically the need to consider potential water quality impacts, and the use of appropriate nonstructural and structural BMPs. Building safety applicants are informed of the same requirements. Building permit applications are kept on hold until the TPDES requirements are met. Stormwater Compliance has implemented an Enforcement Response Policy (ERP) addressing how control measures are evaluated upon inspection, the enforcement response based on the level of a violation, and the circumstances for a violation. The policy escalates enforcement action based on the type of violation. Performance Measures for MCM6 The following performance measures will be tracked annually by the City during the term of the permit by the responsible departments. • Stormwater Compliance o Number of inspections conducted at construction sites o Number of Small Construction Site Notices (SCSNs) received

City of Lubbock Interim Bacteria Reduction Plan Page 16 o Number of TPDES Notices of Intent (NOIs), Notices of Change (NOCs), and Notices of Termination (NOTs) received o Number of building permits issued for residential and commercial construction o Number of Site Plan Reviews conducted by the Site Plan Review Committee o Number of Enforcement Actions taken o Number of complaints made via the 311 On-Line, or EnerGov

City of Lubbock Interim Bacteria Reduction Plan Page 17 MCM-7 - Public Education, Outreach, Involvement and Participation Some contributing sources of bacteria to the City’s storm sewer system can be identified and reduced by the public. The public can be educated on the impacts of illicit discharges to the storm sewer system and encouraged to report any observed illicit discharges. Public reporting of illicit discharges from septic or sanitary sewers allows the City to take action to stop these sources of bacteria from contaminating storm water. Pet waste at parks may be a large contributor of bacteria to the storm drain system. The city has published educational flyers on the levels of pet waste and their impacts and will continue to create resources for education in this area. Along with public education on impacts of pet waste on stormwater, the City has implemented and is expanding a pet waste station program at some City parks to allow and encourage pet owners to pick up their pet’s waste. The Lubbock SWMP (2020) has implemented a Promote, Publicize, and Facilitate Public Reporting program as Part A of MCM7 – Public Education and Outreach/Public Involvement and Participation Program Components This section describes a program that promotes, publicizes, and facilitates public education and outreach to residents, visitors, public service employees, businesses, commercial and industrial facilities, and construction site personnel. This program has been developed in compliance with Part III.B.2.g. of the City’s TPDES permit. The City currently has in place a method for public reporting of illicit discharges on the City Website, 311 On-Line, the City 311 Call Center, Stormwater Hotline, and after-hours phone lines operated by the City Water dispatch service. The activities and materials used for Public Education and Outreach program continue to be documented in the yearly annual report to TCEQ. The City continues to use the City website, social media, advertising, and public meetings to encourage public involvement and participation. Program Schedule In order to facilitate such reporting, the City will continue to maintain the website reporting, and phone numbers for hotline, dispatch, and 311-On-line and 311 Call Center services. Public notification of the availability of reporting is advertised through brochures, website, education events, online and television advertising, etc. The City will implement as part of this plan a program to control pet waste near playa lakes as Part D of MCM 7 - Public Education and Outreach/Public Involvement and Participation. Program Components The City has developed and implemented the following measures to control and limit pet waste at and near playa lakes.

City of Lubbock Interim Bacteria Reduction Plan Page 18 • Public pet waste pickup infrastructure including dog waste stations shall be installed at city owned parks with playa lakes that are shown to have high pet populations. Program Schedule • Year 1-2 o Study effectiveness of installing pet waste pickup and disposal infrastructure at city owned facilities on reducing bacteria loads in playa lakes. • Year 3 o Develop a City pet waste station program • Year 4 o Implement City pet waste station program o Perform qualitative assessment of pet waste concentrations at parks before and after implementation of pet waste stations. • Year 5+ o Continue to implement City pet waste station program Performance Measures for MCM7 The following performance measures will be recorded during the life of the MS4 permit by the responsible departments listed below: • Stormwater Compliance o Promote, publicize, and facilitate public reporting o Number of illicit discharges reported o Amount of educational information distributed to citizens o Number of visits to lubbockstormwater.org • Environmental Compliance o Quantity of material collected o Quantity of material recycled • Solid Waste Management o Amount of educational information distributed to citizens o Number of citizens participating in various recycling programs • Parks & Recreation o Quantity of pet waste collection bags ordered and used through pet waste station program.

City of Lubbock Interim Bacteria Reduction Plan Page 19 MCM-8 - Monitoring, Evaluation and Reporting Monitoring, evaluating and reporting water quality in the MS4 allows the city to track illicit contaminants in the storm water system. Tracking contaminants such as E. Coli and Fecal Streptococci informs the city of trends in bacteria contamination in storm runoff. As part of the screening programs already in place, the city will monitor bacteria in an effort to identify its sources so that they can be effectively treated. The Lubbock SWMP (2020) has implemented a Dry Weather Screening Program as Part A of MCM8 – Monitoring, Evaluation and Reporting Program Components The City of Lubbock will continue to implement, and modify as necessary, the monitoring program for dry weather in an effort to detect the presence of illicit connections and improper discharges into the MS4. Basic field screening activities will be continued through the life of the permit, along with the annual investigations of the storm sewer outlets for flow during those times when there has been no significant precipitation (less than 0.10 inches) within 72 hours to determine if flow is not from rainfall runoff. Program Schedule The dry-weather screening program is ongoing and will continue for the life of the permit. It is estimated that approximately 20 percent of the playa lakes will be monitored each year for the life of the permit, with all major outfalls monitored annually. The Lubbock SWMP (2020) has implemented a Wet Weather Screening Program as Part B of MCM8 – Monitoring, Evaluation and Reporting Program Components Wet-weather screening of the City's MS4 will be accomplished through visual observation primarily in association with rising water levels around the playa lakes. Any observed flows with characteristics attributable to gross pollution will be documented for follow-up as appropriate. Program Schedule The wet-weather screening program is also ongoing and will continue for the life of the permit. It is estimated that approximately 20 percent of the playa lakes will be monitored each year for the life of the permit, with all major outfalls monitored annually. The Lubbock SWMP (2020) has implemented an Industrial and High-Risk Runoff Monitoring Program as Part C of MCM8 – Monitoring, Evaluation and Reporting

City of Lubbock Interim Bacteria Reduction Plan Page 20 Program Components The City will require industries with benchmark monitoring requirements under the Multi-Sector General Permit (MSGP) for stormwater discharges related to industrial activity to submit their monitoring results to the City upon annual inspection of their facility. The City will prepare and maintain a list of those EPCRA (SARA Title III) facilities and others that are subject to the Industrial and High-Risk Monitoring Program as described in Part III.B.2.h.iii. The City will review data collected by these facilities and determine if any of this data necessitates monitoring that facility as part of the Industrial & High-Risk Runoff Monitoring program. The City will prepare and maintain a list of facilities exempted from the Industrial and High-Risk Monitoring Program due to "No Exposure" certifications prepared by the particular industry. Program Schedule The Industrial and High-Risk Runoff Monitoring Program is ongoing and will continue for the life of the permit. The Lubbock SWMP (2020) has implemented an Floatables Monitoring Program as Part E of MCM8 – Monitoring, Evaluation and Reporting Program Components Per the permit Part IV.B, the City has two monitoring locations 1) Stumpy Hamilton Park (21st & Ave X) and 2) Mose Hood (24th & Ave Q) for the removal of floatable material. The material from these locations is anticipated to be collected at a minimum of twice per year. Part IV.B. Floatables Monitoring. The permittees shall maintain two locations where floatable material can be removed before the stormwater is discharged to or from the MS4. Floatable material shall be collected at the frequency necessary for maintenance of the removal devices, but not less than twice per year. The amount of material collected shall be estimated by weight, volume, or by other practical means. Results shall be included in the Annual Report required in this permit. Program Schedule The City is currently performing all existing aspects of the programs identified in this portion of the SWMP. The City will continue these existing programs throughout the life of the permit. Performance Measures for MCM8 The following performance measures will be recorded during the life of the MS4 permit by the responsible departments listed below: • Parks & Recreation o Estimate of litter collected by weight, volume, or by other practical means • Street Maintenance o Estimate of litter collected by weight, volume, or by other practical means • Stormwater Compliance

City of Lubbock Interim Bacteria Reduction Plan Page 21 o Number and location of playa lake outfalls screened and results o Number and location of major outfalls screened and results o List of EPCRA (SARA Title III) facilities o List of facilities exempted from the Industrial and High-Risk Monitoring Program o Number of facilities required to submit monitoring data o Number of data sets received and reviewed • Industrial Waste Monitoring & Pretreatment (IWMP) o Number of representative monitoring samples for Wet Season o Number of representative monitoring samples for Dry Season

City of Lubbock Interim Bacteria Reduction Plan Page 22 References • Lubbock SWMP (2020) • Lubbock TPDES Permit WQ0004773000 (issued August 17, 2015) • Lubbock MS4 Annual Report (2019) • TPDES Program https://www.tceq.texas.gov/permitting/wastewater/pretreatment/tpdes_definition.html • CWA 303(d) https://www.epa.gov/tmdl

City of Lubbock Interim Bacteria Reduction Plan Page 23