Monitoring Berkeley's
Street Sweeping Program

Re: Monitoring Berkeley's Street Sweeping Program
To: Berkeley City Council
L A Wood, January 25, 1993

Monitoring
In the past, Berkeley's street sweeping was done with an emphasis on litter control. The effectiveness of the street sweeping process was measured by simple observation. When a street looked clean, then it was. This idea marks our first attempts to monitor street cleaning and to quantify its environmental impact. There is very little collected data before 1991 concerning the effectiveness of street sweeping. In fact, until this time, mechanical sweepers had never attempted a scheduled sweep of the entire city of Berkeley.

In 1991, Berkeley began to institute its citywide Clean Water Program (CWP). The objectives of our street cleaning program were changed as sweeping was recognized as an important strategy in the control of nonpoint source pollution. It is the simple idea that urban city streets contain more than just litter that has helped to shape our federal runoff, program. As a consequence, the monitoring of street sweeping effectiveness has also changed.

Monitoring of the CWP is directed at numerical water quality standards (more than just looking). This program of measurement, though slow in development, has begun to provide some understanding of the source of runoff pollutants, their varied content, and the value of our designated clean water activities, such as street cleaning. Data collection associated with this program continues to be integral to the development of management strategies (Best Management Practices, BMPs). Coordinated by our regional water board, Berkeley and other CWP participants are contributing to an environmental data bank on a quarterly basis. It is this substantive data collection which guarantees a more accurate measure of the storm water pollution problem. Now, for a street to look clean is not enough.

Recent testing by the ACURCWP is revealing high levels of pollutants generally associated with automobiles (lead, copper, and petroleum by-products). Testing has been limited to several ACURCWP participants. Generally, most cities have resisted the implementation of numerical effluent limits and prefer to rely on the employment of BMP standards as a means of monitoring and controlling urban runoff. Even these minimum standards are being avoided by some participants, including Berkeley.

BMPs for street sweeping operate under a number of premises. First is the idea that we will sweep all. accessible urban roadway surfaces. Equally important is the concept of uniform and effective cleaning practices. BMPs are designed to eliminate some of the variables in the monitoring process and to add some controls to the program. Our storm water NPDES permit requires diligent attention to BMPs and that residential street sweeping must not fall below pre-program levels.

Berkeley's Opt-out Program

After more than a year into the opt-out program, the City of Berkeley is finally asking questions about the effects of this facet of our sweeping program on the Clean Water Program. It is apparent that the effectiveness of street cleaning is being hindered by the opt-out feature. In fact, opt-out fails to uphold BMP standards.

In an informational item to the Public Works Commission on January 8, 1993 (see attachment), Public Works offered a survey form for opt-out monitoring. This survey, when employed, will attempt to monitor opt-out blocks. It designates Public Works staff to begin observing these blocks to see if they are being properly cleaned. This type of monitoring is directed at litter control only Partial monitoring is inadequate given our clean water plan.

Some opt-out blocks that were swept before October 1991 are no longer visited by our mechanical vacuum sweepers. Other opt-out blocks only experience a "hit or miss" sweep. This style of street sweeping fails to address urban street borne pollutants related to runoff and that mechanical vacuum sweeping is more apt to affect the removal of these pollutants.

It should be noted that, to date, no instructions (BMPs) on cleaning city streets have been issued to opt-out participants. No block has ever been returned to the controlled parking street sweep. The fact is no opt-out block has ever been challenged concerning its cleaning performance.

The Community Environmental Advisory Commission (CEAC) was asked by Council (Dec 15) to review the environmental impact of the opt-out feature on Berkeley's street sweeping program. CEAC, at its January '93 meeting, discussed the issues as expressed in the council communication, "Berkeley's Street Sweeping Program(s)." In a unanimous vote, the commission decided that it would support the suggested changes to our street cleaning policies.

Council has the last say concerning the direction and content of Berkeley's citywide Clean Water Program. Reduced implementation of runoff controls do little more than contribute to urban runoff pollution. It is time to rescind the opt-out feature of street sweeping.

Opt-out's Out, Street Sweeping's In: Council Ends Exceptions; Parking Tickets Sure to Follow
Kiratin Miller, Berkeley Voice, December 11, 1997

Did you remember to move the car today?

Street sweeping is back, for almost everyone. The City Council voted Dec. 2 to eliminate Opt-Out, the program that has allowed residents to "opt out" of street sweeping if 66 percent of their block successfully petitioned the city.

Over the next six months, the city will be phasing in a comprehensive street sweeping program to include all publicly maintained streets in Berkeley, "where feasible."

Public Works Department staff promised the new program will keep city streets cleaner and the Bay healthier. Opt-Out opponents added that it's simply reasonable to treat all streets equally.

However, activists in affected neighborhoods fear all they will see are more parking tickets. They doubt the new policy will actually bring equity to the system, or decrease environmental impact.

Voted down at the Oct. 2 meeting was a motion made by Councilmember Polly Armstrong requesting Council hold a public hearing on the matter.

"There are hundreds, perhaps thousands of people affected by this decision," Armstrong said. People who legitimately went through the process (of joining the Opt-Out program) and are now being subjected to this, don't know that it's about to be taken away from them."

Armstrong added that she believes the city needs to sweep the streets and make sure water runoff is clean. She insisted, however, that residents should be permitted to air their concerns at Council before changes are made.

Councilmember Dona Spring spoke to the environmental issues. "Copper and other heavy metals fall out of the car and go into the bay, killing the ecosystem," she said. "We should all bear in the responsibility for clean water and having a car."

A 1987 revision to the 1972 federal Clean Water Act identified urban runoff as a major cause of water pollution. Since then, street sweeping has evolved from a method of debris removal to a basic management practice for reducing urban run-off pollution in the Bay.

Yet, many Berkeleyans fear the sweeper. Residents are forced to get in their parked vehicles once a month and circle the neighborhood searching for a sometimes distant parking spot on the day the street sweeper comes to their block. Should they forget to move their car, they'll soon be greeted by a hefty green parking ticket.

Until now, blocks having opted out of the program have been exempt from that process.

Berkeley resident Malcolm Zaretsky said the decision to abandon Opt-Out doesn't make sense. Zarestsky's block is one of 82 currently off the street sweepers' list. "Everybody keeps the street clean in front of their house, regardless," he explained. "I just don't understand what the reason for this could be."

Over the next few months, Public Works staff will hold neighborhood meetings for Opt Out blocks and other streets to be reinstated under the new plan. Organizers said they expect residents' concerns to center on the inconvenience of moving parked cars on scheduled sweeping days, ticketing and enforcement, and the obtrusiveness of signs announcing the sweeping schedule.

Staff appear committed to the change, nonetheless. "We don't think it's unreasonable for people to move their cars once a month to keep the environment and the streets clean." Deputy Director of Public Works Patrick Keilch said.

Not all blocks currently in Opt-Out would necessarily be subjected to the sweeper, however, Kelich added. Streets that are too narrow or have other limitations, or that don't have nearby parking options, may be exempt. In addition Kelich said, the city is not ruling out future Opt-Out-style programs.

Even Opt-Out critics say they'd consider an alternative. "Let's make it a real program, not just a revenue enhancement program," said activist L A Wood, who has worked to educate his fellow Berkeleyans about public works and influence clean water policy for years. (Wood's new documentary video -- "Berkeley Public Works: Moving into the 21st Century" -- chronicles the history of the Public Works Department)

According to Wood, it's impossible for residents to remove particulates of dangerous metals that drop off cars onto the street, which eventually drain into the Bay, if not collected first. At the same time, he said, current city machines are not much better at retrieving these 'fines' (fine particulates). "They (city sweepers) manage the perception of cleaning the streets, not the reality," Wood said.

Also at issue is the question of equity in sweeping policy and procedure. "It turns out that there are vast areas of the city that we don't sweep that never opted out," said Armstrong. "For example, we don't sweep Bancroft, Channing, Durant, Haste, and Dwight. That's outrageous. It feels to me that our policy has been derived not from where we get the most benefit from sweeping, but from where it's the easiest to sweep."

City representatives said they can't sweep some streets because of heavy traffic and an abundance of parked cars.

It's difficult to say whether the new system will cost more or less than the old. If all current Opt-Out blocks return to regular street sweeping, the city will need to hire one full-time employee to operate another sweeper. For the remainder of the fiscal year (ending in June), the cost adds up to $26,008 for the sweeper operator and $11,000 for sign installation. The city already purchased an additional sweeper for $150,000 last year.

City May Deny Freedom of Sweep
Arthur Kim, Daily Californian, November 2, 1995

Once every month, most of Berkeley's residents move their cars off the roads in order to make way for street sweeping equipment.

But people who live on approximately 81 city blocks, or 6 percent of Berkeley's residential streets, have opted out of the program that requires residents to move their cars, choosing instead to clean their own roads.

The City Council created the option in 1991 and controversy has surrounded the issue since that time. The debate recently took a concrete turn, after critics, including officials from the public works commission, recommended the city require all residents to join the regular street sweeping program.

According to Berkeley activist L A Wood, the exempted neighborhoods work against the city's clean-water goals because the residents do not adequately maintain their streets.

"What we cannot afford is toxic runoff (and) opt-out doesn't sweep streets," he said. "I can guarantee you that they don't, and I'm talking about a complete sweep."

But Duston Richards, a resident on Keoncrest Drive in North Berkeley, said his neighborhood probably does a better job sweeping than the city could.

"I think the neighbors do a better job of policing the street," he said. "This is an incredibly close community, it's a clean neighborhood."

As a participant in a federally mandated clean water program, Berkeley has been seeking to control pollution by intensifying its street sweeping efforts. A certain type of pollution called urban runoff occurs when motor oil, auto emissions and other contaminants are washed into the city's storm drains and flushed untreated into local creeks and the San Francisco Bay.

The efficiency of street sweepers in picking up the fine particles of heavy metals has been a point of contention in the opt-out debate.

"(The street sweepers) don't do anything," said Jerry Gwathney, a resident on Acton Street in North Berkeley. "They just roll by blowing up dust onto the sidewalk. They make, no difference at all."

Earlier this year, the public works commission and members of the city staff delivered a report to the council recommending the elimination of the opt-out alternative.

The report found that Berkeley removed more copper than required under the minimum standard set by the regional water quality control board, but said the city should still do more by sweeping all the streets.

The report also said that retaining the opt-out alternative in the program would cost the city an additional $26,000 every year in administrative expenses.

The report, which the council sent back to the public works department for more information in June, was to be brought before the council last week, but was withdrawn by the city manager.

Mayor Shirley Dean said the council needed more information to make a decision. "There are a lot of issues around this report that need to be straightened out until it can be brought before the council," she said. "How can we say we're going to buy $100,000 worth of (street sweeping) equipment, and we don't know if it's going to work?"

But Councilmember Dona Spring said she saw no reason for the council to delay further action on the issue.

"All I can imagine is that a little time is needed to educate residents," she said. "It's not a lot to ask people (to move their cars). Driving a car is a responsibility."

Vicki Elmer, director of public works, said the opt-out issue should not cloud the fact that the U.S. Environmental Protection Agency had awarded the city a second-place award for an outstanding storm-water program.

"We're really moving forward overall," she said. "There are a lot of other things we are doing to reduce the runoff of heavy metals to the Bay. There's a lot more energy around this issue than is warranted by the facts on both sides."

Street Sweeping assessment district for downtown Berkeley
Berkeley Voice City Briefs, March 23, 1995

Clean streets
Thanks to crews of homeless street cleaners, shoppers and Berkeley businesses can expect cleaner streets in the Telegraph, Shattuck and University Avenue commercial districts.

The City Council voted unanimously to spend $15,000 from the Berkeley Streets and Utilities Division to increase a program that employs the homeless to keep Berkeley streets clean.

Councilmember Dona Spring, who represents the downtown area, said the expanded street sweeping is much needed. "I have never experienced a town with so many litterbugs," Spring said.

The council will expand an existing contract with Berkeley Oakland Support Services, Inc.

But Berkeley resident L A  Wood said he does not think the city should have to pay to clean up downtown. He said there is a 50- to 60-year-old ordinance mandating shop owners keep the sidewalks clean, and no one has ever been cited for breaking the ordinance. In addition Wood said business owners have rebuffed efforts to set up a downtown assessment district to insure clean streets.

"It's about time they [shop owners] came out and took responsibility for that aspect of street cleaning," Wood said.

The increased street sweeping program will do a number of things, including:

• Increase the hours of collection from 5 p.m. to 9 P.M.;

• Expand the collection area to include Addison and Center streets from Milvia to Oxford streets, Kittredge Street from Harold Way to Oxford Street, Shattuck Avenue from University Avenue to Berkeley Way, and Martin Luther King, Jr. Way from University Avenue to Berkeley Way;

• Increase the total contract amount by $15,000 to pay for the new services.

The contract would be increased by $15,000 to a total of $111,153 to pay for the additional hours of operation and the expansion of the collection area through the June 30, 1995 end of the contract.

Alameda County wastewater Disposal Survey
Street Sweepers and Catch Basin Cleaning activities, August 3,1992
Dear Ms. Heinze:

To begin, I want to thank you for including the Bancroft Guardian Coalition on your mailing list. We recognize you haven't had adequate time to respond to our first letter, but thought it important to write a second. After receiving notice of your subcommittee's scheduled discussion on the 5th of August we wanted to contribute our group's ideas to both the disposal issue and the Maintenance Questionnaire. Your survey begins:

Do you think disposal of wastewater generated by municipal maintenance practices is a problem that could be improved by the Maintenance Subcommittee developing Best Management Practices?

It is first important to restate that the disposal practices as seen in Alameda County are varied. The process for development of disposal practices for municipal maintenance activities has already begun. As I understood, the BMPs for disposal of wastewater were being developed and recently were released by your group. The survey question should more appropriately read "... by the Maintenance Subcommittee changing its Best Management Practices?" The BMPs for disposal were incomplete. The omission of a Tier I for disposal did make it appear that the CWP had not fully contemplated the problem. Our coalition's first response to the other participating cities was to ask what their current disposal practices were. This particular question begs the issue of "uniform practice." BMP development is important for this reason alone.

On the phone I discussed how important I thought appropriate municipal disposal activities were to an effective runoff program. Two months ago, the CWP had assigned a relatively low priority to defining disposal standards. The Maintenance Questionnaire sent out by your subcommittee reflects the CWP's changing sense of priority in this area. I think it is easy to assign low priority to those things we know little about, and so early development of BMPs is important. The efforts of your subcommittee's work over the first part of this year is evidence that BMP development is essential and ongoing.

There are many options to the disposal of wastewater generated by municipal maintenance activities. The June '92 BMPs, Tier II, for the CWP suggests the use of "impermeable containment, evaporation (drying bed) and/or wastewater drained to the sanitary sewer system." A problem of this approach is making some determination concerning the strength of the wastewater stream directed to EBMUD, given the variables in each municipal maintenance activity.

Several months ago, I spoke with Thomas C. Paulson, EBMUD Industrial Discharger Section Supervisor, Source Control Division. Our conversation focused on the strength of wastewater streams in relationship to the permit process for municipalities who might decide to use their system (see enclosed application form for wastewater Discharge Permit). Depending upon the characteristics of the wastewater discharge, a municipality may or may not be subject to a permit process. This determination is left up to the discharger (municipality). The permit allows for regular monitoring and testing of discharges to the sanitary drain system (sounds like a good idea).

A new procedure has been developed to enable some municipal facilities to obtain permits more easily. The PBR, Permit By Rule, was designed for those who otherwise would be required to obtain a full hazardous waste facility permit. This permit process is controlled by the California Department of Toxic Substance Control (DTSC). The City of Berkeley petitioned for information concerning this permit process. I don't believe they have filed for a permit with regard to the use of the sanitary drain system and their changing practices. Berkeley's Public Works has stated that they didn't feel a need to file for an permit. Mr. Paulson (EBMUD) stated the permit issue was unclear for municipalities.

Wastewater reduction should be the goal of every municipality. To minimize the use of wash water naturally follows. The recycling of water is the next most desirable option for disposal of waste/wash waters in either a wastewater oil recycler or wastewater recycler.

Berkeley is purchasing an oil recycler for their vehicle steam cleaning activities. When it is installed it will be capable of reclaiming the water by separating it from oil and particulates. The water will then be reused. I spoke to a supervisor of Berkeley's Corporation Yard and he said the wastewater systems he had recently reviewed for their yard were costly and also labor intensive.

At least one municipality processes storm drain inlet debris leachate into a sediment basin where the solids settle and the liquid either evaporates or percolates into the ground. Solids are then removed to the local landfill. This practice probably will not become the standard for the program. There is obvious potential to harm the groundwater with exposure to high concentrations of catch basin and sweeper wastewater collections and wash water. This was the point made at the end of the video. Is this a wastewater program or a runoff program? We think it is both. The use of the term "runoff" at times makes us forget the wastewater part.

There is one other BMP that our coalition thinks should be emphasized and that is the tarping of municipal trucks. I think there exists a notion that "around town" it is not necessary to tie down debris collected from municipal maintenance activities. Our group made formal request of our Public Works Department to be more conscious of this problem. Residents were tired of our neighborhood being dusted down by dirt arid debris. Our city trucks were not being tarped. Heightened awareness to this (local) issue would contribute to litter control and the street sweeper program.

I want to say that we were very pleased to see your questionnaire and particularly with its focus on disposal. We recognize this as the beginning of serious discussions on the matter.

Respectfully, L A Wood

cc: Jack A. Lindley, Water Resources Manager, CWP Robert Marek, City of Berkeley, Engineering Jordan M. Rich, Asst. City Mgr. Public Works, Berkeley

Best Management Practices for Street Cleaning and Storm Drainage Facilities
Diane Heinze, P. E. Interim Chairperson Maintenance Subcommittee, ACURCWP
Oakland, CA, July 22, 1992

Dear Ms. Heinze:

It was good to talk to you on the telephone last week concerning the Best Management Practices for Street Cleaning and Storm Drainage Facilities. As you know, the Bancroft Guardian Coalition's interest in the Alameda County Urban Runoff Clean Water Program (CWP) was as a consequence of a neighborhood action. In order to understand the problems with our own city's Public Works Department, we were compelled to consider the Runoff Program. Our attempt to informally survey the participating cities made us recognize that the disposal problem was not exclusive to the City of Berkeley. We hoped that our video, "Berkeley's Storm System: Portal to the Bay," and our survey would contribute to the awareness of storm drain disposal pollution.

A portion of the video was devoted to a discussion of runoff content and strength. The storm drain inlet debris collection, in an urban context, represents more than storm water or runoff. It is generally recognized that wastewater strength varies in storm drain collections given any number of variables, including illicit discharges. The ability of a given municipality to determine specific content of its disposal collections can only be done by testing. This is generally not cost effective.

Our preliminary survey has shown municipalities' disposal activities to be varied. The concern of our group was that a minimum standard of practice be recognized by the CWP, given the limitations of illicit disposal detection and runoff content.

Last month, your Maintenance Subcommittee issued its Best Management Practices (BMP) for street cleaning and storm water collection. This is a two tier program that reflects shrt­ range (Tier I) and long-range (Tier II) municipal maintenance activities (goals). On the issue of "Disposal of Material" (III), the BMPs list Tier I activity. This we thought was an implied acknowledgement that any current disposal activity is acceptable or to be tolerated by the program. It was our public perception that the perimeters of the Tier I disposal practices were too broad. The Tier II schedule reads:

Store material removed from storm drainage facilities on a concrete pad or other impermeable material and drain wastewater to the sanitary sewer system or allow to evaporate to prevent discharges to the storm drain system.

In our conversation you mentioned that our group's concerns had been heard at the County level. You said that the proposed Tier II for Disposal of Material-BMP's was being changed to read Tier I. The Coalition sees this as a significant change. First and foremost, it reflects a sensible approach to the problem. Secondly, because of the sensitivity to costs surrounding the issue, most municipalities require additional regulatory direction. The integrity of the CWP is hurt when the issue of disposal is not addressed openly and with the emphasis that it deserves.

You also said that our video was going to be shown at the beginning of the next Maintenance Subcommittee meeting on August 5th. We would be interested in any feedback from your group concerning this showing and also your ideas concerning our group's impact on the Best Management Practices of the CWP.

We are encouraged by your openness to our inquiry and the the idea of our group working with the CWP to the betterment of the San Francisco Bay and Region.

REQUEST: Support for Terminating Berkeley's Opt Out Process from Residential Street Sweeping Program, Northern Alameda County Group Sierra Club Executive Committee, September 21, 1997 From: Ben Brandzel and David Tam

On January 19, 1995, the Berkeley Public Works Commission voted unanimously to recommend the following:

Eliminate the opt out process of the Residential Street Sweeping Program (SSP) within the next six months and implement a comprehensive, city-wide street sweeping program to include all publicly maintained streets in Berkeley.

This controversial matter could be voted upon by the Berkeley City Council as early as Tuesday, October 7. Candidates for Berkeley City Council in 1996 were evaluated based on their positions on this issue (as well as eight others).

We have enclosed as a three-page document the executive summary of the Berkeley Public Works Commission's 49-page report. A full copy will be available at the meeting, as will L A Wood, a West Berkeley citizen advocate and video producer who has written and lobbied effectively for several years on this issue.

We have also excerpted the preamble and three most pertinent sections of the Sierra Club's national Water Policy, and attached it as a one-page document. The key section, Water Quality, advocates in part

The Clean Water Act should be aggressively enforced by all agencies with water management responsibilities and should not be weakened. Point-source pollution should be eliminated, best management practices for air and water-borne pollutants should be developed, and adequate funding should be provided to implement control of non-point sources.

Best Management Practices (BMP) proposed for all cities in the Storm Water Management Plan of Alameda County's Urban Runoff Clean Water Program include "...improv[ing} their existing programs so that rather than sweeping solely for aesthetic reasons, sweeping is also conducted at strategic times to control urban runoff pollution. This may include implementation of parking restrictions on specific days to maximize sweeping effectiveness."

Unfortunately, both in 6% of Berkeley (81 blocks out of about 1350, concentrated in Council Districts 1 and 5) and about 200 of 2700 blocks in Oakland (distribution unknown), residents have been allowed to do their own sweeping to avoid moving their vehicles, which are the main sources of copper, zinc, lead and other runoff pollutants. Compliance is probably superficial; the two cities don't budget for monitoring other than through parking enforcement in the non-exempt neighborhoods. This is an environmental injustice.

Examine central Issues of Opt Out, Berkeley Voice
L A Wood, June 9, 1994
Editor:

Your article, "Council Reneges on Opt Out Program for Street Sweeping" (Voice, May 16) will undoubtedly add some confusion to the debate over street sweeping. You seem to have missed the central issue in the residential sweeping exemption program called "opt out."

Although you elicited comments from Councilmember Dean, you failed to point out the source of her resistance to a more democratic, citywide sweep. Her district represents the majority of the exempted streets in Berkeley. The effectiveness of street sweepers or what type of equipment to use, is beside the point. This one is about votes, not the environment. And this has made Berkeley's opt out for street sweeping program "district exclusive."

You also mention that council had instituted a moratorium on any more streets dropping out, but nowhere do you mention that the fairness of this exemption has been called to task. Or that when a program reflects such selective participation, it constitutes nothing more than elitist attitudes and blatant environmental racism.

However, is was clearly pointed out, that Dean was in search of any "criteria" which would allow her district to be grand fathered in. This variance from sweeping will only serve to institutionalize such discriminatory practices in our eco-city.

And finally, you were absolutely remiss in not contacting yours truly, given the over 19 months of activism I have spent on this specific issue in Berkeley, Oakland and Alameda County. In that period of time, I gave public comment, exceeding one hour (in three minute, weekly sound bites) to Berkeley's council, two commission presentations, and a wealth of written literature and council communications (probably a record from one resident). In addition, I was named in the original council referral from Mayor Hancock, and in the most recent council information item from Councilmember Spring to rescind opt out. Maybe next time.
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