Long Term Management Strategy for the Placement of Dredged Material in the San Francisco Bay Region (LTMS) Program

In 1990, due to concerns regarding mounding of dredged material at the main disposal site, near Alcatraz Island, and potential impacts from dredging and dredged material disposal to water quality, wildlife, and uses of the Bay, the San Francisco Bay Conservation and Development Commission (BCDC), the San Francisco Bay Regional Water Quality Control Board (RWQCB), the San Francisco District of the U.S. Army Corps of Engineers (COE), and the U.S. Environmental Protection Agency (EPA) created the LTMS program. The LTMS has four main goals:

• Maintain in an economically and environmentally sound manner those channels necessary for navigation in San Francisco Bay and Estuary and eliminate unnecessary dredging activities in the Bay and Estuary;

• Conduct dredged material disposal in the most environmentally sound manner;

• Maximize the use of dredged material as a resource; and

• Establish a cooperative permitting framework for dredging and disposal applications.

During the 1990’s the LTMS agencies analyzed the potential impacts of dredging and disposing of dredged material from federal navigation channels, ports, refineries, marinas and privately owned docks, conducted demonstration projects, designated a new San Francisco Deep Ocean Disposal Site (SFDODS) fifty miles out to sea, and prepared a proposed LTMS.  In 2000, the LTMS agencies adopted the LTMS plan to reduce in-Bay disposal of dredged material and to maximize the beneficial reuse of  dredged material. Beneficial reuse includes constructing wetland restoration projects in areas that had been historically diked off from the Bay and subsided, such as Hamilton and Montezuma Wetland Restoration Projects; levee repair in areas such as the Delta; and use as construction fill where appropriate.

Currently, there are four open-water dredged material disposal sites in San Francisco Bay: (1) the Alcatraz disposal site (SF-11); (2) the San Pablo Bay disposal site (SF-10); (3) the Carquinez Strait disposal site (SF-9); and (4) the Suisun Bay disposal site (SF-16), which is only available to the COE. The LTMS Management Plan reduces aquatic disposal in the Bay using four, three-year “step-down” periods, by the end of which, in 2012, in-Bay disposal of dredged material will be reduced to approximately 1.25 million cubic yards (mcy) per year. SFDODS is available for dredged material disposal when beneficial reuse is not available or feasible. The LTMS program is in its third step down period. The average annual in-Bay disposal volume target limit is currently set at 2.1 mcy. Each aquatic disposal site also has monthly and annual target disposal volume limits. If the number of projects requesting disposal at a specific site are projected to exceed the monthly or annual limits, the LTMS agencies redirect disposal to an alternate disposal site.

Dredged Material Management Office (DMMO)

The DMMO was created as part of the LTMS program to provide a “one-stop shop” for processing applications for dredging and disposal projects in the San Francisco Bay region. Each LTMS agency provides personnel to help staff the DMMO. Also participating are the California Department of Fish and Game (DFG), NOAA’s National Marine Fisheries Service (NOAA Fisheries), and the U.S. Wildlife Service (FWS), who provide expertise and technical advice on potential biological impacts of proposed projects. The DMMO cooperatively reviews sediment quality sampling plans, analyzes the results of sediment quality sampling, makes suitability determinations for disposal, and processes permit applications for dredging projects proposed for disposal in San Francisco Bay, the SFDODS, and beneficial reuse sites. Applicants use a consolidated DMMO permit application for dredging projects, and the agencies jointly review the applications and sediment data at bi-weekly meetings before issuing their respective permits and authorizations.

The goal of this interagency group is to increase efficiency and coordination between the member agencies and to foster a comprehensive and consolidated approach to handling dredged material management issues. The DMMO also manages and tracks dredging and disposal projects in the region.

Environmental Work Windows for Maintenance Dredging Projects

As part of the implementation of the LTMS, the agencies initiated state and federal Endangered Species Act consultation with NOAA Fisheries, FWS and DFG for maintenance dredging and disposal projects, covering threatened and endangered species and species of special concern, such as the Pacific herring. These consultations reduced the need for individual consultation for maintenance dredging projects through the establishment of programmatic work windows. Based on the project location and potential species presence, each dredging project has a “work window” each year, during which individual consultations are not needed.

In addition, the programmatic biological opinion provides federal endangered or threatened species “incidental take” authorization for projects working within the environmental work window for their area. This “take authorization” protects the dredger from enforcement action in the event of accidental harm to a listed species as a result of the dredging project. In the event that a project cannot be completed during the work window, individual consultations with the appropriate resource agencies can occur. The outcome of the individual consultation would determine whether any additional dredging period for that project is appropriate, and, if necessary, provide a “take authorization.”