Strategic Planning to Implement Bacteria TMDLs in San Diego — Balancing Practicality with Success

San Diego is re-known as a primary vacation destination with beautiful and safe beaches to recreate. However, due to recent exceedances of water quality standards associated with indicator bacteria such as fecal coliform, the San Diego Regional Water Quality Control Board (Regional Board) and the U.S. Environmental Protection Agency Region IX (USEPA) has established TMDLs for many high-use beaches in the region. The City of San Diego is now faced with a huge challenge to address associated TMDL wasteload allocations for storm water, which have been designated as a major source of these indicator bacteria. With sources of bacteria ranging from animal waste and other human activities, which are transported by storm water to the beaches, the responsibility of the City to treat storm water using its infrastructure and storm water program elements, to the maximum extent practicable (MEP), is a topic that requires much analysis and planning, and could result in billions of investment without noticeable improvements unless a clear strategy is in place.The City of San Diego is in the process of developing Comprehensive Load Reduction Plans (CLRPs) to address TMDL requirements, which will focus on how to reduce bacteria loads and densities from storm water, as well as other pollutants for which TMDLs are planned or adopted in the region. These plans will identify a strategic plan for implementation of best management practices (BMP), and identify the MEP that such practices can feasibly meet wasteload allocations per the schedule set by the TMDL. This strategy must consider the reasonableness of funding capabilities, the ability of structural and nonstructural BMPs to reduce bacteria to acceptable levels, and provide assurance that ultimate success will be measured by the safety of recreational uses in San Diego's beaches. This is in line with ensuring that San Diego's greatest asset and source of tourism remains a priority, thereby continuing to serve the City's economy as one of the country's greatest tourist attractions.The plan will provide quantitative analysis of the benefits and costs of alternative BMP implementation scenarios, and must include negotiations with the Regional Board regarding the economic feasibility of storm water infrastructure and program improvements. Clean beaches are the ultimate goal of the City of San Diego, and the strategic plan will layout a roadmap to ensure that this goal is achieved.