Vista PIN 270704 FY2018-19 JRMP AR

Home , San Luis Rey River

Attachment A. Jurisdictional Runoff Management Program Annual Report – Carlsbad WMA: Support Data and Supplemental Information

Information provided in this attachment supplements data presented in the Jurisdictional Runoff Management Program Annual Report Form. Each section that follows is presented in order of program element as identified in the form.

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1 Copermittee Information The City of Vista’s (City) jurisdictional area resides within two Watershed Management Areas (WMAs), the Carlsbad WMA and the San Luis Rey WMA (SLR WMA; Table 1-1). As required by the San Diego region municipal stormwater permit (San Diego Region Water Quality Control Board, Order No. R9- 2013-0001), program activities conducted in these two WMAs are summarized in separate annual reports.

Table 1-1. City of Vista Jurisdictional Area within Watershed Management Areas Watershed Management Area Acres Carlsbad 11,247 San Luis Rey 762 City of Vista Total 12,009

2 Legal Authority The City maintained and implemented legal authority within its jurisdiction consistent with the San Diego region municipal stormwater permit through Vista Municipal Code (VMC) Chapter 13.18, Stormwater Management and Discharge Control Program. VMC Chapter 13.18 was adopted by Vista City Council on June 9, 2015, with most recent editorial revisions made on September 23, 2016. The City’s municipal and development codes are available at: https://www.cityofvista.com/city-services/city-departments/community-development/municipal- development-codes

3 Jurisdictional Runoff Management Program Document Update The City’s Jurisdictional Runoff Management Program (JRMP) document was previously revised in January 2017 following approval of the Carlsbad Water Quality Improvement Plan in November 2016. The City voluntarily updated its JRMP document in FY 2018-19 with revisions as summarized below:

• Removed discussion of transition between 2008 JURMP document and current JRMP document (Executive Summary, Section 12). • Updated references to irrigation runoff as a prohibited discharge, and cross-referenced applicable JRMP and WQIP strategies (Section 3, Appendix E) • Updated discussion regarding building permit stormwater checklist (Section 4, Section 5) • Revised criteria for prioritizing existing development inspections (Section 6) • Updated description of Residential Management Areas (RMAs) and associated inspections (Section 9) • Updated narrative and examples of retrofit projects (Appendix B) • Non-substantive editorial revisions throughout.

The 2019 JRMP document is available on the City’s website (www.cityofvista.com) and the regional clearinghouse website (www.projectcleanwater.org).

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4 Illicit Discharge Detection and Elimination Program Sections 4 through 7 summarize jurisdictional program and inspection activities, presented in order of the program components listed on the Annual Report Form. Note that multiple violations can be identified on one enforcement action; therefore, in the Annual Report Form, the total number of enforcement actions does not equal the number of violations observed. Illicit Discharge Detection and Elimination Program activities are summarized in Section IV on the Annual Report Form.

Inspections of major outfalls and analytical sampling was conducted in support of illicit discharge detection and elimination activities. Forty-seven major outfalls were monitored by visual inspection, and five outfalls were sampled for laboratory analysis consistent with persistent flow monitoring requirements. No surface flow sources were identified during most visits at persistently flowing outfalls, consistent with previous investigations that suggest groundwater infiltration to the storm drain system is contributing to flow. At the end of FY 2018-19, one month of continuous flow monitoring and analytical sampling was conducted at major outfall AH-02 to characterize persistent flows and fulfill the Agua Hedionda Dry Weather Special Study. Initial review of data indicate increased non-stormwater flow during overnight hours. A technical report of findings is currently being prepared. Continuous flow monitoring was also conducted at five other outfalls in the Carlsbad WMA, including major outfalls BV- 16, BV-12, BV-09, BV-05 and BV-01. Data continue to be reviewed and analyzed to characterize flows and potential sources.

In August 2016, the San Diego Regional Water Quality Control Board conducted an audit of the City’s website, municipal code, and jurisdictional documents to assess implementation of the prohibition of irrigation runoff. Results of the audit were provided in October 2018, and a response to audit findings is provided in Attachment B. Irrigation runoff is identified as a prohibited discharge Vista Municipal Code Chapter 13.18, and the City recognizes that irrigation runoff can be a source of pollutants and dry- weather flow in the storm drain system. The City made improvements to clarify irrigation runoff as a prohibited discharge, including the following:

• Revised text on City stormwater webpages (www.cityofvista.com/stormwater). • Clear identification of “Irrigation Runoff” and “Stormwater Pollution” as selectable topics for reporting an issue through the City’s on-line reporting tool and Access Vista smartphone application. • Revised text in the “Best Management Practices for Businesses” brochure. • On the stormwater webpage and on-line reporting tool, provided contact information for Vista Irrigation District (VID), the potable water provider, regarding water conservation, drought, and reporting of water waste. 4.1 Homelessness As noted in the previous reporting period, the Vista City Council developed goals for the 2018-2020 period, two of which will provide citywide benefit in addressing sources of priority stormwater pollutants such as trash and bacteria. The two Vista City Council goals are as follows:

• Goal #3 – Develop a Strategic Plan to address Homelessness • Goal #4 – Continue to Decrease Blight and Improve the Image of Our City

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In addition to these strategic planning activities, City staff continued to respond to the environmental impacts of homeless encampments. On May 7, 2019, the City received notice of a complaint filed through CalEPA indicating presence of an encampment near Buena Vista Creek and Hacienda Drive. Debris removal activities were initiated in vicinity of the compliant, removing approximately 11 tons of debris. Cumulatively, approximately 15 tons of debris was removed from encampments throughout the city during the reporting period.

4.2 Trash Order Track 2 Implementation On August 31, 2017, the City provided notice to the San Diego Regional Water Quality Control Board that ‘Track 2’ was selected as the City’s pathway for compliance with Order R9-2017-0077 (referred to as the Trash Order). On November 29, 2018, the City submitted its Track 2 Implementation Plan, describing the combination of both structural and non-structural programmatic activities that will be implemented to achieve trash capture requirements. To better understand the revenue and expenditures necessary to support the implementation plan, a financial plan was also prepared. The City continues to investigate potential funding sources to support this new regulatory requirement. Implementation plan activities are anticipated to commence in 2020, consistent with the 10 –year timeline for demonstrating compliance by the end of 2030.

5 Development Planning Program Development Planning Program activities are summarized in Section V on the Annual Report Form.

The current inventory of Priority Development Project sites in the Carlsbad WMA is 144 sites, consisting of 675 individual post-construction Best Management Practices (BMPs). Sixty-eight BMPs were inspected in at the end of FY 2018-19, and an additional 289 are identified for inspection in early FY 2019-20.

Staff had previously identified multiple Priority Development Project sites where a combination of design and/or construction deficiencies appeared to contribute to defective post-construction BMPs. Deficiencies at one site was resolved, and design plans were received for proposed revisions at a second site. Seven sites remain to be investigated to confirm potential design deficiencies and initiate resolution.

During the reporting period a revised “Building Permit Stormwater Pollution Prevention Checklist” was developed. The checklist is used to review projects that only require building permits, and identify pollution prevention practices to be implemented based on permitted activities. The checklist is then used to identify sites to be scheduled for targeted inspections for pollution prevention compliance (additional to site inspections conducted by Building Division staff).

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6 Construction Management Program Construction Management Program activities are summarized in Section VI on the Annual Report Form.

City staff continued to implement an effective construction management program through scheduling of site inspections at a frequency of monthly during the dry season and weekly during the rainy season. Construction activity increased in FY 2018-19, with 1,223 inspections conducted at 48 active sites, resulting in 153 enforcement actions and 20 escalated enforcement actions (e.g., stop work notice). The San Diego Regional Water Quality Control Board was notified of sites receiving escalated enforcement, and site compliance was coordinated as necessary.

7 Existing Development Management Program Existing development inspections and enforcement actions are summarized in Section VII of the Annual Report Form.

7.1 Existing Development Facilities To develop the inventory of industrial and commercial facilities subject to pollution prevention inspections, business license data is now queried by Standard Industrial Classification (SIC) numbers. This query changed the distribution of how facilities are classified in the inventory, with fewer facilities identified as Commercial but more facilities identified as Industrial. Approximately 20 percent of both the inventoried Commercial and Industrial facilities were inspected during the reporting period. Efforts to develop a parcel-based inspection program for multi-tenant properties were ceased this year due to other program priorities. It is still believed such program would introduce efficiencies and effectiveness, and staff will continue to explore this in the future.

All inventoried Municipal facilities were inspected. The number of inventoried Municipal facilities increased by five as a result of identifying smaller facilities within large previously inventoried facilities (e.g., the Brengle Recreation Center located within Brengle Terrace Park).

Eighteen of the City’s 20 Residential Management Areas (RMAs) are within the Carlsbad WMA. Eight of these RMAs were inspected twice. Of all 134 residential-based compliance cases that were initiated, 45 cases were initiated as a result of RMA inspections. Discharge control (i.e., irrigation, runoff, or water discharge), waste management, and sediment control were the three most commonly observed deficiencies.

City staff continued to explore development of a parcel-based inspection program for multi-tenant industrial and commercial properties. However, challenges were identified in maintaining accuracy while combining multiple data sets. Staff will continue to evaluate these challenges, as it is believed a parcel- based inspection program could increase the efficiency and effectiveness of these inspections.

7.2 Municipal Activities Routine sanitary sewer maintenance activities continued, guided by response and management plans updated in 2018. City staff responded to fourteen private sewer lateral spills and one sanitary sewer overflow. Three Fats, Oils, and Grease (FOG) inspections were conducted to reduce the potential for

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discharged materials to adversely impact the sanitary sewer system, and additional city-wide FOG inspections are planned for FY 2019-20. Of 1,178 inventoried storm drain inlets, 762 were cleaned, removing 105 cubic yards of debris. To remove debris and pollutants before entering the storm drain system, street sweeping activities continued with high and moderate-rated roadways being swept twice per month and low-rated roadways being swept monthly. Additional activities conducted during the reporting period that support stormwater pollution prevention in the City’s developed areas include the following (not limited to the Carlsbad WMA:

• Maintained 110 trash bins at bus stops and high pedestrian use areas throughout the City. • Christmas tree curbside collection and drop-off locations active between December 26, 2018 and January 12, 2019. • Continued support of certified oil collection centers within the City. Used oil collection centers recovered approximately 26,890 gallons of oil and 3,000 oil filters. • Document shredding and e-waste collection event on June 8, 2019. • Continued operation of the Household Hazardous Waste facility that serves member cities of Carlsbad, Encinitas, Escondido, Solana Beach, and San Marcos. During the reporting year, approximately 552,122 pounds of material was collected from member city residents, including use by 2,900 Vista residents. 7.3 Paseo Santa Fe Green Street Project The Paseo Santa Fe Green Street Project is a multi-benefit project that will convert an existing four-lane roadway to a two-lane corridor, and will include Silva Cell bioretention facilities, pervious pavement, and other stormwater management features. Phase 1 of the project was completed in 2017, providing improvements to S. Santa Fe Avenue, between Main Street and Ocean View. Shortly after, construction commenced on Phase 2 and portions of Phase 3, which would continue project features southward toward Civic Center Drive. The City has identified completion of the Paseo Santa Fe Green Street Project corridor as a priority activity, and through FY 2018-19 staff continued pursuit of grants and other resources to fund Phase 3 streetscape improvements. If the balance of funds are secured, Phase 3 could be completed with the current construction contract, expediting completion of the entire project and fulfilling three strategies in the Carlsbad Watershed Management Area Water Quality Improvement Plan (Carlsbad WQIP).

7.4 Roman Creek Project Roman Creek resides in the southern portion of the City-owned Buena Vista Park and is a tributary to Agua Hedionda Creek. Area directly adjacent to Roman Creek has been identified for wetland creation and enhancement opportunities, expanding the creek’s floodplain and increasing biological and hydrological functions. Seventy-percent design plans had previously been developed for this project, and in early 2019 a contract was awarded to assist the City with environmental studies, design, and construction. Through the reporting period, extensive field data collection activities were conducted to fulfill environmental permitting requirements and guide final project design. Submittal of environmental permits is anticipated in FY 2019-20. Project construction is projected for 2021, and upon completion, will fulfill a strategy and numeric goal identified in the Carlsbad WQIP.

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7.5 Additional Studies The City initiated a ‘data gap’ analysis to review existing GIS storm drain data. Goals of the study are to identify deficiencies and potential remedies in data that support drainage network analyses and asset management practices. Four areas of the City having varied storm drain characteristics were studied, including analysis of existing GIS data, conducting field investigations, and reviewing record drawings. All analyses have been completed and a technical memorandum is in process of being prepared.

8 Public Education and Outreach Tables 8-1 and 8-2 present summaries of citywide education and outreach activities conducted during the reporting period.

Fulfilling strategies identified in the San Luis Rey Water Quality Improvement Plan, in the previous reporting period an inventory was developed of properties in the San Luis Rey watershed and Loma Alta sub-watershed (within the Carlsbad watershed) likely to have septic systems. During FY 2018-19, previously prepared outreach materials encouraging appropriate maintenance activities and protection of Vista’s environment were distributed to property owners. Materials were sent to 84 properties, four of which resided in the Loma Alta sub-watershed.

The San Diego County Office of Education (SDCOE) and I Love A Clean San Diego continued to support education and outreach activities to Vista schools. SDCOE used “Splash Lab” and “Green Machine“ presentations at Vista elementary schools and day camps to promote anti-littering, recycling, and water quality to nearly 1,000 students. ILACSD staff delivered presentations to approximately 1,100 students, providing hands-on activities and information about watersheds and stormwater pollution. On behalf of the City, ILACSD staff also hosted an educational booth at the Vista Strawberry Festival and Movies in the Park event. City staff also conducted pollution prevention presentations to students at Vista Magnet Middle School.

Review of results from previous four rounds of RMA inspections indicate that the most commonly identified violations included control of sediment, trash management, and irrigation runoff. The City can further refine future outreach messaging to focus on BMPs to address these pollutant sources.

City and South Vista Communities staff continued to collaboratively host twice annual creek cleanup events at Buena Creek, a tributary to Agua Hedionda. South Vista Communities is a non-profit organization that represents neighborhoods in the vicinity of Buena Creek. Clean up events were held in coordination with ILACSD’s Coastal Cleanup Day and Creek to Bay Cleanup events, and were used to actively engage the community while informing residents about their watershed.

Targeted outreach to businesses regarding stormwater pollution prevention activities had been planned for FY 2018-19 to accompany the previously mentioned Paseo Santa Fe Green Street Project (see Section 7.3). These outreach activities were postponed, in part due to regular contact between City staff and businesses along the project corridor who have expressed concerns about the impact of project construction on customer traffic. These outreach activities are now anticipated to occur closer to completion of Phase 2 construction, projected in 2020.

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Table 8-1. Summary of Outreach Events Outreach Opportunity Description Dates Green Machine Outdoor education for elementary children, Multiple visits through coordinated by San Diego County Office of the fiscal year, ~590 Education. students

Splash Science Lab Science and chemistry education for children, Multiple visits through coordinated by San Diego County Office of the fiscal year, ~430 Education. students

Presentations to Schools I Love a Clean San Diego support for watershed and 23 presentations through stormwater pollution presentations at multiple the fiscal year, ~1,100 middle schools and high schools. students Pollution Prevention Calendar Distribute calendars with monthly reminders for Throughout year Distribution pollution prevention practices Summer Fun Fest at Movie I Love a Clean San Diego support for Enviroscape July 14, 2018 Night in the Park watershed model and public education. Post-construction BMP Fact Distributed information about post-construction August 2018 Sheet BMP inspection and certification program to inventoried priority development project properties. Save Your Scraps Workshop I Love a Clean San Diego and City of Vista supported August 25, 2018 workshop to educate on composting food waste. Buena Creek Cleanup Events Support and promote cleanup site for annual September 15, 2018 and Coastal Cleanup Day and Creek to Bay cleanup April 27, 2018 events. Rainy Season Informative Letters delivered to owners and developers with October 2018 Letters for Construction Sites open grading permits to inform of preparations for upcoming rainy season. Our Vista Magazine Promote Christmas tree recycling program and sites Winter 2018 to Vista Residents. Our Vista Magazine Promote upcoming used oil recycling and document Spring 2019 shredding events to Vista residents. Used Oil Certified Collection I Love a Clean San Diego support for site visits and April 2019 Center Coordination coordination with oil collection centers in Vista Classroom Presentations City staff presentations at Vista Academy of April 2019 Performing Arts and Vista Magnet Middle School National Prescription Drug Take Prescription drug collection event. April 27, 2019 Back Day Used Oil & Filter Collection Hosted oil waste/recycling and education events at April 20, 2019 Events automotive retail store in Vista. Vista Strawberry Festival I Love a Clean San Diego support for Enviroscape May 26, 2019 watershed model and public education. Document shredding and e- Shredding and electronic waste collection event at June 8, 2019 waste Event Civic Center.

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Table 8-2. Summary of Municipal Education Activities Workshop/Training Audience Attendees Location Dates Multiple ESRI - GIS User City Staff GIS Users staff & San Diego July 2018 Conference days CASQA - Annual Stormwater Professionals 3 Riverside September 2018 Conference Success with Stormwater Professionals 1 Webcast September 12, 2018 Stormwater Fees Public Works Annual Public Works Staff 52 Vista October 10, 2018 Stormwater Training Getting to YES: Successful Revenue Stormwater Professionals 2 Riverside December 5, 2018 Enhancement Strategies Annual Pesticide Safety Public Works Staff 11 Vista January 2019 Training CASQA – Federal and State Stormwater Stormwater Professionals 1 San Diego January 10, 2019 Regulatory Update Stormwater Adaptive Stormwater Professionals 2 San Marcos May 5, 2019 Management Drivers Building Division Pollution Prevention Building Division Staff 8 Vista June 26,2019 Checklist

9 Fiscal Analysis The City of Vista’s Jurisdictional Runoff Management Program is primarily funded through a combination of both Enterprise Fund and General Fund (Table 9-1). During the reporting period, grant funds were received as reimbursement for construction activities associate with Phase 2 of the Paseo Santa Fe Green Street Project. Program expenditures, including jurisdictional, watershed, and regional components, are summarized in Table 9-2.

Table 9-1. Summary of Funding Sources

Source Funding General Fund $ 2,304,143 Enterprise Fund $ 2,841,715 Special Assessment District $ 169,835 Grant Funds $ 1,195,580 TOTAL PROGRAM FUNDING $ 6,511,273

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Table 9-2. Summary of Expenditures

Program Component Expenditures Jurisdictional Administration $ 346,616 Development Planning $ 796,116 Construction $ 1,511,394 Municipal $ 1,880,261 Industrial-Commercial $ 75,571 Residential $ 33,067 IDDE $ 407,839 Public Education & Participation $ 21,334 Special Investigations $ 88,462 Grants $ 1,195,580 Subtotal - Jurisdictional $ 6,356,240 Watershed Carlsbad and San Luis Rey WMAs $ 90,627 Administration $ 48,409 Subtotal - Watershed $ 139,037 Regional Copermittee Cost Share $ 5,012 Administration $ 10,984 Subtotal - Regional $ 15,996 TOTAL PROGRAM EXPENDITURES $ 6,511,273

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Attachment B City of Vista Response to San Diego Regional Water Quality Control Board Irrigation Audit

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City of Vista Response to Regional MS4 Permit Audit of Discharge Prohibition

Background On October 26, 2018, the City of Vista (City) received results of an audit1 completed by San Diego Region Water Quality Control Board staff in August 2016. The purpose of the audit was to assess “…active and effective implementation of the over-irrigation prohibition” through review of accessible City documents and its website. Results presented in audit findings provided “…recommendations and potential non-compliance with the Regional MS4 Permit.”

In early 2019, the City prepared the following response to audit findings to be included with the Fiscal Year 2018-19 Jurisdictional Runoff Management Program (JRMP) annual report. This response addresses each component of audit results and is formatted as follows:

• Audit Headings are in bold. • Core Audit Questions are listed numerically in italics. • City responses are in plain text.

City Response to Findings Legal Authority (Provision II.E.1) 1. Has the Copermittee updated its municipal ordinance(s) to reflect the requirements of the Regional MS4 Permit? Yes.

Affirmative response to Core Audit Question.

2. Does the Copermittee have the legal authority in its municipal ordinances to prohibit over-irrigation? Yes.

Affirmative response to Core Audit Question.

Public Education and Outreach (Provisions II.E.2/II.E.7) 3. Is the over-irrigation prohibition clearly identified and easily located by the public on the home page of Copermittee web page? No

Text on the City of Vista’s stormwater home page (www.cityofvista.com/stormwater) was revised to clearly identify irrigation runoff as a prohibited discharge. On the home page, following the “Report Stormwater Pollution” heading, text now reads:

“City staff actively investigate reports of stormwater pollution. Pollutants such as trash, irrigation runoff, illegal dumping, and sediment/mud are prohibited from entering the storm drain system. Residents and businesses in Vista are encouraged to report incidents of stormwater pollution through the City of Vista’s online reporting tool.”

1 Regional MS4 Permit Audit of Discharge Prohibition, City of Vista, PIN #s CW-270204 CW-794838 CW-794836, Provision II.A.1.b, and Jurisdictional Program Provisions II.E.1, II.E.2, II.E.5, II.E.6, II.E.7, II.F.2.a, II.D.2 and II.B.3 (October 26, 2018)

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City of Vista Response to Regional MS4 Permit Audit of Discharge Prohibition

4. Is the over-irrigation prohibition clearly identified and easily located as a reportable prohibited discharge by the public through the Copermittee’s hotline reporting system, complaint form, and/or application? No

See response to Core Audit Question #3.

Access Vista is a smartphone application readily available to the public, providing information, news, and events occurring throughout the City of Vista. The application also provides a compliant reporting tool supported by GPS location settings and the smartphone camera. The Access Vista compliant reporting tool was updated to clearly identify “Irrigation Runoff” and “Stormwater Pollution” as selectable topics for submitting a complaint.

The City of Vista’s homepage (www.cityofvista.com) includes an on-line complaint reporting function. The primary website navigation bar includes a button for the phrase “HOW DO I.” This button leads the user to a webpage with a heading for “REPORT A PROBLEM,” which directs users the City’s on-line reporting tool. As with the Access Vista application, this tool was updated to clearly identify “Irrigation Runoff” and “Stormwater Pollution” as selectable topics for submitting a complaint.

The Copermittee’s regional clearinghouse website, Project Clean Water (www.projectcleanwater.org) provides means for reporting complaints anywhere in San Diego County. The “Report Pollution” tool on this website underwent significant upgrades in 2018, including use of easy to understand descriptions of prohibited discharges (including irrigation runoff) and simplified reporting fields. A hyperlink to this tool is included on the City’s stormwater homepage following the “Report Stormwater Pollution” heading.

5. Is the over-irrigation prohibition clearly identified, easily located and described for the public in the Copermittee’s storm water program web page information? No

See responses to Core Audit Questions #3 and #4.

Additionally, to reinforce the ability for public reporting of prohibited discharges, the following text was included at the bottom of each of the City’s stormwater program webpages:

“If you observe something being dumped into the storm drain or street, or observe water running in the street when it is not raining, please report this to the Water Quality Hotline: 760.643.2804 or use the Report a Problem webpage, or by email: [email protected]”

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City of Vista Response to Regional MS4 Permit Audit of Discharge Prohibition

6. Is the over-irrigation prohibition clearly identified, easily located and described for the public on the Copermittee’s public information outreach documents, handouts, or brochures? No

The “Protecting Our Waterways: How Residents Can Help” brochure targets pollution prevention activities for Vista residents (Attachment A). The brochure was updated in 2016, and prevention of irrigation runoff is mentioned in multiple locations. The “Best Management Practices for Businesses” brochure was updated in 2019, including narrative that clarifies irrigation runoff as a prohibited discharge (Attachment B). City staff routinely distribute these brochures to residents and businesses while conducting inspections, responding to complaints, and conducting outreach events. These brochures are also available in PDF format on through the City’s Online Resources webpage.

7. Does the Copermittee identify local water district prohibitions for over-irrigation and provide direct links to the water district web page drought information? No

Vista Irrigation District (VID) provides potable water to all customers within Vista city limits. The City of Vista’s website was updated to more clearly identify resources provided by VID on topics of water conservation and drought.

When residents access the City’s on-line reporting tool (see Report Question #3), users now see the following text and hyperlink to VID:

“Broken water line, water waste, or irrigation runoff. Contact Vista Irrigation District at (760) 597-3100 or www.vidwater.org”

On the City’s stormwater homepage, text following the subheading for “Water Conservation and Drought” was revised as follows:

“Vista Irrigation District provides drinking water to Vista residents. Information about water conservation and drought can be found on the District’s website.” (hyperlink included)

8. Does the Copermittee identify prohibitions for over-irrigation in its JRMP? Yes

Affirmative response to Core Audit Question.

Illicit Discharge Detection and Elimination/Enforcement (Provisions II.E.2/II.E.6) 9. Does the Copermittee actively investigate over-irrigation complaints and implement its enforcement response plan? No

As presented in Jurisdictional Runoff Management Program Annual Reports submitted to the San Diego Region Water Quality Control Board and summarized in Table 1, City staff have

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City of Vista Response to Regional MS4 Permit Audit of Discharge Prohibition

actively investigated complaints of irrigation runoff and implemented enforcement actions consistent with its Enforcement Response Plan. Over the past three years, the number of irrigation runoff-related complaints received by the City has decreased. This corresponds with state-wide easing of water use restrictions (including Vista Irrigation District) and decreased public messaging of drought conditions.

Table 1. Number of Residential Compliance Cases Where Irrigation Was Identified as Pollutant Carlsbad Watershed San Luis Rey Watershed

Cases with Cases with Fiscal Year Annual Total Cases Total Cases Irrigation Source Irrigation Source Report 100 12 4 1 2015-16 92 20 14 2 2016-17 59 4 9 0 2017-18

The City’s Enforcement Response Plan discusses that enforcement actions may consist of verbal warnings, written warnings (including violation notices), administrative citations, or public nuisance abatement. These actions provide flexibility for enforcement staff to establish appropriate corrective actions and penalties on a case-by-case basis.

The Carlsbad Watershed Management Area, Water Quality Improvement Plan Annual Report Fiscal Year 2017-18 (January 2019) provided discussion of active investigation of irrigation runoff by City staff. Within the Loma Alta Hydrologic Area section of the report, the Cities of Vista and Oceanside worked cooperatively to investigate irrigation runoff discharges from an existing residential subdivision. A verbal warning through in-field meetings achieved compliance.

Upstream investigations at persistently flowing outfalls also provide opportunity for identifying irrigation runoff as a flow source. Within the Agua Hedionda Hydrologic Area, upstream investigation at one outfall revealed a damaged irrigation line in landscape of a residential community. A written warning was issued, along with residential stormwater best management practice information. The issue was resolved and flow eliminated the same day. Visual observations, flow information, and upstream source investigation results were reported using the County of San Diego’s data sharing template as part of the Carlsbad WMA WQIP Annual Report.

10. Does the Copermittee actively coordinate over-irrigation complaints with the local water agency? No

When necessary, City staff have, and continue to, actively coordinate irrigation runoff complaints with VID. Municipal strategies IDDE 2 and ED 3 in the San Luis Rey River Watershed

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City of Vista Response to Regional MS4 Permit Audit of Discharge Prohibition

Management Area Water Quality Improvement Plan (March 2016) directly address such inter- agency coordination, where VID and City staff meet no less than annually to discuss program activities and coordination. Irrigation runoff complaints do not necessarily require inter-agency coordination for resolution. However, VID and City staff communicate directly with each other to expedite compliant resolution when appropriate.

11. Does the Copermittee actively enforce the over-irrigation prohibition through its enforcement process? No

City staff actively investigate and enforce the prohibition of irrigation runoff. Vista Municipal Code Chapter 13.18 provides legal authority for staff to enforce the prohibition (see Core Audit Question #2), and enforcement actions have been implemented by City staff to achieve compliance (see Core Audit Question #9)

12. Does the Copermittee actively coordinate its over-irrigation prohibition program with local water district programs? No

The City does actively coordinate its irrigation runoff prohibition program with VID, as discussed in responses to Core Audit Questions #7 and #10.

13. Does the Copermittee specifically identify enforcement of the over-irrigation prohibition in its JRMP? No

In Section 3.2.1 “Prohibited Discharges” of both the 2015 and revised 2017 City of Vista Jurisdictional Runoff Management Program document, irrigation runoff is clearly identified as a prohibited discharge. The prohibition of irrigation runoff is also identified within minimum Best Management Practices for existing facilities (e.g., Section 6.3 “Best Management Practice Requirements.”

In 2019, minor updates were made to the City of Vista Jurisdictional Runoff Management Program document. The document, including Enforcement Response Plan, were reviewed and edited, as appropriate, to address irrigation runoff enforcement. A ‘track changes’ version of this document is included with the City of Vista’s Fiscal Year 2018-19 jurisdictional runoff program annual report.

14. Does the Copermittee identify IDDE and enforcement of prohibited discharges in its JRMP and Enforcement Response Plan? Yes

Affirmative response to Core Audit Question.

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City of Vista Response to Regional MS4 Permit Audit of Discharge Prohibition

Water Quality Improvement Plan (Provisions II.B.3/II.D.2)

15. Does the Copermittee identify strategies for over irrigation prohibition in the WQIP? Yes

Affirmative response to Core Audit Question.

16. Does the Copermittee have a numeric goal or strategy in the accepted Water Quality Improvement Plan(s) to address pollutant reduction through prohibition of over-irrigation? Yes

Affirmative response to Core Audit Question.

17. Does the Copermittee identify over-irrigation strategies to address the High Priority Water Quality Conditions, Priority Water Quality Conditions or persistent dry weather flow from the MS4? Yes

Affirmative response to Core Audit Question.

18. Does the Copermittee actively and effectively implement the over-irrigation strategies to address the High Priority Water Quality Conditions, Priority Water Quality Conditions or persistent dry weather flow from the MS4? No

Responses to previously discussed Core Audit Questions illustrate that the City does actively and effectively implement the irrigation runoff prohibition to address water quality conditions and dry weather flows in the storm drain system. Existing facility inspections provide direct observation and opportunities for education about the prohibition. Dry weather outfall investigations have led to identification and elimination of upstream sources of irrigation runoff. The City has previously, and will continue to, implement continuous flow studies at outfalls to assist with targeted upstream investigation. Continued improvements to the public compliant reporting tools provided by the City also support active implementation of the irrigation runoff prohibition.

JRMP Strategies (Provisions II.B.3, II.E.5, and II.F.2.a) 19. Did the Copermittee update the JRMP in accordance with II.F.2.a? Yes

Affirmative response to Core Audit Question.

20. Does the Copermittee identify minimum BMPs for over-irrigation prohibition in the JRMP? Yes

Affirmative response to Core Audit Question.

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City of Vista Response to Regional MS4 Permit Audit of Discharge Prohibition

21. Did the Copermittee identify and implement the WQIP strategies in the JRMP to address persistent dry weather flow and the over-irrigation prohibition? No

To clarify how Water Quality Improvement Plan strategies are addressed in the Jurisdictional Runoff Management Program document, the City has prepared a matrix that illustrates a ‘crossroad’ for the documents. This matrix is provided in Attachment C, and has been incorporated as Appendix E within the City’s Jurisdictional Runoff Management Program document.

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City of Vista Response to Regional MS4 Permit Audit of Discharge Prohibition

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City of Vista Response to Regional MS4 Permit Audit of Discharge Prohibition

Attachment A

Protecting Our Waterways: How Residents Can Help

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City of Vista Response to Regional MS4 Permit Audit of Discharge Prohibition

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Vista Waterways Brochure_4-21-16_press.pdf 1 4/21/16 10:2

City of Vista Response to Regional MS4 Permit Audit of Discharge Prohibition

Attachment B

Best Management Practices for Businesses

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City of Vista Response to Regional MS4 Permit Audit of Discharge Prohibition

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City of Vista Stormwater Program

The City of Vista is committed to protecting and enhancing water quality in local waterways, all of Best Management Spill Response & Training which eventually flow to the Pacific Ocean. The City appreciates your cooperation in this effort Practices for • Have a spill kit on site. Consider having brooms, and staff are available to assist you with any Businesses mops, towels, absorbents and safety supplies questions or concerns. readily available. • Develop a spill response plan and provide If businesses and residents help us to prevent employees with training. urban runoff pollution, our local environment and community will benefit. For more information • Provide information about pollution prevention in regarding the City’s Stormwater and Water Quality employee areas. Protection Program, please visit our website at: Stormwater Compliance cityofvista.com/stormwater Business Inspections If you have questions about pollution prevention at your business or observe polluted runoff, City of Vista staff regularly inspect businesses to please contact the City of Vista’s Water Quality assess pollution prevention measures and ensure Hotline at: compliance. Facility inspections include a meeting 760.643.2804 (English and Spanish) with business representatives, a walk-through of the facility, evaluation of pollution prevention measures, [email protected] and recommendations for additional measures that may be required.

City staff appreciate your efforts in preventing pollution and are available to assist you with identifying site-specific pollution prevention Commercial and Industrial measures.

200 Civic Center Drive Vista, CA 92084 This publication is available in an alternate format. Please contact the ADA Coordinator at 760. 639.6145.

April 2019

City of Vista Did You Know ... Good Housekeeping Landscaping The network of catch basins and underground pipes • Routinely sweep or mop sidewalks and • Inspect irrigation system; and make that direct runoff away from streets, parking lots, and pavement. Do not wash surfaces with water adjustments to prevent runoff. rooftops during rain events is called the storm drain unless it is collected for disposal or directed to system. This system prevents flooding by directing landscaped areas. • Minimize use of fertilizers, pesticides, runoff to nearby creeks. Because runoff is not herbicides. treated at a treatment plant, it can collect a variety of • Keep site clean by regularly removing trash, pollutants, including trash, bacteria, dirt, pesticides, dirt, leaves, and debris. and fertilizers. This pollution can adversely affect the Waste Management environment and quality of life in Vista. • Place trash and recycling bins around the site. • Keep trash enclosures, dumpsters, grease • Regularly inspect site storm drain features and bins clean. Best Management Practices identify sources of pollution. • Dumpsters and grease bin lids must be Because stormwater runoff can carry pollutants in the kept closed. environment, businesses are required to implement • Wash company vehicles at a commercial car pollution prevention measures and activities, wash, not on site. • All hazardous materials/waste must be referred to as Best Management Practices. This disposed of in accordance with applicable brochure provides businesses with an overview of Material Storage & Handling State and Federal laws and regulations. important pollution prevention measures required by Contact San Diego County Environmental Vista Municipal Code (Chapter 13.18, Urban Runoff • Cover outdoor materials with a roof (permanent) Health Hazardous Materials Division for Management and Discharge Control Program). Vista or tarp (temporary), and elevate materials, where questions regarding disposal of hazardous Municipal Code prohibits all pollutants and irrigation possible, to prevent contact with rain water. materials/waste at 858.505.6900. runoff from entering the storm drain system. • Store all hazardous materials in designated areas with cover and secondary containment.

City of Vista City of Vista Response to Regional MS4 Permit Audit of Discharge Prohibition

Attachment C

WQIP and JRMP Irrigation Runoff Strategies (Appendix E of 2019 JRMP document)

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City of Vista Response to Regional MS4 Permit Audit of Discharge Prohibition

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Appendix E City of Vista WQIP and JRMP Strategies to Reduce and Eliminate Irrigation Runoff

Carlsbad WQIP San Luis Rey City of Vista Strategy Name Description of Strategy Strategy Number Strategy Number JRMP Reference The City implements an Irrigation Runoff Reduction Program (IRRP) to eliminate or reduce dry weather flow contributions, concurrent with the final goals, coming from irrigation runoff, regardless of the time of day the discharges occur. Core elements include: • Developing municipal codes that prohibit irrigation runoff • Developing educational materials and outreach program specific towards irrigation runoff Sections 3.2 and • Assessing dry weather flows at outfall(s) Irrigation Runoff Reduction 3.3.4; Section 10.4, • Identifying key times to perform site observations 14 -- Program Table 10-2; • Performing site observations to identify sources of Appendix F irrigation runoff • Collaboration with the City of Carlsbad Public Works Department to address municipal property irrigation systems • Initiating contact and correspondence with property managers/owners • Periodically assessing flows • Optionally developing and implementing an incentive program to encourage the elimination of irrigation runoff

The City implements inspections and investigations of Property-Based existing development areas to reduce discharges to the Inspections/Patrol, Existing MS4. The inspections are expected to eliminate dry weather Sections 6.4, 7.3.3, Development Facilities, 5, 15 DP 1 flows, but can also reduce the wet weather loading 8, and 9.4 Areas and Activities potential and provide opportunities for identification of Inspections, & Investigations potential retrofit projects.

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Appendix E City of Vista WQIP and JRMP Strategies to Reduce and Eliminate Irrigation Runoff

Carlsbad WQIP San Luis Rey City of Vista Strategy Name Description of Strategy Strategy Number Strategy Number JRMP Reference Based on findings from preliminary assessments, the City implements strategies to address irrigation issues found Administrative BMPs, Runoff Sections 6, 7, 8, regarding persistent, anthropogenic flows from focus area and Nutrients Source 11, 10, 22 IDDE 16, IDDE 17 and 9 and and repeat violators within focus area. The City actively Reduction, & Enforcement Appendix F enforces prohibitions related to illicit discharges and connections.

The City implements a baseline education program and makes enhancements to the program when deemed appropriate to address specific pollutants, BMPs, or target specific areas/audiences within the City. The enhancements General Education, Employee DP 3, DP 4, ED can include production and distribution of educational Training/Focused Training, 12, ED 2, ED 3, materials, outreach events, trainings or seminars, and Homeowners Association and ED 13, ED 14, individual educational encounters (one-on-one meetings). 8, 9, 17, 18, 20 Section 10 Property Manager Outreach IDDE 1, IDDE 2, The program is designed to engage the public, Program, and Outreach & IDDE 3, IDDE 4, jurisdictional staff, and other agency staff to proactively Enhanced Education Program IDDE 5, & IDDE 6 identify and report illicit discharges. The program also encourages and/or incentivizes HOAs and business property managers to implement measures to reduce dry weather and/or wet weather flows leaving their properties.

The City requires implementation of structural Sections 4.7 and Program for Retrofitting Areas ED 23, ED 33, ED (engineered) BMPs or retrofitting existing structural BMPs 12 7.3.1, of Existing Development 34 to address flow and/or pollutant issues. and Appendix B

BMP = Best Management Practice; HOA = Homeowners Association; JRMP = Jurisdictional Runoff Management Program; WQIP = Water Quality Technical Report

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Attachment A. Jurisdictional Runoff Management Program Annual Report – San Luis Rey WMA: Support Data and Supplemental Information

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Table 1-1. City of Vista Jurisdictional Area within Watershed Management Areas Watershed Management Area Acres Carlsbad 11,247 San Luis Rey 762 City of Vista Total 12,009

The 2019 JRMP document is available on the City’s website (www.cityofvista.com) and the regional clearinghouse website (www.projectcleanwater.org).).

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Two Illicit discharge-related compliance cases were initiated within the San Luis Rey WMA. In both cases the source of non-stormwater discharge was identified and eliminated.

Outfall inspections and monitoring was also conducted in support of identifying illicit discharges. Four major outfalls were monitored in the SLR WMA, two of which were dry during all site visits. Results of the two flowing outfalls are as follows:

• Outfall SLR-01 exhibited a flow rate of 7.5 and 8 gallons per minute during two separate inspections. This is an observed increase in flow from previous years, but upstream investigations continue to suggest groundwater being collected and conveyed by a subsurface perforated pipe upstream of the outfall. • Outfall SLR-03 exhibited persistent flow at a rate of 1.5 gallons per minute, consistent with observations in previous years. A flowmeter was installed to collect continuous flow measurements during the month of June. Flow and water quality sampling data is being analyzed, and will be compared with data previously collected in FY 2016-17. Results will be summarized in a report to fulfill Special Study #1, City of Vista Strategy IDDE 14 in the San Luis Rey Water Quality Improvement Plan.

In August 2016, the San Diego Regional Water Quality Control Board conducted an audit of the City’s website, municipal code, and jurisdictional documents to assess implementation of the prohibition of irrigation runoff. Results of the audit were provided in October 2018, and a response to audit findings is provided in Attachment B. Irrigation runoff is identified as a prohibited discharge Vista Municipal Code Chapter 13.18, and the City recognizes that irrigation runoff can be a source of pollutants and dry- weather flow in the storm drain system. In response to audit findings, the City made improvements to clarify irrigation runoff as a prohibited discharge, including the following:

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4.1 Homelessness As noted in the previous reporting period, the Vista City Council developed goals for the 2018-2020 period, two of which will provide citywide benefit in addressing sources of priority stormwater pollutants such as trash and bacteria. The two Vista City Council goals are as follows:

• Goal #3 – Develop a Strategic Plan to address Homelessness • Goal #4 – Continue to Decrease Blight and Improve the Image of Our City

The City partners with multiple non-profit organizations such as North County Lifeline, Operation HOPE, and Alpha Project, to provide emergency shelter, homeless outreach services, food and other basic needs, and to provide case management services. In February 2019, staff began a series of meetings in the community to discuss homelessness and solicit input on possible strategies toward addressing the issue. A multi-departmental homelessness task force was also developed to support implementation of the future strategic plan. The plan is continuing to be developed, and will include guidance though future presentations to Vista City Council in FY 2019-20. In addition to these strategic planning activities, City staff continued to respond to the environmental impacts of homeless encampments by conducting debris removal activities in the Carlsbad WMA (homeless encampments are infrequently encountered in the City’s portion of the San Luis Rey WMA).

5 Development Planning Program Development Planning Program activities are summarized in Section V on the Annual Report Form.

No new PDP sites were added to the inventory during the reporting period. Three of the eleven inventoried PDP sites were inspected (18 individual BMPs) during FY 2018-19. An additional five sites are planned for inspection in early FY 2019-20 as continuation of annual inspections in 2019.

During the reporting period a revised “Building Permit Stormwater Pollution Prevention Checklist” was developed. The checklist is used to review projects that only require building permits, identifying pollution prevention practices to be implemented based on permitted activities. The checklist is then used to identify sites to be scheduled for targeted inspections for pollution prevention compliance (additional to site inspections conducted by Building Division staff).

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6 Construction Management Program Construction Management Program activities are summarized in Section VI on the Annual Report Form.

City staff continued to implement an effective construction management program through scheduling of site inspections at a frequency of monthly during the dry season and weekly during the rainy season. During the reporting period, 93 inspections were conducted at four active construction sites in the SLR WMA. Eight enforcement actions were issued, with one site being issued a stop work order and notification of non-compliance to the San Diego Regional Water Quality Control Board.

7 Existing Development Management Program Existing development inspections and enforcement actions are summarized in Section VII of the Annual Report Form.

7.1 Existing Development Facilities To develop the inventory of industrial and commercial facilities subject to pollution prevention inspections, business license data is now queried by Standard Industrial Classification (SIC) numbers. This query changed the distribution of how facilities are classified in the inventory, with fewer facilities identified as Commercial but more facilities identified as Industrial. Facility inspections during FY 2018- 19 were focused on the Carlsbad WMA, therefore only one facility in the SLR WMA was inspected. This facility had previously been identified as an Industrial facility, however for consistency with the updated business license query it is now identified as Commercial.

All three inventoried Municipal facilities were inspected. The County-owned Guajome Regional Park was added to the inspection inventory due to its size and proximity in the San Luis Rey WMA.

Two of the City’s 20 Residential Management Areas (RMAs) are within the San Luis Rey WMA, and both were inspected. Two violations were observed. Results from city-wide RMA inspections indicate discharge control (i.e., irrigation, runoff, or water discharge), waste management, and sediment control were the three most commonly observed deficiencies.

7.2 Municipal Activities Routine sanitary sewer maintenance activities continued, guided by response and management plans updated in 2018. City-wide, staff responded to fourteen private sewer lateral spills and one sanitary sewer overflow (none of which were in San Luis Rey WMA). No Fats, Oils, and Grease (FOG) inspections were conducted, as few food service establishments exist in the San Luis Rey WMA and additional citywide FOG inspections are planned for FY 2019-20. Of 33 inventoried storm drain inlets, 12 were cleaned, removing approximately 1 cubic yards of debris. To remove debris and pollutants before entering the storm drain system, street sweeping activities continued with high and moderate-rated roadways being swept twice per month and low-rated roadways being swept monthly.

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Additional activities conducted during the reporting period that support stormwater pollution prevention in the City’s developed areas include the following (not limited to the San Luis Rey WMA):

• Maintained 110 trash bins at bus stops and high pedestrian use areas throughout the City. • Christmas tree curbside collection and drop-off locations active between December 26, 2018 and January 12, 2019. • Continued support of certified oil collection centers within the City. Used oil collection centers recovered approximately 26,890 gallons of oil and 3,000 oil filters. • Document shredding and e-waste collection event on June 8, 2019. • Continued operation of the Household Hazardous Waste facility that serves member cities of Carlsbad, Encinitas, Escondido, Solana Beach, and San Marcos. During the reporting year, approximately 552,122 pounds of material was collected from member city residents, including use by 2,900 Vista residents. 7.3 Additional Studies The City completed San Luis Rey WMA Special Study #2 (Assess hydraulic connectivity to lower San Luis Rey River. Through field investigation and GIS analyses, study results indicate that most stormwater flows from the City’s jurisdictional area discharge to a wetland area adjacent to Guajome Lake, prior to flowing to the San Luis Rey River. Remaining flows comingle with private property drainage before discharging to Guajome Lake. Completion of this study provided new understanding of where flows are conveyed in the northern portion of the City’s jurisdiction. The City initiated a ‘data gap’ analysis to review existing GIS storm drain data. Goals of the study are to identify deficiencies and potential remedies in data that support drainage network analyses and asset management practices. Four areas of the City having varied storm drain characteristics were studied, including analysis of existing GIS data, conducting field investigations, and reviewing record drawings. All analyses have been completed and a technical memorandum is in process of being prepared.

8 Public Education and Outreach Tables 8-1 and 8-2 present summaries of citywide education and outreach activities conducted during the reporting period.

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the City, ILACSD staff also hosted an educational booth at the Vista Strawberry Festival and Movies in the Park event. City staff also conducted pollution prevention presentations to students at Vista Magnet Middle School.

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Splash Science Lab Science and chemistry education for children, Multiple visits through coordinated by San Diego County Office of the fiscal year, ~430 Education. students

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Table 9-1. Summary of Funding Sources

Source Funding General Fund $ 2,304,143 Enterprise Fund $ 2,841,715 Special Assessment District $ 169,835 Grant Funds $ 1,195,580 TOTAL PROGRAM FUNDING $ 6,511,273

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Table 9-2. Summary of Expenditures

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Attachment B. City of Vista Response to San Diego Regional Water Quality Control Board Irrigation Audit