Surfrider San Diego is supportive of:
- The new regional structure of the permit.
- The watershed-based approach.
- The shift to become “outcome-oriented” instead of “action oriented”.
- The increased reliance on Best Management Practices (BMPs) and Low Impact Development (LID) to improve water quality.
- The increased stakeholder and public involvement in the Water Quality Implementation Plan process.
Surfrider San Diego is opposed to:
The “safe-harbor” clause recently added to the revised draft permit on page 31. The “safe-harbor” clause takes the teeth out of the new regional permit by granting co-permittees a “safe harbor” from litigation if they complete a checklist of requirements. No one wants an overly litigious environment, but members of the public and vested environmental organizations need to maintain their ability to sue for egregious violations of water quality parameters. Without the threat of potential enforcement actions, the stormwater permit would be completely ineffective. The fact is, we just celebrated the 40th-anniverary of the Clean Water Act, and we are still not reaching those goals! There is no room for a “safe harbor” clause for our region when it comes to stormwater.
The safe harbor is a “poison pill”, and if it remains, Surfrider and fellow environmental organizations will be forced to oppose the new permit. Surfrider believes the safe harbor clause is a step-backwards in stormwater management and may in fact be illegal.
If you are interested in these issues please join us at the Regional Water Quality Control Board hearing on April 10th from 4-6pm at 9174 Sky Park Court, Suite 100. Also, be sure to check out our Know Your H2O committee, future meetings are posted here.