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The Municipal Regional Stormwater Permit (MRP) (Order No. R2-2015-0049) requires the development of Green Infrastructure (GI) Plans (Provision C.3) and Polychlorinated Biphenyls (PCBs) and Mercury Control Measure Implementation Plans (Provisions C.11 and C.12) that provide the necessary pollutant load reductions to meet Total Maximum Daily Load (TMDL) waste load allocations (WLAs) over specified compliance periods.

A key component of these plans is a Reasonable Assurance Analysis (RAA) that quantitatively demonstrates that proposed control measures will result in sufficient load reductions of PCBs and mercury to meet WLAs for municipal stormwater discharges to the Bay. The City/County Association of Governments (C/CAG) of San Mateo County, via its San Mateo Countywide Water Pollution Prevention Program (SMCWPPP), led a county-wide effort to develop an RAA to estimate the baseline PCB and mercury loads to the Bay, determine load reductions to meet WLAs among San Mateo County Permittees, and set goals for the amount of GI needed to meet the portion of PCB and mercury load reduction the MRP assigns to GI (SFBRWQCB 2015). The following reports document the development and results of the RAA for San Mateo County permittees:

  • Phase I Baseline Modeling Report – Provides documentation of the development, calibration, and validation of the baseline hydrology and water quality model, and the determination of PCB and mercury load reductions to be addressed through GI implementation (SMCWPPP 2018).
  • Phase II Green Infrastructure Modeling Report – Provides documentation of the application of models to determine the most cost-effective GI implementation for each municipality, setting stormwater improvement goals for the GI Plan (SMCWPPP 2019).