On July 23, 2026, the Los Angeles Regional Water Quality Control Board adopted a new Commercial, Industrial, and Institutional (“CII”) Stormwater Permit that could create significant new compliance obligations for certain commercial, industrial, and institutional properties in portions of Los Angeles County. In general, the permit applies to facilities within the Dominguez Channel and Los Cerritos watersheds that have five or more acres of impervious surface or, in some circumstances, five or more acres of total site area, including certain facilities that currently rely on No Exposure Certifications, Notices of Non-Applicability, or other forms of stormwater permit coverage. The permit also contains broad provisions regarding campus-style developments, allowing contiguous parcels and certain parcels separated by public rights-of-way to be aggregated for coverage purposes, and applies to the commercial, industrial, or institutional portions of mixed-use developments.

The permit is expected to become effective on or around October 31, 2026. Covered sites will be required to conduct stormwater sampling, develop a Stormwater Pollution Prevention Plan (“SWPPP”), implement required best management practices, pay annual fees, and comply with one of three available compliance pathways, some of which could involve substantial capital expenditures. Owners and operators of potentially covered facilities should consider promptly evaluating whether any facilities fall within the permit’s geographic scope and whether existing stormwater permit coverage, site configuration, acreage, ownership structure, or mixed-use characteristics necessitate permit coverage.

Notably, similar requests are pending in several other regions of California, including Lower San Diego, Ontario, Salinas, Santa Rosa, the San Francisco Bay Area, and Sacramento, which could lead to similar permit programs being adopted by Regional Water Boards in those additional watersheds. Owners and operators potentially subject to the new CII Stormwater Permit or similar pending permits will want to consider applicability assessments, compliance planning, and implementation strategies.

Photo of Nicole Granquist Nicole Granquist

Nicole Granquist is among a select group of attorneys in California who specializes exclusively in water quality regulatory compliance, enforcement defense, and litigation. Described by clients as a “powerhouse” who has a “tremendous grasp of the complex scientific, legal, and political issues” involved…

Nicole Granquist is among a select group of attorneys in California who specializes exclusively in water quality regulatory compliance, enforcement defense, and litigation. Described by clients as a “powerhouse” who has a “tremendous grasp of the complex scientific, legal, and political issues” involved in California water quality regulation and litigation, Nicole’s tenacity, creativity, and pragmatic approach have consistently delivered exceptional results for her statewide municipal and industrial clients, earning her respect and credibility with both regulators and opposing counsel.

Nicole routinely negotiates NPDES Permits, waste discharge requirements (WDRs), and water reclamation requirements with the state board and regional water boards for municipal wastewater, industrial process water, and all types of stormwater discharges, as well as reclamation projects. Her involvement in these matters consistently results in more favorable and reasonable permit provisions. She also is deeply involved in the development of Total Maximum Daily Loads (TMDLs) and all aspects of Basin Planning and has positively contributed to and influenced important statewide policies. A recent example involves Nicole’s testimony before the California State Water Resources Control Board (SWRCB), which beneficially influenced the terms of the SWRCB’s compliance schedule policy.

Photo of Jaycee Dean Jaycee Dean

Jaycee Dean advocates for her clients using a detail-oriented approach to help them navigate complex environmental issues. She counsels them on various federal and state natural resources issues related to the Clean Water Act (CWA), the Comprehensive Environmental Response, Compensation and Liability Act…

Jaycee Dean advocates for her clients using a detail-oriented approach to help them navigate complex environmental issues. She counsels them on various federal and state natural resources issues related to the Clean Water Act (CWA), the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), California’s Porter-Cologne Water Quality Control Act, California’s Fish and Game Code, and associated local rules and regulations. Jaycee is honing particular expertise in water quality regulation and enforcement defense.

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