AMERICAN RIVERS NATURAL RESOURCES DEFENSE COUNCIL together with Los Angeles Waterkeeper Petition For A Determination That Stormwater Discharges From Commercial, Industrial, And Institutional Sites Contribute To Water Quality Standards Violations in the Alamitos Bay/Los Cerritos Watershed (Los Angeles County, California) And Require Clean Water Act Permits September 17, 2015 Jared Blumenfeld, Regional Administrator EPA Region 9 75 Hawthorne Street Mail Code: ORA-1 San Francisco, CA 94105
[email protected] Dear Regional Administrator Blumenfeld, American Rivers, the Natural Resources Defense Council, and Los Angeles Waterkeeper hereby petition you, the Regional Administrator of U.S. Environmental Protection Agency Region 9, for a determination that currently unpermitted stormwater discharges from privately- owned commercial, industrial, and institutional sites are contributing to violations of water quality standards in the Alamitos Bay/Los Cerritos Channel watershed, and therefore require National Pollutant Discharge Elimination System (NPDES) permits pursuant to Section 402(p) of the Clean Water Act.1 Evidence summarized in this petition and included in the attached Exhibits shows that commercial, industrial, and institutional (CII) sites are unquestionably contributing to the watershed’s zinc, copper, and ammonia impairments because: • CII sites occupy 30.6% of the land area in the Alamitos Bay/Los Cerritos watershed. • 93.0% of this CII area is located within a half-mile of a receiving water. • Modeled results indicate that, out of all urban stormwater sources, CII sites contribute at least 30% of zinc loadings, 18% of copper loadings, and 26% of nitrogen loadings in the watershed. • CII sites likely cover 21.4% of the watershed with impervious surface.