Comparative Analysis of Regulatory and Compliance Strategies in Commercial, Industrial, and Institutional (CII) Stormwater Permits

The Los Angeles Regional Water Quality Control Board (LARWQCB) has proposed a Commercial, Industrial, and Institutional (CII) National Pollutant Discharge Elimination System (NPDES) Permit to address stormwater discharges from facilities in the Dominguez Channel/Greater Los Angeles and Long Beach Harbor Watershed and the Los Cerritos Channel/Alamitos Bay Watershed. Initiated under the United States Environmental Protection Agency's (USEPA) Residual Designation Authority (RDA) and 40 CFR 122.26 regulations, this permit seeks to mitigate pollutant loads generated by impervious surfaces, including parking lots, rooftops, and access roads, at an estimated 600&700 facilities in the watersheds. Affected facilities include industrial stormwater dischargers, No Exposure Certification (NEC) sites, and other CII facilities with impervious areas exceeding five acres. This presentation will provide a detailed examination of the proposed CII Permit, including its regulatory context, pollutant loading assessments, and compliance pathways. Attendees will gain insights into the three primary compliance options offered by the permit: (1) participation in regional projects through agreements with Watershed Management Groups (WMGs), (2) implementation of facility-specific design standards to reduce stormwater runoff, and (3) direct demonstration of compliance with effluent limitations. To ground this regulatory framework in practical application, three real-world case studies will be presented. These case studies highlight the technical, economic, and operational considerations associated with each compliance option, offering conceptual cost estimates for capital investments, operation and maintenance, feasibility analyses, and scheduling. Through this analysis, dischargers can better understand potential financial and operational impacts and make informed compliance decisions. The presentation will conclude by addressing the broader implications of the CII Permit, including its potential expansion to other watersheds across California and the significance of USEPA's RDA in shaping stormwater policy. By providing clear takeaways and actionable insights, this presentation will equip attendees with the knowledge needed to navigate the proposed regulatory landscape and prepare for permit adoption and implementation.