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“C.3” Compliance
Assistance to the City of Milpitas

Example site design for C.3 compliance
Update—January 2006
During 2005, Dan assisted City of Milpitas staff to update the Stormwater C.3 Guidebook. He also developed proposed language to be considered in a draft update to the Water Quality and Conservation element of the City's General Plan.
During 2004, Dan assisted City staff to prepare Guidebook Appendix H, which provides step-by-step instructions for preparing a stormwater treatment facility operation and maintenance plan.
Update—October 2003
Dan is completing revisions to the City of Milpitas Stormwater C.3 Guidebook.
Changes include the addition of instructions for preparing a detailed “Stormwater Facilities Management Plan.” These plans specify the operation and maintenance requirements and schedules for stormwater treatment facilities on development sites subject to the new Provision C.3 requirements.
In addition, the updated Guidebook includes new tips for designing BMPs and incorporates applicable guidance released by the Santa Clara Valley Urban Runoff Pollution Prevention Program in June 2004.
Background
Beginning in late 2002, Dan has been assisting the City of Milpitas to comply with the San Francisco Bay Regional Water Quality Control Board's “C.3” requirements for new development.
The Water Board's new "C.3" provisions require local governments to revise development review procedures so that future development and redevelopment projects are designed--to the maximum extent practicable--to prevent pollutant discharges, minimize the impact of increased runoff on streams, and protect beneficial uses of receiving waters.
Dan facilitated a Guidebook Committee comprised of staff from the City's planning, land development, engineering, and building permit review departments. Development of the guidebook focused on two principles:
- The Guidebook must help the developer prepare the require submittal.
- The Guidebook must help City staff determine whether the submittal meets minimum requirements.
The first key decision was to incorporate C.3 compliance review into review of the applicant's Planning and Zoning review submittal. By linking C.3 compliance with the City's existing procedures for reviewing site and landscape designs, Milpitas is able to streamline review and foster an integrated, low-cost approach to the design of stormwater control measures.
To simplify preparation and review of submittals, Dan recommended that the City require developers to compile and format all required C.3 compliance information into a project "Stormwater Control Plan." The information required includes:
- Existing conditions, such as hydrologic features, soil types, and depth to groundwater.
- Locations and types of potential pollutant sources.
- Existing and proposed site drainage network.
- Sizes of proposed pervious and impervious areas.
- Design features and treatments used to reduce imperviousness.
- Locations of stormwater infiltration or treatment BMPs.
The "Stormwater Control Plan" outlines the control measures in sufficient detail to insure that they are incorporated into the project's site, landscape, and drainage design, and that the control measures are buildable.
Project conditions of approval require that features in the "Stormwater Control Plan" be fully designed and detailed when the project construction documents are submitted for building permits.
The Stormwater C.3 Guidebook provides guidance for preparing the "Stormwater Control Plan." Because people use and retain information in different ways, the guidance presents the guidance in four formats:
- A checklist of items to be included in the plan.
- Step-by-step instructions for preparing the plan.
- An outline for the plan and accompanying report.
- A sample Stormwater Control Plan.
In another innovation, Dan recommended that the Stormwater C.3 Guidebook's design guidance emphasize the use of small treatment devices (BMPs) that can be incorporated into the landscaping throughout the site, rather than concentrating runoff and directing it to large BMPs. These smaller BMPs, which can be configured as bioretention areas, flow-through planter boxes, or underdrained swales, have fewer maintenance requirements and are less likely to breed mosquitoes than large devices (such as detention basins or wetlands) that hold water for extended periods of time.
The City of Milpitas Planning Commission adopted the completed Stormwater C.3 Guidebook in September 2003, well ahead of the Water Board's deadline for updating development review requirements.