City of Salinas: A Collaborative Relationship With Your State Regulator

THE CLIENT

City of Salinas, CA

NPDES program manager Heidi Niggemeyer, CPSWQ

Located on the Central Coast of California, Salinas is the county seat and largest municipality in Monterey County, serving as the main business, industrial, and government center for the region. An urban area with a population of over 160,000, it is primarily known for its prominent role in California’s agriculture and farming economy. Salinas sits just inland from the Pacific Ocean and the mouth of the Salinas River Valley. The city is surrounded by impaired waterways on the EPA 303(d) list and is required to reduce pollutant loading to address several TMDLs.

THE CHALLENGE

So Much Work, So Little Impact

It was early 2017, and Heidi Niggemeyer, NPDES (National Pollutant Discharge Elimination System) Program Manager for Salinas was grappling with multiple, related challenges. The most immediate and frustrating was compiling the city’s NPDES Municipal Separate Storm Sewer System (MS4) Permit annual report to the State Regional Water Quality Control Board. At the same time, she was still struggling to figure out how to comply with several of the MS4 permit requirements — many of them vague or hugely resource-intensive to meet — plus she knew that Salinas was due for a new MS4 permit soon, which was a worry in itself. The 2012 MS4 permit had been so difficult to comply with, and many of the requirements were just paperwork exercises that did nothing to support management of a stormwater program. What if the next permit was even more onerous for the city?

A Thousand Hours to Create a 2,000 Page Annual Report

At the time, compiling the city’s MS4 NPDES annual report regularly took over 1,000 hours, involved a dozen city staff members, and totalled nearly 2,000 pages. All that work was a literal headache for Heidi: she measured her anxiety during each year’s reporting season in the number of migraines that she got while producing it.

“Costs are way down — literally cut in half”

The city’s annual report took so much time and effort to compile because the city staff responsible for the implementation of different pieces of the permit were scattered across multiple departments. Multiple teams generated and managed the data, and everyone stored their own data separately, on paper in file cabinets in city offices or on individual computers. Just finding the required pieces of data was a challenge.

Creating the report was a huge resources sink, but worse: those long columns of numbers didn’t tell Heidi, or the state regulators, whether the water was getting any cleaner. Those 2,000 pages only provided evidence that the required sampling, inspections, and actions had taken place. All that data had to be manually summarized in tables and lists with no easy way to analyze it. And there was no connection between the data and Heidi’s need to comply with other permit requirements, like those for new or redevelopment projects or the several TMDLs in her permit.

For example, Salinas’ water quality monitoring program was the most costly stormwater program, requiring hundreds of thousands of dollars each year to grab samples from the regulated receiving waters that run through the city. But the annual reports summarizing this program were piles of tables and charts. Heidi could not use those tables and charts of water quality analytical lab results to understand how effective her stormwater program efforts were at improving Salinas stormwater quality, or where to her focus efforts to make actual progress. Salinas’ water quality monitoring program suffered from the same problem as the rest of the MS4 NPDES programs: a lot of data but very little insight.

To communicate her program’s impact, Heidi knew she needed a holistic solution for compliance, one that would help her organize and track all the city’s efforts, standardize data collection, pull the data into a report with minimal effort, and let her analyze the numbers to understand what was working and what wasn’t. With such a system, Heidi could use that data to evaluate the effectiveness of her program and strategically plan what changes and investments might actually give the result that both she and the state regulators were working toward: cleaner stormwater  for Salinas.

A Litigious Relationship With Regulators

Like a number of permittees, in the past Salinas had a contentious relationship with the Regional and State Water Board. Salinas city leaders argued that they couldn’t be held responsible for water pollution that came from surrounding agricultural lands that they have no jurisdiction over. They claimed that the regulatory expectations for stormwater quality management were both impractical and unaffordable.

“2NDNATURE has brought critical quantification and geospatial intelligence to advance watershed scale management of stormwater.” —Dominic Roques, retired water quality regulator for the state of California

The city threatened to sue, and the meetings between the city and the State’s Regional Water Quality Control Board were bitter, with lawyers present and many angry diatribes. The situation was bad.

Finally, Salinas acknowledged that it would have to comply with stormwater requirements, but that grudging admission left them back where they began: trying to comply with requirements that they worried were both difficult to achieve and would cost a lot of money to comply with.

Heidi was brought in to run Salinas’s stormwater compliance program in late 2015,  She took a sensible approach and started asking questions. She opened up the dialog with the city regulators to clarify the meaning of the permit, and what, exactly, it required. “What if we do it this way?” she asked. “Does that mean we’re supposed to do this?” Together, they parsed the language, and began to build a productive relationship, along with a better understanding of practical, feasible and concrete actions she and her team could take to comply with the regulations and efficiently track and demonstrate that compliance.

OUR SOLUTION

A Better Approach, a Better Tool, a Better Relationship with Regulators

Heidi went looking for a tool that would help her achieve her goals. In 2018 she found 2NFORM, 2NDNATURE Software’s cloud-based platform for stormwater management and MS4 NPDES compliance.

With 2NFORM, Salinas has reduced both the cost and complexity of all aspects of the city’s stormwater program. Today, not one element has remained untouched. The cloud-based software has enabled a digital transformation of the city’s MS4 compliance program. 2NDNATURE’s system-level approach brings geospatial intelligence through new technology and tools to solve old problems. The results are impressive. Every step in the process that Salinas uses for NPDES MS4 compliance is more efficient and more effective with 2NFORM, from collecting the data to organizing it to demonstrate compliance. Dozens of users who contribute data to the City’s stormwater program collaborate within this single solution. Data analysis has become possible in an entirely new way, allowing data-driven evaluation of program needs and strategic planning. And costs of routine compliance are way down, literally cut in half.

Data Collection: With 2NFORM, all of the people that contribute data relevant to the stormwater program collaborate within a single solution. Workflows and information are tailored to each user, but Heidi can see it all.

With 2NFORM, trained interns can perform field inspections and assessments, freeing up valuable higher level staff time. Using intuitive and repeatable field protocols, they enter data directly into their mobile devices, rather than relying on paper and pencil in the field. The data needs are standardized, so it’s easy to compare apples to apples when analyzing the data. They can check results right in the field for better quality assurance and control. Entries seamlessly sync to the 2NFORM central geospatial database, so that everyone who needs the information can access it.

The entire stormwater team can now see the history and status of key stormwater program elements, such as stormwater structural BMPs, catch basins and other stormwater assets, low impact development projects, construction projects, and more. Heidi can view and filter all of the city’s data in easy to understand maps, forms and tables at any time.

Data Driven Insights: The automated analytics within 2NFORM turn data into actionable information. Now Heidi has city-wide maps that are generated automatically and showed her where stormwater program improvements were needed most. She is able to more efficiently and accurately estimate her municipal maintenance operations and management budget, and better plan for required inspections and workflows. With peer reviewed science embedded in the solution, the analysis from 2NFORM provides a quantitative description of the city’s environmental accomplishments of pollutant load reduction progress. These insights give Heidi the solid foundation she needs to shape a stormwater program that strives to meet clean water goals, not just checked boxes.

This is what a science-based, data-driven stormwater program can do.

Compliance: Using 2NFORM, the city’s stormwater program data is integrated and stored in the cloud, allowing easy sharing across multiple departments, and getting rid of frustrating departmental silos.

Over time, Heidi developed a collaborative — rather than litigious — relationship with her regulators. Dominic Roques, a now-retired water quality regulator for the state of California, who worked closely with Heidi, calls 2NDNATURE “visionary.” He hopes more cities, counties and DOTs around the country join in this forward-thinking approach of collaborating with their regulators to create more useful permits and utilizing new technology to make their work easier and their stormwater programs more effective. “2NDNATURE has brought critical quantification and geospatial intelligence to advance watershed scale management of stormwater,” Dominic says. “And they are listening to what permittees say they need and what regulators say they want.”

From a public perspective, the 2NFORM data visualization inspires engagement and allows program managers to easily share program accomplishments and priorities with a variety of groups, including city councils, technical staff, community members, and more, helping Salinas comply with the public outreach requirement in their permit.

And that huge, time-consuming, expensive annual report? For the past few years, Heidi reports zero migraines. 2NFORM translates the data already in the system into a comprehensive report with the click of a button. Months of effort have turned into weeks spent on final checks and organization. And Heidi knows that their data is solid, so she isn’t worried about questions or audits. She knows she has good answers at her fingertips.

The Results

  • A transformed relationship with the State Regulator from combative to collaborative equating to reduced risk associated with regulatory compliance.
  • A holistic integrated stormwater solution grounded in geospatial intelligence that allows multiple agency personnel to collaborate, and focus on optimizing program effectiveness.
  • More effective communication to stakeholders — city councils, technical staff, and the public — about the impact the stormwater program has and can have on the local community and its receiving waters. Better understanding and awareness of the value of stormwater is increasing stakeholder support for stormwater improvements in the City
  • More than 2x cost savings throughout program elements, allowing the city to better focus limited resources on improving urban land management.

Check out the City of Salinas’ stormwater website, with up-to-date program data: www.cleanwatersalinas.com