Because of the confusion about street sweeping as a required regulatory activity, I asked Keith H. Lichten, Chief, Watershed Management Division, SF Bay Regional Water Quality Control Board, to explain it. Click here for his response.
Lichten writes. “While street sweeping is not a control action specifically required in the MRP, municipalities can choose to implement an effective street sweeping program to comply with particular MRP requirements.”
While street sweeping is not a control action specifically required in the MRP, municipalities can choose to implement an effective street sweeping program to comply with particular MRP requirements. For example, one method for achieving PCBs load reductions required under MRP Provision C.12 – PCBs Controls, involves street sweeping as a means of preventing PCBs-laden sediment from entering receiving waters through the MS4. Similarly, to comply with MRP Provision C.10 – Trash Load Reduction, Permittees may choose to implement trash control actions, such as street sweeping, that are equivalent to controlling the discharge of trash through installation of a full trash capture devices. In such cases, a municipality may choose to implement street sweeping, in combination with on-land cleanup efforts and other control actions, as a method of preventing the discharge of trash to receiving waters via the MS4 system. To date, Richmond has achieved an 87 percent reduction in trash relative to 2009 baseline conditions. The City implements enhanced street sweeping as a method for controlling the discharge of trash to receiving waters in six of its nine trash management areas where “other trash management actions” are implemented.
If Richmond abandons effective street sweeping, which requires signs and enforcement, the City will have to consider other, and probably more expensive, means of limiting the discharge of pollutants in stormwater.
Halting an effective street sweeping program is a core value of the Richmond Progressive Alliance as they pander to a minority of environmentally insensitive residents of the districts that elected them.
For more information, contact:
Keith H. Lichten, Chief
Watershed Management Division
SF Bay Regional Water Quality Control Board
1515 Clay St., Suite 1400
Oakland, CA 94612
Tel. (510) 622-2380
Fax (510) 622-2460