HomeMy WebLinkAboutStaff Report 2504-4486CITY OF PALO ALTO
CITY COUNCIL
Tuesday, June 17, 2025
Council Chambers & Hybrid
5:30 PM
Agenda Item
5.Approval of the 2025 update to the Sewer System Management Plan (SSMP) and
Authorization for Staff to Make Future Administrative or Minor Updates to the SSMP as
Needed; CEQA Status – Exempt under CEQA Guidelines sections 15301, 15302, 15308.
City Council
Staff Report
From: City Manager
Report Type: CONSENT CALENDAR
Lead Department: Utilities
Meeting Date: June 17, 2025
Report #:2504-4486
TITLE
Approval of the 2025 update to the Sewer System Management Plan (SSMP) and Authorization
for Staff to Make Future Administrative or Minor Updates to the SSMP as Needed; CEQA Status
– Exempt under CEQA Guidelines sections 15301, 15302, 15308.
RECOMMENDATION
Staff recommends that the City Council:
1. Approve the 2025 update to the SSMP1, as required by the State Water Resources
Control Board (SWRCB) Order No. WQO-2022-0103-DWQ, Statewide Waste Discharge
Requirements General Order for Sanitary Sewer Systems (General Order).2
2. Authorize future SSMP updates that are administrative or minor in nature to be
approved by staff without returning to Council for approval.
EXECUTIVE SUMMARY
The 2025 update to the SSMP aligns the City with current regulatory requirements under
SWRCB’s General Order. The SSMP serves as the City's guiding document for managing,
operating, maintaining, and improving the sanitary sewer system, and aims to reduce sanitary
sewer overflows (SSOs). The SSMP documents the City’s Sanitary Sewer System, defines the
City’s goals for improving its sewer system infrastructure, and establishes an implementation
plan and schedule for achieving these goals. This update reflects current system conditions and
includes improvements in maintenance practices, spill response, and infrastructure planning.
The General Order requires that the City Council approve the document prior to submittal to
the SWRCB.
1 2025 SSMP: Link to SSMP:
2 State Water Resources Control Board (SWRCB) Order No. WQO-2022-0103-DWQ, Statewide Waste Discharge
Requirements General Order for Sanitary Sewer Systems (General Order)
https://www.waterboards.ca.gov/board_decisions/adopted_orders/water_quality/2022/wqo_2022-0103-dwq.pdf
BACKGROUND
3
to address two (2) key requirements of the re-issued 2022 General Order, both due before June
5, 2023:
4 is now necessary to reflect current conditions and for
compliance with the 2022 General Order, which is due on August 2, 2025. Revisions focus on
improving clarity, consistency, and structure through editorial updates, elimination of duplicate
content, and reorganization of sections of the Plan to align with SSMP elements. A redline version
of the revised Plan is available for reference. The revisions also include updated staffing details,
performance data through 2024, refined system mapping, and simplified appendices to reflect
current operational practices and regulatory standards. The updated SSMP must be presented to
the Council at a public meeting and formally adopted to ensure that the public has the
opportunity to comment on the collection systems policies and procedures.
DISCUSSION
3 Staff Report ID #2301-0789 https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=11197
4 2023 Sanitary Sewer Management Plan https://www.paloalto.gov/files/assets/public/v/1/utilities/utilities-
engineering/wastewater/2023-ssmp-final.pdf
The 2022 General Order requires internal audits of the SERP annually and the SSMP every three
years and updates as needed. The City’s Utilities Department will complete the required audits,
update the SERP and SSMP, and implement identified changes based on the audit findings. The
SSMP will be reviewed and updated annually to ensure any significant program changes, after
audits, or when there are changes in the Implementation Team's membership or responsibilities.
To streamline future updates, staff recommends that administrative and minor program changes
be approved by staff without returning to Council. These changes will be documented in the
SSMP’s Appendix O: SSMP Change Log for transparency. The SSMP will continue to be reviewed
annually, audited every three (3) years, and certified by Council every six (6) years, in compliance
with State requirements.
FISCAL/RESOURCE IMPACT
STAKEHOLDER ENGAGEMENT
5
5 City of Palo Ato Utilities Department Website https://www.paloalto.gov/Departments/Utilities/Utilities-Services-
Safety/Safety#panel-1-4
ENVIRONMENTAL REVIEW
Implementation of the SSMP will apply to sanitary sewer collection systems that constitute
"existing facilities" of the City, or may require the installation of minor sewer system facilities
which will involve either minor alterations to existing facilities, or repair or replacement of
existing facilities involving negligible or no expansion of sewer capacity. Such activities are
exempt from review under the California Environmental Quality Act (CEQA). (CEQA Guidelines
sections 15301 and 15302.) The adoption of the SSMP is also exempt from environmental review
because it requires the implementation of management operations programs and plans to
enhance and protect the environment by limiting the occurrence of SSOs in the City. (CEQA
Guideline section 15308.).
ATTACHMENTS
None.
Link to 2025 SSMP: https://www.paloalto.gov/files/assets/public/v/1/agendas-minutes-
reports/agendas-minutes/city-council-agendas-minutes/2025/june-16/staff-report-2504-
4486/sewer-system-management-plan-2025-update-2.pdf
APPROVED BY:
Alan Kurotori, Director of Utilities
Staff: Matt Zucca, Utilities Assistant Director WGW Engineering & Operations