Submitted By: Public Works
Prepared By: Dustin Burnside, Utilities Manager
Subject:
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CONSIDERATION OF A RESOLUTION ADOPTING THE 2025 SEWER SYSTEM MANAGEMENT PLAN, DESIGNATING A LEGALLY RESPONSIBLE OFFICIAL AS REQUIRED BY THE REGIONAL WATER QUALITY CONTROLS BOARD’S WASTE DISCHARGE REQUIREMENTS, AUTHORIZING THE CITY MANAGER AND THE UTILITIES MANAGER TO APPROVE ANY FURTHER MINOR UPDATES TO THE PLAN, AND FINDING THE PROJECT CATEGORICALLY EXEMPT FROM THE CALIFORNIA ENVIRONMENTAL QUALITY ACT
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Fiscal Impact:
None.
Summary:
The Statewide General Waste Discharge Requirements General Order for Sanitary Sewer Systems (WDR-SSS) requires the City’s Sewer System Management Plan (SSMP) be updated periodically to ensure it complies with the most current regulations and staff responsibilities. The objective of the Statewide General Waste Discharge Requirements (WDRs) is to reduce the frequency and volume of Sanitary Sewer Spills by requiring cities to properly fund, operate, maintain, and manage their wastewater collection system. The programs and plans to operate, maintain, and manage the entire wastewater collection system are adequately documented in the SSMP. The resolution before the City Council would approve the 2025 SSMP.
Background:
On May 2, 2006, the California State Water Resources Control Board (SWRCB) adopted Water Quality Order 2006-0003, requiring all public agencies that own sanitary sewer collection systems greater than one mile in length to comply with the WDR-SSS. The WDRs are the regulatory standards for agencies that own or operate sanitary sewer collection systems that collect and/or convey untreated or partially treated wastewater to a publicly owned treatment facility.
On December 6, 2022, the State Water Resources Control Board adopted a new Order 2022-0103-DWQ, outlining updated requirements for public agencies, which went into effect beginning June 5, 2023. The new order requires each agency to adopt, certify, and upload its SSMP Update or current SSMP to the online California Integrated Water Quality System (CIWQS) Sanitary Sewer System Database to continue regulatory coverage from the previous Order. Under the new Order, the City was required to submit an updated SSMP by August 2, 2025. Staff has submitted a draft version of the SSMP to meet the mandated deadline.
The new WDR also requires the City to designate a Legally Responsible Official that has authority to ensure the enrolled sanitary sewer system(s) complies with this Order and is authorized to serve as a duly authorized representative. The Legally Responsible Official must have responsibility over management of the Enrollee’s entire sanitary sewer system and must be authorized to make managerial decisions that govern the operation of the sanitary sewer system, including having the explicit or implicit duty of making major capital improvement recommendations to ensure long-term environmental compliance. The Legally Responsible Official must have or have direct authority over individuals that:
• Possess a recognized degree or certificate related to operations and maintenance of sanitary sewer systems, and/or
• Have professional training and experience related to the management of sanitary sewer systems, demonstrated through extensive knowledge, training and experience.
For this purpose, the Director of Public Works, the Deputy Director of Public Works, Utilities Manager, the Utilities Superintendent of Collections/Maintenance, and the Chief Operator of Collections may be designated as Legally Responsible Officials. The recommendation is to designate the Utilities Manager as the Legally Responsible Official.
The City’s last SSMP recertification was approved and adopted by the City Council on October 15, 2019. The City is required to update the SSMP to be compliant with the current mandate of the new Order 2022-0103-DWQ and update the SSMP every 6 years.
The SSMP includes the following elements:
• Sewer System Management Plan Goal and Introduction
• Organization
• Legal Authority
• Operation and Maintenance Program
• Design and Performance Provisions
• Spill Emergency Response Plan
• Sewer Pipe Blockage Control Program
• System Evaluation, Capacity Assurance, and Capital Improvements
• Monitoring, Measurement, and Program Modifications
• Internal Audits
• Communication Program
If adopted by the City Council, Utilities Division staff would certify to the State Board that the SSMP is compliant with the WDRs.
Council Options:
• Adopt Resolution No. 25-165, which would adopt the 2025 Sewer System Management Plan as required under the WQ 2022-0103-DWQ Statewide Waste Discharge Requirements General Order for Sanitary Sewer Systems adopted by the State Water Resources Control Board on December 6, 2022, designate the Utilities Manager as the Legal Responsible Official, authorize the City Manager and the Utilities Manager to approve any further minor updates to the Sewer System Management Plan, and find the actions categorically exempt from the California Environmental Quality Act (CEQA) under Class 8 of the State CEQA Guidelines, Section 15308 - Actions By Regulatory Agencies for the Protection of the Environment.
• Modify and adopt Resolution No. 25-165 and request any modifications be brought before the City Council.
• Continue the item and direct staff to provide additional information.
• Do not adopt Resolution No. 25-165.
Environmental Review/Analysis:
SSMPs are primarily plans for the operations and maintenance of existing sewer systems, and their purpose is to protect public health and the environment by managing and mitigating sewer spills. While the SSMP’s may articulate the need for replacement or construction of new facilities, the plans do not constitute design approval for such facilities. Therefore, approval of the updated SSMPs is categorically exempt from the California Environmental Quality Act (CEQA) under Class 8 of the State CEQA Guidelines, Section 15308 - Actions By Regulatory Agencies for the Protection of the Environment, because it consists of actions taken by regulatory agencies, as authorized by state or local ordinance, to assure the maintenance, restoration, enhancement, or protection of the environment where the regulatory process involves procedures for protection of the environment, which allows for the operation and maintenance of existing public facilities with negligible or no expansion of use.
Recommended Actions:
Staff Recommendation
recommendation
Staff recommends that the City Council adopt Resolution No. 25-165, which will:
1. Find the actions categorically exempt from the California Environmental Quality Act (CEQA) under Class 8 of the State CEQA Guidelines, Section 15308 - Actions By Regulatory Agencies for the Protection of the Environment;
2. Appoint the Utilities Manager as the Legally Responsible Official under the Regional Water Quality Controls Board’s Waste Discharge Requirements;
3. Approve and adopt the 2025 Sewer System Management Plan; and
4. Authorize the City Manager and Utilities Manager to approve any future minor updates mandated by the State Water Resources Control Board regarding the Sanitary Sewer Management Plan, Sanitary Sewer Overflow Prevention Plan and Sanitary Sewer Overflow Emergency Response Plan.
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Attachments:
1. Sewer System Management Plan Resolution
2. CEQA Notice of Exemption Form
3. Sewer System Management Plan Update
Notification:
None.