Banning City Council
July 8, 2025

RESOLUTION 2025-108

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF BANNING, CALIFORNIA, AUTHORIZING THE CITY’S GRANT APPLICATION FOR FUNDING FROM THE BUREAU OF RECLAMATION WATERSMART: TITLE XVI WIIN ACT WATER RECLAMATION AND REUSE PROGRAM FOR FISCAL YEAR 2023 AND FOR FISCAL YEAR 2024 FOR UP TO 25% OF THE TOTAL PROJECT COSTS, UP TO $30 MILLION, FOR THE WASTEWATER TREATMENT

PLANT AND RECYCLED WATER UPGRADES AND AUTHORIZING THE CITY MANAGER TO

EXECUTED RELATED GRANT AGREEMENT TO RECEIVE FUNDING
WHEREAS, the United States Bureau of Reclamation (USBR) has solicited applications for authorized projects for WaterSMART: Title XVI WIIN Act Water Reclamation and Reuse Projects for Fiscal Years 2023 and 2024 per Funding Opportunity Announcement No.

R23AS00464; and
WHEREAS, the City of Banning will be upgrading its Wastewater Treatment Plant (WWTP), also known as the Water Reclamation Facility, to reduce the City’s future reliance on imported water and to enhance groundwater recharge; and WHEREAS, the City has recognized that its Wastewater Treatment Plant is in need of capacity and treatment improvements to keep up with the City’s growth as well as to produce recycled water supply to bolster its water supply portfolio and to meet impending wastewater effluent discharge quality permit requirements; and
WHEREAS, the City desires to improve the WWTP to treat its wastewater and produce recycled water; and
WHEREAS, the City of Banning is seeking grant funding to further fund the design-build construction of the Project; and
WHEREAS, the City of Banning prepared and submitted a grant application to the WaterSMART: Title XVI WIIN Act Water Reclamation and Reuse Projects for Fiscal Years 2023 and 2024 per Funding Opportunity Announcement No. R23AS00464; and WHEREAS, USBR has directed applicants to submit an official resolution adopted by the applicant's board of directors or governing body verifying 1) the identity of the official with legal authority to enter into an agreement, 2) the board of directors, governing body, or appropriate official who has reviewed and supports the application submitted, 3) the capability of the applicant to provide the amount of funding and/or in-kind contributions specified in the funding plan, and 4) that the applicant will work with Reclamation to meet established deadlines for entering into a grant or cooperative agreement.

NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Banning as follows:

SECTION 1. The City Manager, or his designee, is authorized to sign and submit all required information to the United States Bureau of Reclamation (USBR) to obtain a USBR WaterSMART:

Title XVI WIIN Act Water Reclamation and Reuse Projects for Fiscal Years 2023 and 2024 per Funding Opportunity Announcement No. R23AS00464 for and on behalf of the City including, but not limited to, the execution of a grant agreement.
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Resolution 2025-108

SECTION 2. The City Council has reviewed and supports the City’s application for USBR Funding Opportunities R23AS00464 submitted by the 30th day of September 2024.

SECTION 3. The City Council has reviewed and supports the application for grants from Reclamation for the WaterSMART Title XVI WIIN Water Reclamation and Reuse Program.

SECTION 4. The City of Banning is able to provide the minimum 75% funding match specified in the funding plan.

SECTION 5. The City Manager, or his designee, is hereby authorized and directed to prepare the necessary data, conduct investigations, file such applications, and execute grant agreements with the USBR in association with this application process. The City of Banning will work with the USBR to meet established deadlines required for entering into a cooperative agreement to obtain the aforementioned grant funding.

SECTION 6. The City Manager, or his designee, is authorized to represent the City in carrying out the City's responsibilities under the grants agreement, including certifying disbursement requests on behalf of the City and compliance with applicable state and federal laws.

SECTION 7. The City Manager, or his designee, is authorized to make necessary budget adjustments, appropriations and transfers related to the Financial Assistance Application for grant agreement from USBR.

SECTION 8. The City Council authorizes the Director of Public Works to be the City Manager’s designee.

SECTION 9. The City Clerk shall certify to the adoption of this resolution and shall cause a certified resolution to be filed in the book of original resolutions.

PASSED, APPROVED AND ADOPTED this 8
th day of July, 2025.

Sheri Flynn, Mayor
City of Banning
ATTEST:

Caroline Patton, Administrative City Clerk
City of Banning
APPROVED AS TO FORM:
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Resolution 2025-108

John Pinkney, Interim City Attorney
Slovak, Baron, Empey, Murphy & Pinkney,
LLP
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Resolution 2025-108

CERTIFICATION:

I, Caroline Patton, Administrative City Clerk of the City of Banning, California, do hereby certify that the foregoing Resolution 2025-108, was duly adopted by the City Council of the City of Banning, California, at a regular meeting thereof held on the 8 th day of July, 2025 by the following
vote, to wit:

AYES:

NOES:

ABSENT:

ABSTAIN:

Caroline Patton, Administrative City Clerk
City of Banning, California
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WASTEWATER TREATMENT PLANT AND RECYCLED WATER UPGRADES

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Table of Contents

1. EXECUTIVE SUMMARY .............................................................................................................................. 3

2. PROJECT LOCATION ........................................................................................................................................ 4

3. PROJECT DESCRIPTION ................................................................................................................................. 5

3.1 Background Information ..................................................................................................................... 5 Climate Crisis ............................................................................................................................................. 5

3.2 Project Description .............................................................................................................................. 7

3.3 Proposed Scope of Work..................................................................................................................... 9

4. EVALUATION CRITERIA ............................................................................................................................. 11 Evaluation Criterion 1—Water Supply (35 points) .............................................................................. 11 Sub criterion No. 1a—Stretching Water Supplies (18 points) ............................................................ 11 Sub criterion No. 1b—Contributions to Water Supply Sustainability (17 points) .............................. 14 Evaluation Criterion 2—Environment and Water Quality (15 points) .................................................... 20 Evaluation Criterion 3—Economic Benefits (25 points).......................................................................... 23 Subcriterion No. 3a—Cost Effectiveness (15 points) .......................................................................... 23 Subcriterion No. 3b—Economic Analysis and Project Benefits (10 points) ........................................ 29 Evaluation Criterion 4—Presidential and Department of the Interior Priorities (15 Points) ................. 33 Evaluation Criterion 5— Reclamation’s Obligations and Watershed Perspective (10 Points) ............... 37 Subcriterion No. 5a— Reclamation’s Legal and Contractual Water Supply Obligations (5 points).... 37 Subcriterion No. 5b— Watershed Perspective (5 points) ................................................................... 37

5. PROJECT BUDGET ......................................................................................................................................... 41

5.1 Funding Plan ...................................................................................................................................... 41

5.2 Budget Narrative ............................................................................................................................... 42

6. ENVIRONMENTAL AND CULTURAL RESOURCES COMPLIANCE ............................................... 46

7. REQUIRED PERMITS OR APPROVALS ................................................................................................... 49

8. OVERLAP OR DUPLICATION OF EFFORT STATEMENT ............................................................. 49

9. CONFLICT OF INTEREST DISCLOSURE STATEMENT ................................................................. 50

10. UNIFORM AUDIT REPORTING STATEMENT ............................................................................ 50

11. SF-LLL: DISCLOSURE OF LOBBYING ACTIVITIES ................................................................... 50

12. LETTERS OF SUPPORT ...................................................................................................................... 50

13. OFFICIAL RESOLUTION ..................................................................................................................... 50

14. LETTERS OF FUNDING COMMITMENT....................................................................................... 50

15. REFERENCES ......................................................................................................................................... 50 1113

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1. EXECUTIVE SUMMARY
DATE: SEPTEMBER 30, 2024
APPLICANT: CITY OF BANNING
COUNTY: RIVERSIDE
STATE: CALIFORNIA
PROJECT SUMMARY: The City of
Banning (City) requests $16,194,575
from the WaterSMART: Title XVI WIIN
Act Water ReclamaAon and Reuse
program for criAcal upgrades to its
Wastewater Treatment Plant (WWTP)
to produce valuable reclaimed water.

This Project will address the urgent need to increase locally sourced water supplies by an estimated 2,470 AFY (2.2
MGD) with recycled water. This is exceptionally important to the economically disadvantaged communities that
comprise Banning’s populaAon (31,680 residents)1 giving them the unprecedented opportunity to use every gallon
of water twice. Banning lies in the San Gorgonio Pass
region of Southern California, approximately 85 miles east of downtown Los Angeles. The Project will upgrade the
existing WWTP to provide tertiary treatment to meet both regional and California Title 22 recycled water quality requirements. The safe, clean water will serve high volume irrigation customers in Banning who currently use
groundwater recharged by imported water. Additionally, it will provide vital regionally significant groundwater
replenishment. Currently, the City relies on purchasing imported water from the San Gorgonio Pass Water Agency
(SGPWA) for groundwater recharge. This will reduce the need for imported water, which is becoming an increasingly unreliable, diminishing water source. The Project is well aligned with goals and objectives identified in both the Banning Urban Water Management Plan (2020)2, the San Gorgonio Integrated Regional Water Management Plan, and the Western Riverside County Subregional Climate Action Plan. By producing a new local, sustainable water supply source, the City will improve its drought resilience, climate adaptability, and its water management efficiency. The progressive design-build approach will enable Banning to complete the Project with significant cost savings and an expedited 3-year timeline. The proposed Project is not located on a federal facility and will not involve federal land. 1 U. S. Census Bureau 2023
2 link to Banning UWMP

REGIONALLY SIGNIFICANT

BENEFITS

WATER QUALITY

SUPPLY RELIABILITY

GREEN SPACE SUSTAINABILITY

DROUGHT RESILIENCE

URBAN HEAT MITIGATION

EQUITY/JUSTICE

TRIBAL RESOURCES

COST SAVINGS

ENERGY SAVINGS

SOIL IMPROVEMENTS

QUALITY OF LIFE

GHG REDUCTIONS
Banning, CA
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2. PROJECT LOCATION
The City of Banning (City) is in southern California, northern Riverside County approximately 25 miles east of the City of Riverside and 85 miles east of downtown Los Angeles (see Figure 1). It lies within the jurisdiction of the Colorado Regional Water Quality Control Board (RWQCB), Region 7. The City encompasses 23.2 square miles and is bisected by Interstate 10 in the San Gorgonio Pass region at the gateway to the Coachella Valley. Banning is adjacent to the City of Beaumont on the west, the Morongo Band of Mission Indians reservation to the east, the San Bernardino Mountains to the north, and the San Jacinto Mountains to the south.

Figure 1. Project Location Map
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3. PROJECT DESCRIPTION
Overview: The proposed multi-benefit Project will upgrade the existing WWTP to produce advanced tertiary treated recycled water. A portion of the water will be used to serve irrigation customers currently using groundwater recharged by imported water, and the rest will discharge to the City’s percolation ponds for groundwater recharge. This will increase the supply and reliability of locally sourced non-potable water by an estimated 2,470 AFY (2.2 MGD). The U.S. Bureau of ReclamaAon approved the Project within the Wastewater Treatment Plant and Recycled Water Upgrades Feasibility Study on January 31, 20243.

3.1 Background Information
Climate Crisis
With climate change bringing unpredictable and severe variations in weather including droughts in California and the western United States, Banning will implement this Project to generate sustainable regional supplies to address future water supply challenges.

Existing Recycled and Non-Potable Water System
The City of Banning does not currently utilize any reclaimed water. The City’s existing nonpotable water system delivers water from two non-potable groundwater wells, Well M7 and M12, to Sun Lakes Golf Course for irrigation use. The City has finished construction of a 24-inch diameter pipeline to connect the existing non-potable water pipe to the WWTP, and has begun construction of two booster stations and storage tanks along this pipeline. See Figure 2 for a map of this non-potable pipeline.

Figure 2. Project Location Map
3 See Appendix A for the Signed Executed Memorandum from the Bureau of Reclamation approving the Feasibility Study. See Appendix B for the Feasibility Study.
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City of Banning Wastewater Treatment Plant
The City’s WWTP is currently rated at 3.6 MGD and is designed to treat wastewater to secondary standards. The generated wastewater is proportional to the City’s population and the water used by its residents. The wastewater flows are metered at the influent point to the WWTP. Total wastewater collected in the City between 2018 and 2023 is shown in Table 1. The WWTP, located in the southeast corner of the City, collects the wastewater discharged from the City through a network of 112 miles of gravity sewer mains. The WWTP consists of preliminary treatment, primary treatment, secondary treatment, solids handling, and disinfection (currently not in use). Secondary effluent is discharged to 10 unlined evaporation/percolation ponds which recharges the Cabazon Groundwater Basin. This recharge is provided only through surface percolation, and no injection wells are used by the City. Although the WWTP effluent is currently in compliance with discharge requirements, it requires significant upgrades to comply with pending water quality discharge limits set by the Regional Water Quality Control Board, as described below. In addition, many of the facilities, including the existing trickling filters, which perform secondary treatment, have reached their end of life.

Table 1. Banning Wastewater Flows Collected
Year Acre Feet per Year (AFY) Million Gallons Per Day (MGD) 2018 2,259 2.02
2019 2,234 2.00
2020 2,185 1.95
2021 2,226 1.99
2022 2,307 2.06
2023 2,466 2.20
Regional Water Quality Control Board Order
In 2016, the Colorado River Basin Regional Water Quality Control Boad (RWQCB) adopted Waste Discharge Requirements (WDRs) Board Order R7-2016-0016 for the City of Banning, Wastewater Treatment Plant, Banning, Riverside County (Board Order). The Board Order requires the WWTP to remove constituents that present the greatest risk to groundwater quality including total nitrogen (TN), coliform, and total dissolved solids (TDS/salts). Currently, the average TN concentration in the WWTP effluent is 27 mg-N/L, well above the future TN limit of 10 mg-N/L specified in the Board Order. As a result, the RWQCB required the City to conduct a nitrogen removal analysis and summarize the findings in a technical report that included a tentative work plan and time schedule for the installation and implementation of nitrogen removal treatment alternatives. This final technical report was submitted to the RWQCB in 2020. In order to comply with these impending limits to continue discharging to the percolation ponds above the Cabazon Groundwater Basin, the City must upgrade the biological treatment system at the WWTP. The City proposes to upgrade the WWTP to recycled water 1117

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standards, in order to
both meet the Board
Order requirements as
well as serve irrigation
customers currently supplied
with groundwater recharged by
imported water.

3.2 Project Description
The proposed Project involves
upgrading the existing City
WWTP to California Code of
Regulations, Title 22
Environmental Health (Title 22)
standards for recycled water
use. This includes constructing
the following:

1. A membrane bioreactor
(MBR) system to replace the
existing trickling filters and
secondary clarifiers for
biological treatment

2. A chlorine contact tank to disinfect the water

3. A reverse osmosis (RO) system to further reduce TN and TDS levels

4. Evaporation ponds for the RO brine

5. Laterals along the existing non-potable water pipeline to serve recycled water to other City customers (including on-site signage and retrofits)

6. Other miscellaneous upgrades of the WWTP to improve the final effluent quality The average effluent of the Banning WWTP in 2023 was 2.2 MGD, or 2,470 AFY. This flow rate will increase steadily over the next few years due to new developments in the City (e.g., the Atwell development with an estimated 4,000 homes). The new treatment facilities will be sized at 2.4 MGD capacity, allowing for a 0.2 MGD safety factor. A portion of the WWTP effluent will serve irrigation customers currently using groundwater recharged by imported water. This total future demand is 2,060 AFY (see Table 2). The remaining recycled water supply (410 AFY) from the WWTP will continue flowing to the existing percolation ponds for indirect potable reuse into the Cabazon Groundwater Basin. The Project is regionally significant because it will produce high quality advanced reclaimed water that meets standards for recharge in the Banning, Beaumont and Cabazon basins (see Figure 3).

Other beneficiaries include the irrigation users who will convert to reclaimed water. Banning High School, Lions Park, Sun Lakes Golf Course, and Dysart Park are existing facilities currently serviced by the City. The Atwell housing development is under construction and is projected to be fully built within the next five to seven years. Banning High School, Dysart Park, and Lions Park lie above the Banning Storage Basin, while Sun Lakes Golf Course and the Atwell Figure 3. Regional Groundwater Basin Beneficiaries
(Banning, Beaumont and Cabazon)
(Banning 2020 UWMP)
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development, the two customers with the highest demand, are located above the Beaumont Storage Basin. To serve customers over the Banning Storage Basin, the only requirement the WWTP effluent must meet is Title 22 regulations (which can be met with MBR treatment and chlorine disinfection). However, to serve customers over the Beaumont Basin, the recycled water must also comply with the Beaumont Basin’s Maximum Benefit Objectives, which impose stricter regulations on TN and TDS levels; thus, the additional RO treatment step is included in the Project. See Figure 4 for a map of the planned recycled water system.

Table 2. Future Recycled Water Use and Demand4
Figure 4. Planned City of Banning Recycled Water System 4 1f9eac_e3a40fb5e6a64240bcf9b5ca5c86035a.pdf (sgirwm.org) Future Recycled Water Users Demand (AFY) Demand (MGD)
Existing Irrigation Areas
Banning High School 175 0.15
Lions Park 80 0.07
Sun Lakes Golf Course 865 0.77
Dysart Park 90 0.08
Subtotal 1,210 1.07
Phased Development In Progress
Atwell Master Planned Community 850 0.76
Subtotal 850 0.76
Total 2,060 1.83
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By producing advanced recycled water from the WWTP as projected in Table 3, the City will not only reduce its reliance on imported water, but also improve groundwater quality in the Cabazon Groundwater Basin. Since 100% of the City’s population is categorized as severely disadvantaged or disadvantaged, a reliable local supply of water will also support sustainability and economic development, which are dependent on the availability of water supplies.

Table 3. Current and Projected Recycled Water Production Use Year Produced / Used (AFY) Produced / Used (MGD)
2024 0 0
2027 2,470/1,210 2.2/1.07
2030 2,690/2,060 2.4/1.83

3.3 Proposed Scope of Work
The City of Banning has developed the following scope of work to implement the Project.

Task 1: Environmental Reviews and Permitting California Environmental Quality Act (CEQA) and National Environmental Policy Act (NEPA) documentation will be completed prior to initiation of construction of each component. The City does not anticipate that the Project will have negative impacts on endangered or threatened species, public health or safety, hydrology and regulated waters of the United States, or cultural resources. As such, the City will prepare an Initial Study/Mitigated Negative Declaration (IS/MND) for CEQA and expects that Reclamation will adopt a Finding of No Significant Impact (FONSI) for NEPA coverage for the Project.

Permitting includes the application and receipt for all applicable permits for the Project, including construction permits. Anticipated permits are listed below.

1. State Water Resources Control Board Division of Drinking Water (DDW) Title 22 Engineering Permit

2. Regional Water Quality Control Board – Colorado River Basin General Permit (combining Non-Discharge National Pollutant Discharge Elimination System [NPDES], Waste Discharge Requirement [WDR], and Waste Recharge Requirements [WRR])

3. RWQCB Notice of Intent (NOI)

4. RWQCB Notice of Applicability (NOA)

5. DDW – Recycled Water Customer Conversion Approval

6. Air Quality Management District (AQMD)

7. CEQA (IS-MND)
A Title 22 Engineering Report is required to be submitted for approval by DDW to meet water quality standards for recycled water. After the design documents are finalized, the City will submit the necessary reports, analyses, and applications to obtain required permits from the RWQCB.
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Task 2: Design Work under this task will include field investigations as well as preliminary and final design of the WWTP upgrades and conveyance.

Preliminary Design will include initial investigations consisting of an assessment and background research of the WWTP site. This assessment will evaluate and address the potential logistical issues, including but not limited to site access, available space for equipment, obstructions, above ground and underground utilities, and noise constraints.

A preliminary design report will be prepared that will summarize the evaluation of the WWTP site. The report will also include a planning-level estimate of contractor costs (i.e., engineer’s estimate) and preliminary design drawings. The planning-level cost of contractor costs for the construction, development, and testing of the proposed WWTP upgrades will be prepared based on local conditions and recent Contractor cost estimates for similar projects.

Final Design will include 30%, 60%, 90%, and final design drawings and specifications for the following Project components: MBR system, chlorine contact tank, RO system, evaporation ponds, pipeline laterals to recycled water customers (including on-site signage and retrofits), and other miscellaneous upgrades of the WWTP.

Task 3: Construction Work under this task will include mobilization, shop drawings, construction, commissioning and start-up, testing, and demobilization. Construction comprises the bulk of the work to be completed under the Project. During this stage, a detailed schedule of values will be developed for the bid package, with specific line items showing anticipated units and unit quantities for the construction of each item. Bidding and construction of the WWTP upgrades will be performed, including equipment procurement and installation, commissioning, and start-up.

The City plans to conduct activities to keep the public informed and engaged as the Project progresses. Activities include community workshops, public meetings, and distribution of outreach material via social media outlets.

Task 4: Construction Administration Construction administration will span the construction duration of the Project. This task includes confirmation of compliance with permits, review of construction activities, inspection and environmental monitoring during construction, and other construction administration needs.

The Project will be operational within 3 years from the date of initiation (Table 4).

Table 4. Project Schedule
Milestone / Task / Activity Planned Start
Date
Planned
Completion Date

1. CEQA Documentation/Permits January 2025 December 2025

2. Design January 2025 December 2025

3. Construction, Start-up, Testing, Commissioning January 2026 September 2027

4. Construction Administration January 2026 September 2027 1121

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4. EVALUATION CRITERIA
Evaluation Criterion 1—Water Supply (35 points)
Sub criterion No. 1a—Stretching Water Supplies (18 points)

1. How many acre-feet of water are expected to be made available each year upon compleAon of the Project? An esAmated 2,470 AFY (2.2 MGD) – the total average WWTP effluent – of locally-sourced nonpotable recycled water will be made available each year upon compleAon of the Project. The expected annual non-potable water demand is 2,060 AFY (Table 2). The recycled water generated from this Project will saAsfy this demand and “free up” both potable water and current non-potable well water that can now be permiTed for drinking water use instead of irrigaAon. The breakdown of current water use by sector shows that irrigaAon makes up a significant percentage (more than 15%) of total current water use (see Table 5). Future phases of upgrades at the WWTP and populaAon growth will generate an even greater volume of recycled water. Table 5 does not capture the surplus recycled water that will be available for groundwater recharge.

Table 5. Recent and Projected Water Use by Sector (Acre Feet)5 Sector 2024
Demand/Use
2030
Demand/Use
2045
Demand/Use
Single Family Residential 3,637 (51.9%) 5,071 6,382
Multi-Family Residential 192 (2.7%) 103 130
Commercial 808 (11.5%) 2,548 3,206
Industrial/Government 861 (12.3%) 29 37
Public Water Systems 335 (4.8%) 0 0
Landscape Irrigation POTABLE 916 (13.1%) 0 0
Landscape Irrigation NON-POTABLE
WELL
189 (2.7%) 0 0
Landscape Irrigation

NEW RECYCLED WATER
0 2,0606 3,2457
Unaccounted Water (losses) 67 (1.0%) 1,630 2,052
Total Water Consumption 7,005 11,441 13,467
Water Service Area Population 31,179 45,235 66,400

5 2020 Banning Urban Water Management Plan
6 Landscape irrigation currently sourced by potable and non-potable well sources for (parks, a golf course, school green spaces etc.) detailed in Table 2.
7 Potential Regional recycled water Demand from the 2018 San Gorgonio Regional Integrated Water Management Plan
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2. Will the Project reduce, postpone, or eliminate the development of new or expanded non-recycled water supplies?
Yes, the Project will reduce the development of new imported water supplies for groundwater recharge, as the City will rely solely on the new recycled water supply to meet their nonpotable water demands. The reduction of imported water demand will be in a 1:1 ratio with the deliveries of recycled water. The City currently purchases non-potable imported water from the Sacramento-San Joquin River Delta (Bay Delta) in Northern California through the San Gorgonio Pass Water Agency (SGPWA). Table 6 shows the City’s last 6 years of imported water purchases. In 2021, no imported water was delivered due to a lack of supply from the Bay Delta caused by drought conditions, highlighting the unreliability of imported water deliveries. The City’s imported water purchases are expected to increase due to new developments, unless offset by recycled water generated by the proposed Project.

The imported water is used for recharging the City’s groundwater supply, which the City relies on to meet the current water demands listed above in Table 2. Because new recycled water from the Project will serve the existing non-potable water customers in place of groundwater, the City’s groundwater basins will no longer require this additional imported water recharge.

This will reduce the City’s need for imported water supplies by 1,210 AFY.

To meet the irrigation demands of the Atwell development, the City will need to purchase an additional 850 AFY. The new recycled water supply will offset this additional 850 AFY of imported water. Therefore, this Project will enable the City to avoid purchasing a total of 2,060 (1,210 + 850) AFY of imported water to meet irrigation demands.

3. Will the Project alleviate pressure on exisAng water supplies and/or faciliAes? Yes. The City currently operates two non-potable groundwater wells, Wells M7 and M12 to meet the demands of the Sun Lakes Golf Course (see Figure 5). By supplemenAng groundwater with recycled water to supply Sun Lakes, the Project enables the City to convert Wells M7 and M12 to be pumped and treated for potable water use. This shiV alleviates pressure on both wells, as they will no longer be required to meet the demands of Sun Lakes and can instead serve other exisAng or future potable water needs. As a result, the City will gain redundancy and reliability in its water producAon capacity.

The City’s other non-potable customers, Banning High School, Dysart Park, and Lions Park are supplied with potable groundwater. By supplying recycled water to these customers instead of groundwater, the Project will reduce the demand on potable water supplies. With more potable water sources available, the need to construct new wells and storage reservoirs for the City’s water system will also be eliminated.

Year Purchases (AF)
2018 500
2019 250
2020 250
2021 0
2022 35
2023 1,000
Table 6. Imported Water
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By generaAng a new recycled water supply, it will reduce the strain on the City’s groundwater basins, which would otherwise have been required to meet the needs of projects like Atwell. The Project does not incenAvize or enable new irrigaAon areas but, will provide for valuable green space in exisAng, master-planned, “smart development” already underway.

4. What performance measures will be used to quantify actual benefits? The following performance measures will be used to quantify the benefits of the Project:
• Improved WWTP final effluent quality: By installing an MBR system and RO facility at the WWTP, the final effluent of the WWTP will have significantly improved water quality, specifically in reduced TN and TDS concentrations, as the effluent must meet RWQCB Board Order requirements, Title 22 regulations, and the Beaumont Basin Maximum Benefit Objectives.
• Measured by analyzers and sensors installed at the WWTP post RO treatment (the last stage of treatment) and monthly sampling to validate standards. • Improved groundwater quality and recharge: The portion of WWTP effluent not used to serve irrigation customers will discharge to percolation ponds above the Cabazon Groundwater Basin. With the implementation of the new treatment systems (MBR and RO), the water discharging to the percolation ponds will be of much higher quality, resulting in improved groundwater quality in the Cabazon Basin. • Measured through quarterly sampling of these monitoring wells adjacent to the percolation ponds: R-1, MP-1, and C-6.
• Recharge measured through excess not delivered to irrigation sites.

The project will deliver
recycled water to irrigate
the 250-acre Sun Lakes
site. The City’s nearby
wells can then be used to
produce potable water.

RECYCLED WATER

CREATES A WIN-WIN
Figure 5. Sun Lakes 55+ community with two 18-hole courses 1124

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• Improved supply reliability: The Project will create a new, drought-resilient local recycled water supply that will greatly improve supply reliability. The City will have a total annual non-potable water demand of 2,060 AFY in the near future. Since this Project will create 2,470 AFY of advanced recycled water, this will meet 100% of this demand, increasing supply by 100% in addition to providing clean, purified recycled water for recharge.
• Measured using a flowmeter at the distribution point of the WWTP. • Production of recycled water: This Project will create 2,470 AFY of disinfected, advanced tertiary recycled water that will be used for direct non-potable reuse. • Quantified with flowmeter readings of the WWTP effluent flow. • Delivery of recycled water: Once the Atwell development is complete, 2,060 AFY of recycled water from the WWTP will be delivered to recycled water customers. • Quantified with flowmeter readings at distribution points.

Sub criterion No. 1b—Contributions to Water Supply Sustainability (17 points) Will the Project make water available to address a specific concern? Water supply reliability
Currently, there is 0 AFY of recycled water produced by the City. All current non-potable needs are met by potable and non-potable groundwater recharged by imported water. This Project will create a new, reliable non-potable recycled water supply of 2,470 AFY from the WWTP effluent. This water supply can meet 100% of future (2,060 AFY total) non-potable needs in the City. Recycled water is considered a reliable water source for several reasons:
• Consistency: Unlike traditional water sources that can be heavily impacted by drought, recycled water is consistently available because it is derived from treated wastewater, which is continuously produced by communities. This is especially important in Banning which was severely impacted by the 2020 drought.
• Local Supply: Recycled water reduces dependence on imported water sources, which can be unreliable during drought conditions. California demands on limited imported water from the Colorado River and the Bay Delta are extreme. Many communities rely exclusively on these sources. This underscores the importance of Banning’s ability to generate and maximize local water.
• Sustainability: By reusing water, Banning can conserve potable resources, ensuring that more water remains available for essential uses during drought periods.

Groundwater depletion
Currently, the City’s largest non-potable water customers, Sun Lakes Golf Course, is supplied by groundwater Wells M7 and M12. Other existing non-potable water customers, including Banning High School, Dysart Park, and Lions Park, are supplied with potable groundwater. This Project involves replacing these groundwater sources with recycled water from the WWTP to meet customer demands. This alleviates pressure on the wells, thereby helping to prevent the 1125

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depletion of these groundwater sources. In addition, recycled water from the Project will be used to serve the new Atwell development that is currently being constructed, thus offsetting further depletion of groundwater.

Water quality issues
Currently, the existing WWTP process does not effectively remove nitrates from the wastewater to meet the impending RWQCB water quality limits. By upgrading the WWTP to include MBR and RO, this will reduce the total nitrogen (TN) in the effluent from 27 mg/L to 4 mg/L, allowing the City to meet the RWQCB requirements of 10 mg/L. In addition, through the RO system, total dissolved solids (TDS) in the water will decrease from 410 mg/L to 207 mg/L.

Since approximately 410 AFY of the treated WWTP effluent will be discharged to the percolation ponds over the Cabazon Groundwater Basin, the improved water quality of the water will allow the City to both meet RWQCB limits and alleviate rising nitrate and salt levels observed in the Region. This improved water quality discharged over the Cabazon Groundwater Basin is shown in Table 7.

Table 7. WWTP Effluent Water Quality Discharged into the Cabazon Groundwater Basin8 Constituent Before the Project After the Project
Total Nitrogen (TN) 27 mg/L 4 mg/L
Total Dissolved Solids (TDS) 410 mg/L 207 mg/L
Natural disasters impacting water supply infrastructure Banning is extremely
vulnerable to natural
disasters that can
severely impact water
delivery infrastructure.

This Project will create a
new water supply that
can be made available in
the event of a natural
disaster or emergency.

For instance, the
recycled water source
can be used by
firefighters to combat
wildfires in the area.

Access to recycled water
will be from storage
tanks and reservoirs.
8 Values based on Biowin modeling of the proposed system Figure 6. Apple Fire August 2, 2020
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Banning has a significant border that interfaces with wildlands susceptible to fires that are becoming more frequent as the climate changes. The Apple Fire in 2020 proved just how vulnerable Banning and its water infrastructure are to wildfire impacts (see Figures 6, 7, and 8).

The fire also damaged two groundwater wells (8 and 10) and destroyed a critical water flume that conveys water to the unincorporated, disadvantaged communities of Banning Heights and the City of Banning. Drought conditions created tinder dry terrain in Banning and the surrounding landscape; the Apple Fire burned over 33,000 acres. The fire forced mandatory evacuations impacting more than 2,500 homes and 8,000 residents.

Figures 7 and 8. Whitewater flume Apple Fire damage
In addition, Banning lies in a seismically active landscape where earthquakes can impact imported water conveyance, including the canals used to deliver water into Southern California through the State Water Project (SWP). This Project will enable the City to rely less on imported water. Local water supplies could also be impacted but having more source options in the system gives Banning greater resilience to earthquake damage. According to the California Office of Emergency Services’ online planning tool (My Plan) and the California Geological Survey’s online earthquake hazards zone application (EQ Zapp), several faults, including the Banning Fault and portions of the San Gorgonio Fault Zone (orange lines below), are present within the City's sphere of influence (see Figure 9).

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Heightened competition for water supplies
The City purchases imported water from the SGPWA through the State Water Project.

However, due to droughts and other factors, the availability of that water is expected to decrease, and competition is expected to increase. According to the Department of Water Resources’ 2023 State Water Project Delivery Capability Report, State Water Project delivery capability is expected to reduce as much as 23% in the next 20 years.9 This decrease in the future availability of surface water deliveries confirms the unsustainable nature of imported water and an urgency for reliable local supplies. This Project involves creating a drought-proof water supply that will reduce imported water purchases. This will protect the City from the effects of climate change and the resulting competition for imported water resources.

Availability of alternative supplies
Banning’s Project also bolsters groundwater recharge with a continuous reliable source of recycled water, as opposed to the imported water which is currently used for recharge. Both groundwater and imported water are sources reliant on rainfall and therefore susceptible to climate change and droughts. This Project presents a valuable opportunity to create a reliable, local supply of non-potable water to supplement this unreliable alternative water supply.

Cost-Effectiveness
Over time, investing in water recycling infrastructure will be more cost-effective than developing new water sources or imported water from northern California or the Colorado 9 https://smartwatermagazine.com/news/california-department-water-resources/californias-state-water-project-maysee-a-23-decline Figure 9. Fault Zones In and Near Banning1
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River. The cost to continue serving irrigation customers with groundwater recharged with imported water is $1,581/AF (see Evaluation Criterion 3 for more details) and is expected to increase in the foreseeable future. After the initial investment in the WWTP upgrades, Banning will be able to reliably produce recycled water for $1,287 per acre foot. These savings will allow Banning to keep water and wastewater rates lower for its customers who face significant economic burdens. Additionally, recycled water uses are not restricted during droughts, therefore the Sun Lakes Golf Course and other recreational areas will be sustained and usable, even during devastating dry periods. According to the California Department of Water Resources (DWR) Mapping Tool10, Banning’s population is categorized as 100% severely disadvantaged or disadvantaged. Severely disadvantaged communities such as Banning (shown in Figure 10) suffer from a combination of economic, health, and environmental burdens. These burdens include poverty, high unemployment, air and water pollution, presence of hazardous waste, and a high incidence of asthma and heart disease. Severely disadvantaged communities are also disproportionately affected by drought and water restrictions. The Project benefit area is the entirety of the City of Banning and its regional neighbors, including the Morongo Reservation, Beaumont, and Cabazon who are all water interdependent.

Will project help create additional flexibility to address drought? Yes. This Project allows Banning to provide recycled water even during periods of drought, as it is generated from wastewater, a consistent and reliable source. Unlike alternative water supply options, such as surface and groundwater, that depend on precipitation for recharge, wastewater is generated continuously through domestic and industrial processes. This means that even during droughts, when groundwater sources may be limited, recycled water can still be produced and supplied. By relying on the constant supply of wastewater rather than groundwater or imported sources, the Project guarantees non-potable water supply reliability, 10 https://gis.water.ca.gov/app/dacs/
Figure 10. CA DWR Disadvantaged Communities Mapping tool 1129

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bolstering available potable supplies and drought resiliency.

1. Has the area served by the Project been identified by the United States Drought in the last 4 years? Yes. the United States Drought Monitor (Figure 11) reported Banning’s service area and the entirety of Riverside County enduring severe drought (orange) in 2020, 2021, 2022, and 2023, extreme drought in 2020, 2021, and 2022 (red), and exceptional drought (brown) in 2021.

In 2021, drought conditions escalated to catastrophic levels in California. Banning experienced severe drought, and conditions were even more dire with extreme and exceptional drought parching most of the state. As shown in Figures 12 and 13, summer 2021 drought conditions triggered the Westward Fire near Banning High School on August 25th, prompting numerous evacuations.

Figures 12 and 13. 2021 U.S. Drought Monitor11 and Westward Fire in Banning12 11 https://droughtmonitor.unl.edu/
12 Photo credit NBC News Palm Springs City News Service Figure 11 U.S. Drought Monitor Riverside County Drought Classification 1130

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Severely disadvantaged communities like Banning disproportionately bear the consequences of drought. Banning residents suffer social, economic, and environmental drought impacts.

Social impacts include reduced income, reduced recreational activities, public safety threats, and depression and anxiety due to economic struggles and water insecurity. Additionally, drought-associated health problems related to increased heat, dust, and wildfire smoke have an undue effect on Banning residents, a population that already suffers with asthma rates that are higher than 89 percent of census tracts in California, and cardiovascular disease rates that are higher than 98 percent of California census tracts.

Economic impacts from droughts strike Banning residents particularly hard. Increased costs for food, water and electricity can be insurmountable for residents that have poverty-level median household incomes. Increased costs of imported water and reduced city water revenues have long-lasting budgetary impacts for the Banning Water and Wastewater Utilities Department, resulting in rate increases for end users. These increased costs add to the overwhelming burdens borne by disadvantaged residents. Finally, Banning residents have suffered from environmental effects of drought including low water levels and the resultant water restrictions, as well as decreased water and air quality and heightened risk of wildfires.

2. Has the area served by the Project been designated as a state drought disaster area in the last 4 years? Yes, in the last four years, Riverside County, including the Banning service area, has been designated as a drought disaster emergency area by the State of California and the U.S.

Department of Agriculture (USDA). In October 2021, with water conservaAon efforts conAnuing to fall short, Governor Gavin Newsom extended a drought emergency declaraAon statewide, adding eight counAes that were previously excluded, including all of Southern California. The drought emergency proclamaAon conAnued statewide through 2022.13 In March 2021, the USDA also designated Riverside County (including Banning) as a primary disaster area. USDA issued another drought declaraAon in the county in July 2022 reflecAng worsening condiAons.

In March 2023, a local emergency proclamaAon was issued due to extreme weather including drought.

Evaluation Criterion 2—Environment and Water Quality (15 points)

1. Will the Project improve the quality of surface water or groundwater? If so, how? Yes, the Project will improve groundwater quality but will not involve surface water. Upon compleAon of the Project, a porAon of the WWTP effluent will serve irrigaAon demands to customers over the Beaumont and Banning Storage Basins. The rest will discharge to the exisAng percolaAon ponds to recharge the Cabazon Groundwater Basin.

The Project involves upgrading the biological treatment at the WWTP from Trickling Filters to an MBR system. MBR yields very high effluent water quality, leading to lower TN, BOD, and TSS levels. An RO system will also be implemented post MBR treatment to meet the Beaumont Basin Maximum Benefit ObjecAves, further lowering TN and TDS levels. As a result, the Project will contribute to improving the water quality of the groundwater in the Cabazon Groundwater 13 https://cww.water.ca.gov/emergency-county
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Basin. Table 8 indicates the current Cabazon Basin quality compared to the new recycled water effluent quality. The improved water quality of the WWTP effluent will result in lower concentraAons of both nitrate and salt concentraAons in the recycled water compared to the current groundwater quality. Consequently, the water discharged across the Cabazon Basin will enhance overall groundwater quality condiAons.

Table 8. Groundwater Basin Water Quality Improvements
Parameter
(Units)
Current Cabazon Basin
Water Quality
Future Cabazon Basin
Water Quality
TN (mg/) 12 4
TDS (mg/L) 380 207

2. Will the Project improve effluent quality beyond levels necessary to meet State or Federal discharge requirements?
Yes, the Project will improve effluent quality beyond State discharge requirements. There are no Federal discharge requirements for non-potable recycled water. The City has the following three requirements for the water to meet: an impending RWQCB Board Order to conAnue discharging to the Cabazon Basin, Title 22 regulaAons to supply recycled water to customers, and Beaumont Basin Maximum Benefit ObjecAves to serve Sun Lakes Golf Course and the Atwell development. California’s water recycling criteria outlined in Title 22, Code of RegulaAons includes requirements for turbidity, chlorine residual, coliform, and other consAtuents. However, only the regulaAons with TN and TDS limits are listed in the table below.

As shown in Table 9, the Beaumont Basin has the most stringent regulaAons for TN and TDS, more so than the RWQCB and Title 22 regulaAons. As such, the expected water quality of the WWTP effluent will have beTer effluent quality than State requirements to accommodate for the TN and TDS Beaumont Basin requirements.

Table 9. Beaumont Groundwater Basin Water Quality Improvements Parameter
(Units)
Current WWTP
Effluent Quality
Colorado Regional
Water Quality Control
Board Order
Beaumont Basin
Maximum Benefit
Objectives
Expected WWTP
Effluent Quality
TN (mg/L) 27 10 5 4
TDS (mg/L) 410 500 330 207
AddiAonally, the Project’s RO treatment system for wastewater effluent will also effecAvely reduce Hexavalent Chromium (Cr6). New State regulaAons will require water suppliers to reduce levels of Cr6. In addiAon to contaminaAng groundwater, the Cr6 is also present in wastewater. Cr6 is considered a toxic and carcinogenic substance, making its presence in all water, including wastewater, a significant environmental concern. Typically, RO systems can remove up to 90-99% of Cr6. AddiAonally, studies and reports from the Environmental ProtecAon Agency also indicate similar removal efficiencies. This is significant. The Project will 1132

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improve groundwater quality by recharging underground supplies with cleaner water that contains reduced levels of Cr6.

For the brine
management of the RO
system, brine
evaporaAon ponds will
be constructed on City
property near the
percolaAon ponds. The
expected brine flow is

0.084 MGD, assuming
parAal blending and a
recovery rate of 93%.

This will require
approximately 15 acres
of salt evaporaAon ponds
and 10 mechanical
evaporators. These
evaporaAon ponds will be subject to regulaAon under the California Code of RegulaAons, Title 27 Environmental ProtecAon (27 CCR), Division 2 Solid Waste. To comply with this regulaAon, the design of the evaporaAon ponds will include several layers of protecAon and monitoring capabiliAes. See Figure 14 pond locaAons. The City will also be looking into opAmizing brine management by connecAng into the Santa Ana Watershed Project Authority (SAWPA) Inland Empire brine line through the City of Beaumont.

3. Will the Project improve flow condiAons in a natural stream channel? If so, how? Yes. This Project benefits extend north to the Bay Delta, as it will decrease purchases of imported water supplies drawn from the Sacramento-San Joaquin Delta (Bay Delta) by 2,060 AFY. This helps improve flow condiHons in the natural stream channels of the Bay Delta.

Impacts from withdrawals occur due to the change of river flow by pumping, capture within pumping equipment, and increased saltwater intrusion due to pumping. A decrease in water imported through the SWP could help to alleviate these pressures on the Bay Delta ecosystem and restore habitat for non-listed species.

4. Will the Project restore or enhance habitat for non-listed species? If so, how? Yes, recycled water will help sustain important urban green spaces and protect other ecosystems by reducing the need to extract water from aquifers, ulAmately benefi\ng nonlisted species in the San Gorgonio/Coachella Valley region. These funcAonal turf and park areas play a crucial role in restoring and enhancing habitats for non-listed species. Urban green spaces, such as parks, gardens, and turf areas offer essenAal habitats for a variety of species, including pollinators, birds, and small mammals. These areas can support naAve species by providing food, shelter, and breeding grounds. Green spaces also act as corridors that connect fragmented habitats, allowing species to move and disperse more freely across urban landscapes. This connecAvity is vital for maintaining geneAc diversity and healthy populaAons.

Figure 14. Proposed Location of Brine Evaporation Ponds 1133

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Green spaces help miAgate urban stressors like polluAon and heat islands, creaAng more favorable condiAons for wildlife. They also provide refuges where species can thrive despite the challenges of urban environments. Urban green spaces are not just for human enjoyment; they are vital for supporAng and enhancing urban species biodiversity.

In addiAon, recent droughts resulted in reduced flows into the Bay Delta. With conAnued exports for water supply, there has been an overall reducAon in aquaAc habitat availability and higher contaminant concentraAons from agricultural runoff in both the Sacramento and San Joaquin River systems. Therefore, since this Project reduces imporAng water from the Bay Delta, the Project will help enhance the habitat for all affected species by allowing it to become more resilient to changing climate paTerns. The 2013 Bay Delta ConservaAon Plan14 idenAfied over 30 non-listed species potenAally impacted by withdrawals from that system through the SWP. These non-listed species will benefit from the reducAon of imported water, as many species rely on this habitat for ecologic funcAon at various life stages.

5. Will the Project provide water or habitat for federally listed threatened or endangered species? If so, how? Yes, because this Project sustains urban green spaces, several federally protected species in Riverside County will reap habitat benefits. The parks, recreaAon areas, and tree canopies irrigated with recycled water will enhance habitat connecAvity by creaAng wildlife corridors that link fragmented habitats in Banning with the densely developed Southern California landscape. They allow species to move more freely and maintain geneAc diversity. CriAcally, the Pacific Flyway, a major north-south route for migratory birds in America, extends from Alaska to Patagonia passes through Banning. Many birds travel through California, including areas like Banning, as they migrate between their breeding and wintering grounds. These irrigated green areas also provide essenAal refuge and shelter for wildlife offering a safe haven from urban threats like traffic, polluAon, and drought. Green spaces support a variety of plants and insects that provide food resources. Riverside County protected species that will benefit from sustainable landscaped areas include the Stephens and San Bernardino Kangaroo rat, California Gnatcatcher, and Quino Checkerspot BuTerfly.

This Project will also produce non-potable water supplies that will directly offset imported water from the Bay Delta. This will result in additional water left in the Bay Delta that can support native habitats for federally listed or endangered species.

Evaluation Criterion 3—Economic Benefits (25 points)
Subcriterion No. 3a—Cost Effectiveness (15 points)

1. Reclamation will calculate the cost per acre-foot of water produced by the Project.

Project Construction will begin in 2025, and it is estimated that approximately $6,211,260 will be completed by the end of this first year, about 12% of the total construction cost. 55% ($28,468,275) of the total construction cost will be completed in 2026, and the remaining 33% ($17,080,965) in 2027. The Opinion of the Construction Cost (OPCC) estimate was developed using the American Associations of Cost Engineers guidelines and recommendations. The OPCC was completed by the City’s Owner’s Engineer consultant following AACE Class 4 cost 14 Public Draft, Bay Delta Conservation Plan: Executive Summary (ca.gov) 1134

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estimating methodology. The estimate was developed based on industry standards, and adjusted to the anticipated Project’s complexity, with market conditions and cost escalation at the time of the estimate. The total OPCC was estimated to be $51,760,500. Table 10 allocates construction costs by year.

Table 10. Estimated Construction Cost per Year, in 2024 dollars Calendar Year Cost
2025 $6,211,260
2026 $28,468,275
2027 $17,080,965
Total $51,760,500
(a) The total esAmated or actual costs to plan and design the Project.

Table 11 details the planning and design costs of the Project. The design is expected to be completed within one year by December 2025. ConstrucAon Management tasks will occur in 2026 and 2027, the two years during which most construcAon will take place.

Table 11. Total Planning and Design Costs by Year, in 2024 dollars Year Planning or Design Activity Cost
2025 Predesign, Final Design, and CEQA $3,923,235
2026-2027 Construction Management $3,205,630
Total $7,128,865
Since the Project development is in the planning stage and the contract for performing design has not yet been executed by the City, the cost estimate methodology for the design and construction management services are based on percentages of construction costs. Design costs were estimated at 7% of the construction cost (2% for predesign and 5% for final design).

These percentages were confirmed by the 2023 California Multi-Agency Benchmarking Study (see Table 12). Based on Table 1.1 of this guide, design tasks are typically no more than 25% of the total construction cost for Water/Wastewater Facilities and construction management is typically no more than 24%. The $300,000 environmental cost is based on the City’s estimated contract value for the development of an Initial Study-Mitigated Negative Declaration (IS-MND). 1135

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Table 12. 2023 California Multi-Agency Benchmarking Study, in 2023 dollars15 (b) The esAmated expected average annual operaAon and maintenance costs for the life of the Project.

Average annual operation and maintenance (O&M) costs for the Project components are presented in Table 13 and are based on estimates provided by the City’s Owner’s Engineer consultant, who developed them based on similar projects and planning-level estimates. The unit electricity cost assumed for this estimate was $0.20/KWh. As shown in the table, total annual O&M costs in 2024 dollars for the Project are projected to be approximately $2,853,350.

Table 13. Average Annual O&M Costs, in 2024 dollars
Project Component Estimated Annual O&M Cost
Labor $1,242,000
Power $1,577,600
Chemicals $33,750
Total O&M Costs $2,853,350
(c) The year the Project has or is expected to begin to deliver reclaimed water.

As shown in Table 14, the Project will be completed and delivering reclaimed water in 2027.

Table 14. Project Schedule
Milestone / Task / Activity Start Date Completion Date

1. CEQA Documentation/Permits January 2025 December 2025

2. Design January 2025 December 2025

3. Construction, Start-up, Testing, Commissioning January 2026 September 2027

4. Construction Administration January 2026 September 2027 15 California Multi-Agency CIP Benchmarking Study | Bureau of Engineering (lacity.gov) Type Design Construction
Management
Total
Project
Delivery
Median
Total
Construction
Cost
Number
of
Projects
Municipal Facilities 21% 14% 35% 1.54 77
Parks 28% 21% 50% 1.19 52
Pipe Systems 17% 20% 37% 1.63 205
Streets 27% 27% 54% 1.71 155
Wastewater & Water Facilities 25% 24% 50% 1.98 58
ALL TYPES 23% 22% 44% 1.64 548
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(d) The Projected life (in years) that the Project is expected to last. Note: this should be measured from the Ame the Project starts delivering water.

The Project has an expected 50-year project life; this includes treatment equipment and recycled water pipeline laterals. The Project is expected to be completed in 2027, with the first full year of delivery in 2028. The Project is therefore expected to last through 2077, at a minimum.
(e) All esAmated replacement costs by year as shown in Table 5. If there are mulAple replacement costs in one (1) year, or at the same interval, please total them and put them on one line with the year or interval.

Like the average O&M costs presented in Table 13 replacement costs for the Project components are based on planning level estimates from the Owner’s Engineer consultant and budgetary manufacturer’s quotations. Replacement costs and timing are presented in Table 15, and replacement frequency is assumed to begin in 2028, the first full year of recycled water delivery. It shall be noted that the estimated replacement costs are presented in 2024 dollars without any escalation.

Table 15. Replacement Cost Timing, in 2024 dollars
Replacement Requirement Frequency Year(s) Cost
Spare Parts / Replacements Every year Every Year from 2028 to 2077 $326,475 RO Membrane Replacement and
MBR Membrane Replacement Every 5 years
2033, 2038, 2043, 2048, 2053,
2058, 2063, 2068, 2073, 2078 $2,200,000
(f) The maximum volume of water (in acre-feet) that is expected to be produced annually upon compleAon of the Project.

At Project compleAon, the City’s WWTP will produce 2,470 AFY of recycled water. However, as City development grows and WWTP influent increases, more water will conAnually be made available for recycled water use. This is not a growth-inducing Project, but due to low housing costs and economic development land availability, Banning’s populaAon is expected to increase.

2. ReclamaAon will calculate the cost per acre-foot for the Project using the informaAon requested in quesAon No. 1 and compare it to the non-reclaimed water alternaAve, and any other water supply opAons that the applicant idenAfies to evaluate the cost effecAveness of the Project.

Without the Project, the City would continue to supply non-potable customers with groundwater supply. Non-potable groundwater wells, including M7 and M12, could not be converted to potable wells, as they would need to be used to meet Sun Lakes Golf Course’s demands. This would contribute to the depletion of the City’s groundwater supply.

The City would also keep relying on imported Bay Delta water to recharge the City’s groundwater basins to meet the demands of the Sun Lakes Golf Course (and the Atwell development, in the near future). However, imported water is expected to become increasingly unreliable due to its vulnerability to droughts and heightened competition. 1137

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The City has also recently discovered Chromium VI in their wells. On March 28, 2022, the California Division of Drinking Water (DDW) released a draft Cr6 maximum contaminant level (MCL) of 10 μg/L. Approximately eight existing City-owned wells, one future City-owned well designated Well C8, and two co-owned wells have Cr6 concentrations above the draft MCL.

Without this Project, the City would need to invest in treating all eleven active wells to continue serving the City’s customers. However, since this Project involves reducing groundwater reliance for recycled water, the Project would allow the City additional time to construct treatment facilities at these wells and lessen the financial impact on its rate payers.

This “Do Nothing” Alternative is Alternative 1 (further described in the Section below).

However, the primary driver for this proposed Project is compliance with impending RWQCB Board Order regulations. The City cannot “Do Nothing,” as the WWTP must be upgraded to meet the new TN limit.
a. Provide the cost per acre-foot of other water supply alternaAves that could be implemented by the non-Federal Project sponsor in lieu of the Project.

The alternaAve water supply that the City would use in place of recycled water is groundwater recharged by imported water. This corresponds to the “Do Nothing” AlternaAve (AlternaAve 1), as the City would maintain its current supply of groundwater to its nonpotable customers. As menAoned previously, the City is expected to import an average of 2,060 AFY of water, once the Atwell development is complete. The total cost to conAnue serving irrigaAon customers with groundwater recharged by imported water is $1,581/AF, which includes the $399/AF for the cost of imported water, $432/AF for the electrical pumping costs associated with imported water delivery, $300/AF for maintenance of faciliAes associated with imported water recharge, and $450/AFY for Cr6 treatment (further described in the secAons below).

As shown in Table 16, the cost to produce recycled water in Banning is less than using groundwater recharged with imported water.

Table 16. Cost Efficiency
RECYCLED WATER VS. GROUNDWATER COST PER ACRE FOOT
Recycled Water $1,287 Groundwater Recharged by Imported SGPWA Water
$1,581
a. If available, provide the cost per acre-foot of one water supply project with similar characterisAcs to the Project.

One alternative that the City could implement is incorporating indirect potable reuse over the Banning Basin in addition to non-potable reuse. Instead of the WWTP effluent that is not used to meet recycled water demands discharging to the percolation ponds (as proposed in the Project), the remaining effluent would flow to a groundwater aquifer, North Basin, for indirect potable reuse. Currently, the WWTP effluent that recharges the Cabazon Groundwater Basin through the percolation ponds is not entirely extracted by Banning - the percolated water flows to other water agencies located downgradient. By percolating to new basins upgradient of the 1138

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Banning groundwater storage unit, this will keep groundwater recharge within the City’s wells.

This “North Basin” option is further known as Alternative 2.

North Basin is in the northeastern part of the City boundary. This site is not owned by the City.

Since the site has been mined and a large pit exists, it is assumed that minimal earthwork will be required. The site improvements included as part of this analysis include a berm on all four sides of the basin, a berm to create two cells for operational flexibility, basin piping, maintenance ramps, security, and monitoring equipment. Since the potential recharge basin is at a higher elevation than the WWTP, an 800 HP pump and 15,000 feet of 16-inch diameter pipeline will be required to convey water from the WWTP to the recharge basin. The City will also need to add monitoring wells and lysimeters. This option would have a cost per acre foot of $1,778, assuming a yield of 2,470 AFY (same as the proposed Project) and an annual cost of $4,391,025.
b. Discussion of the degree to which the Project is cost-effecAve.

Under Alternative 1, the City would “Do Nothing.” The estimated yield is 2,060 AFY—the total non-potable demand (Atwell full buildout). Annual and O&M costs are based on the cost of imported water, electrical pumping costs and maintenance costs associated with imported water delivery, and Cr6 treatment costs. The unit cost (in $/AF) equals annual cost / annual yield. However, as mentioned previously, Alternative 1 is not viable, as the impending RWQCB Board Order requires a biological treatment upgrade of the WWTP to achieve the minimum TN limits.

The capital cost for Alternative 2 is $80,036,200. This alternative would allow the City to achieve the objectives of the proposed Project (also referred to as Alternative 3) in addition to retaining water within the City’s wells and extraction sites. However, due to the additional site work, pumps, and piping required to deliver water to the North Basin, the overall capital, O&M, annual, and therefore unit cost of this alternative is high relative to Alternatives 1 (“Do Nothing”) and 3 (“Proposed Project”). Currently, the City is unable to implement this alternative because of limited available funds. However, this could become a potential future project once the City secures the necessary funding. See a cost comparison of the alternatives in Table 17. As shown in the table, the proposed Project has the lowest unit cost per AF.

Table 17. Monetary Analysis
Alternatives
Estimated
Annual Yield
(AFY)
Capital Cost
($)
O&M Cost
($/year)
Annual Cost
($/year)
Unit Cost
($/AF)
Alternative 1 (Do
Nothing) 2,060 $0 $3,256,860 $3,256,860 $1,581
Alternative 2
(North Basin) 2,470 $80,036,200 $3,901,200 $4,391,025 $1,778 Alternative 3
(Proposed Project) 2,470 $64,778,300 $2,853,350 $3,179,825 $1,287 1139

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Also, Banning is utilizing a progressive design-build approach which offers several cost and pragmatic efficiencies as described below.
• Integrated design and construction allow for better collaboration between engineers, contractors, and stakeholders. This leads to more innovative solutions and streamlines processes.
• Flexibility to accommodate adjustments during the Project based on real-time feedback and evolving requirements leads to more efficient use of resources and time. • Cost and time savings completes projects faster and often at a lower cost compared to traditional methods. This has proven to be particularly beneficial for complex projects like tertiary treatment upgrades.
• Enhanced quality control occurs with involvement of the design team during construction to ensure the Project adheres to the intended design specifications and quality standards.
• Improved risk management with the collaborative nature of progressive design-build, potential risks are identified and mitigated earlier in the Project implementation, reducing the likelihood of costly delays and rework.

A progressive design build success story comes from the Mel Leong Treatment Plant in San Fransisco where upgraded wastewater treatment processes and construction of a new recycled water treatment facility documented the efficiencies mentioned above, resulting in a successful upgrade that met regulatory requirements and improved water quality16.

Subcriterion No. 3b—Economic Analysis and Project Benefits (10 points)

1. Summarize the economic analysis performed for the Project including informaAon on the Project’s esAmated benefits and costs.
(a) QuanAfied and moneAzed costs, including expected capital, operaAons and maintenance costs.

Table 18 summarizes the capital, O&M, and foreseeable replacement costs of the Project.

These costs have been described in detail under Subcriterion 3a; total capital cost includes a contingency of 10%. The present value of these costs over the 50-year lifetime of the Project is estimated to be $569M in future cost and $181M in present cost (assuming an inflation rate of

3.75% and nominal discount rate of 5%), as seen in Appendix C.

Table 18. Monetary Summary of the Selected Alternative
Estimated
Annual Yield
(AFY)
Capital Cost O&M Cost Annual Cost
($/year)
Unit Cost
($/AF)
50-Year
Future Cost
50-Year
Present Cost
2470 $64,778,300 $2,853,350 $3,179,825 $1,287 $569,777,670 $181,380,020 16 Mel Leong Treatment Plant
Upgradeshttps://www.walshgroup.com/ourexperience/water/wastewatertreatmentplants/melleongtreatmentpla ntupgrades.html and https://pmaconsultants.com/projects/mel-leong-industrial-waste-treatment-plant/. 1140

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(b) QuanAfied and moneAzed Project benefits includes those that can be quanAfied and expressed as a moneAzed benefit per acre-foot.

A significant financial benefit for the City with this Project is the reduction of costs associated with purchasing imported water. The current cost of imported water from the Sacramento-San Joaquin Delta is $399 per AF. Including the cost for pumping ($432/AF) and maintenance ($300/AF), the total cost per AF is $1,131. If the Project is not constructed, the City will need to purchase approximately 2,060 AFY of imported water per year (Atwell full buildout). Therefore, this reduction in imported water purchases would result in $1,131 AF * 2,060 AFY = $2,329,860 per year of savings.

In addition to imported water costs, this Project will also offset some of the costs associated with treating Chromium VI (Cr6). The City contracted Hazen Sawyer to conduct a Cr6 Treatment and Compliance Study, recommending an approach for the City to comply with this MCL.

According to this study17, it will cost the City $300-$600 AFY in operations and maintenance of treatment facilities to remove Cr6 in the City’s water supply. Since this Project will supply recycled water to non-potable water customers instead of groundwater, the City will save money for not having to treat the water delivered to its non-potable water customers. The total expected recycled water demand is 2,060 AFY. This Cr6 treatment avoidance would in turn save the City approximately $450 AF * 2,060 AFY = $927,000 per year.

Therefore, the total cost savings of the Project is $2,329,860 (imported water) + $927,000 (Cr6 treatment) = $3,256,860 per year. Assuming the life cycle of the Project to be 50 years, this will save the City a total of $460M in future cost and $112M in present cost over 50-year period (assuming an inflation rate of 3.75% and nominal discount rate of 5%). See Appendix C for details.

Cost savings are critically important in a severely disadvantaged community like Banning. In 2022, the City Council and rate payers supported and approved a significant rate increase to provide partial funding for the improvements of the WWTP and recycled water upgrades.

Unfortunately, the rate increase is not sufficient to fully fund the costs that escalate significantly each year. The rate increase is a financial burden to the City’s lower-income residents. However, they approved the higher rates, recognizing the City’s water challenges and showing the willingness of Banning customers to help pay for the reliability of valuable recycled water.
(c) A comparison of the Project’s quanAfied and moneAzed benefits and costs.

The main cost benefits of the Project are the imported water and Cr6 costs offset by the new recycled water supplies described in the secAon above.

Compared to AlternaAves 1 and 2, the proposed Project (AlternaAve 3) offers the lowest unit cost per AF. With the anAcipated increase in imported water prices, the unit cost for AlternaAve 1 is only expected to rise further. While the City aims to implement indirect potable reuse for the North Basin site as outlined in AlternaAve 2, the associated costs make 17 http://banning.ca.us/DocumentCenter/View/4622/Chromium-6-Study-2016 1141

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it financially unfeasible at this Ame. AlternaAve 3 enables the City to comply with upcoming RWQCB limits and supply recycled water to irrigaAon customers currently relying on groundwater replenished by imported water, all within a more manageable budget and lower cost per AF.

Another cost benefit of the AlternaAve 3 is that it maximizes the value of the City’s investments in new recycled water infrastructure. The City has already constructed a backbone pipeline from the WWTP to Sun Lakes Golf Course, and is currently beginning the construcAon for storage faciliAes and booster staAons to send recycled water through the backbone pipeline to the Golf Course. AlternaAve 1 would not uAlize these faciliAes since no recycled water would be generated.

2. Describe any economic benefits of the Project that are difficult to quanAfy and/or moneAze.

QualitaHve benefits resulAng from the Project are significant and include environmental jusAce/equity, recreaAon, quality of life, climate change miAgaAon, and posiAve environmental outcomes. This is a regionally significant project that will have long term benefits and provides equity to underserved, overburdened and low-income residents.

Regional Significance and Environmental Justice: The Project will benefit the disadvantaged residents within and outside of the Banning City limits. The City of Cabazon and Morongo Band of Mission Indians (MBMI) both pump water from the Cabazon Groundwater Basin. The California Office of Environmental Health Hazard Assessment (OEHHA) identifies these jurisdictions as disadvantaged communities (red shaded areas shown in Figure 15)

18. One of the
main benefits of the Project is meeting RWQCB limits to discharge WWTP effluent to the percolation ponds over the Cabazon Basin. Upgrading the WWTP with MBR and RO will treat the WWTP effluent to meet the RWQCB TN requirements. Through these upgraded treatment processes, groundwater quality in the Cabazon Basin will improve. Enhanced water management will benefit the customers over the Cabazon Basin as they will receive higher quality water that can be delivered with reduced costs.

Rate Stability: The Project will help stabilize water rates for the City of Banning by utilizing recycled water for non-potable purposes, reducing the strain on existing potable groundwater supplies. This decreases the need for costly infrastructure, such as new production wells and Cr6 treatment facilities, which could otherwise raise water rates. Recycled water is also less expensive per acre-foot than imported water, lowering overall operating costs. These savings, over time, will help keep water rates more predictable. Additionally, the Project enhances longterm water security, providing a reliable local supply that can buffer the City from droughts or shortages that might lead to significant rate increases.

Greenhouse Gas Removal: The Project will reduce imported water purchases by 2,060 AFY. As further described in Evaluation Criterion 4, this will enable the City to reduce their energy consumption of transporting imported water over long distances, decreasing total emissions per year by 565.47 MTCO2e. Recycled water will help the City promote local water sustainability, contributing to climate change mirigation efforts. 18 https://oehha.ca.gov/calenviroscreen/sb535
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Superior Nitrate Management:

Since treatment systems at the
exisAng WWTP do not effecAvely
remove nitrate from
wastewater, this Project
significantly improves nitrate
management by reducing the
amount of nitrate that
percolates into the
groundwater. This helps the City
meet regulatory requirements,
while also miAgaAng the rising
nitrate levels observed in some
wells in the region.

Cr6 Removal: The Project’s RO treatment system for wastewater effluent will effectively remove Cr6. This provides significant value by recharging groundwater supplies with cleaner water that contains reduced levels of Cr6. Case studies show that for large-scale municipal systems, the total cost to reduce Cr6 levels in drinking water is substantial. For example, Glendale, California, has spent approximately $9 million on research and implementation of Cr6 removal technologies that included installation, operation, and maintenance19. With the project, Banning is making a proactive advancement toward addressing Cr6.

Sustaining Urban Green Spaces: This Project is critically important because it sustains important green spaces that are highly beneficial to urban/developed areas. The Project will supply irrigation water to more than 508 acres of open space and landscape areas (see Table 19). As more and more residents in the drought stricken Southern California area remove lawns and landscaping in their own yards, these public green areas become even more critical to the community. Recycled water users are not subject to restrictions during periods of droughts.

Urban green spaces provide a wide range of benefits, including:

1. Environmental:
• Air Quality Improvement: Trees and plants absorb pollutants and produce oxygen, improving air quality.
• Temperature Regulation: Green spaces help mitigate the urban heat island effect by providing shade and cooling the air through evapotranspiration. • Water Management: Green areas can reduce runoff and improve water quality by filtering rainwater.

2. Health:
• Physical Activity: Parks and trails encourage physical activities like walking, jogging, and cycling, promoting overall health.
19 Hexavalent Chromium Removal: Research Project Report to the California Department of Public Health (clu-in.org) Figure 15. OEHHA Disadvantaged Communities Mapping Tool 1143

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• Mental Well-being: Access to green spaces has been linked to reduced stress, improved mood, and better mental health. These spaces provide venues for socializing, which can enhance community cohesion and reduce feelings of isolation.

3. Economic:
• Property Values: Proximity to green spaces is known to increase property values. • Tourism and Recreation: Parks and recreational areas can attract visitors, boosting local economies.

4. Biodiversity:
• Habitat for Wildlife: Urban green spaces provide habitats for various species, supporting biodiversity within cities.

5. Aesthetic and Cultural Value:
• Beauty and Serenity: Green spaces enhance the visual appeal of urban areas and provide serene environments for relaxation.
• Cultural and Recreational Activities: Green spaces often host cultural events, sports, and recreational activities, enriching community life.

Table 19. Urban Green Acreage Sustained with Reclaimed Water Evaluation Criterion 4—Presidential and Department of the Interior Priorities (15 Points) Points will be awarded based on the extent the project will reduce climate pollution; increase resilience to the impacts of climate change; protect public health; and conserve our lands, waters, oceans, and biodiversity.

The Project will enhance the City’s resilience to climate change impacts and conserve water by establishing a local, drought-proof supply of recycled water. This will enable the conversion of non-potable groundwater wells to potable water use, thereby serving additional needs, and reducing the need for imported water, which can be redirected to other cities in need. Reliance on groundwater recharged by imported water leaves the City vulnerable to threats such as rising temperatures, reduced rainfall, diminished surface water supply, and wildfires (see Table Site Acres
Sun Lakes Golf CourseTwo 18-hole courses with turf, shrubs, shade trees, and ponds. 250
Atwell developmentA master-planned residential community with open spaces, parks, greenways and trails. 210
Dysart ParkOpen green spaces, mature trees, walking trails, wildlife habitat, playground and recreation areas, rodeo, music, and community festivals. 20 Banning High SchoolSports fields (turf), landscaped areas with trees, shrubs and outdoor gathering spaces for students, staff, and visitors.
23 Lion’s ParkBaseball/softball diamonds, walking path, soccer fields, children’s playing and picnic areas. City has plans to expand Lion’s Park with 7.5 acres of soccer fields. 5 Total Acreage Preserved & Sustained 508
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20). In contrast, the Project’s recycled water, sourced from the City’s wastewater, remains available even when groundwater and surface water sources are limited due to these factors, as wastewater will always remain a constant supply of water.

This Project will also improve overall public health by providing high quality water to the Cabazon Groundwater Basin. The new treated water from the WWTP will have higher water quality than is currently discharged to the basin. This will enhance the overall groundwater basin quality which will benefit the general health of all end users that pump water from this basin.

Table 20. Climate Change Impact Mitigation
Climate Change Impact Project Mitigation
Temperature- Earth’s average surface
temperature has increased by 2
degrees with the most warming
occurring in the most recent 40 years.

The Project sustains urban green spaces that are
proven to lessen urban heat island effects with
shade trees, permeable surfaces, and
evapotranspiration which helps cool the air by
converting liquid water into vapor, which absorbs
heat.

Rainfall- Climatologists predict a 10-
20% reduction in rainfall in Southern
California in the coming decades.

Recycled water is not impacted by declining
precipitation and provides a reliable source when
wells run dry.

Flooding- extreme weather events like
the atmospheric river that flooded
Banning in 2020 are expected to
increase in frequency.

Permeable surfaces in urban green spaces that
capture runoff in developed areas are critically
important to mitigate flooding. The Project
ensures the long-term preservation of valuable
park and open spaces.

Wildfires- the number of large wildfires
(more than 1,000 acres burned) has
more than doubled since 1970s.

Recycled water provides another source for
fighting fires. Post fire, it can aid in restoration
with new vegetation.

Additionally, since the Project will reduce the delivery of imported water from the Bay Delta, this will also support the fish and other wildlife within the hydrologic system of the Bay Delta. It will also enhance ecological resilience to climate change by reducing greenhouse gas emissions associated with the transportation and treatment of imported water supplies, as further described in the section below.

Combating the Climate Crises: E.O. 14008: project will address the impacts of climate change and help combat the climate crisis.

The City of Banning is doing its part to tackle the climate crisis at home by implementing a Project that reduces greenhouse gas emissions. In order to quantify the benefits of recycled water with the reduction on imported water demand, the City relied on data provided by the SGPWA and Department of Water Resources (DWR) for the energy and emissions associated with importing one acre foot of water. Using a 5-year average of SWP data from 2019-2023 to average year-to-year variability and account for the long-term trend toward lower emissions 1145

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factors, DWR calculated a factor for Greenhouse gasses (GHG)/megawatt-hours (MWh) measured by Metric Tons of Carbon Dioxide equivalents. Based on these inputs, 0.0602 MtCO2e of pollution is generated for every MWh. Multiplying this factor by the SGPWPA’s kWh/AF factor from the “State Water Project Energy Intensity of Water Supplies” provides the GHG/AF. For the San Gorgonio Pass, this factor is as follows:
4559kWh/AF * 0.0602 MtCO2e/MWh* 1 MWh/1000 KWh= 0.2745 MtCO2e (GHG)/AF Multiplying this amount by the anticipated imported water purchases of 2,060 AFY, this equals a total of 565.47 MTCO2e of greenhouse gases. Since the City will reduce their imported purchases by 2,060 AFY through this Project, the City will thereby decrease emissions by 565.47 MTCO2e. The Project’s energy savings reduces GHGs by 565,470 kilograms (kg) or approximately 1,246,647 pounds (lbs) of CO₂e.

Does the proposed project contribute to climate change resiliency in other ways not described above? An additional significant benefit that
has not been discussed previously is
the mitigation of hydrophobic soil
caused by frequent cycles of drought
and extreme heat. All the irrigation
sites show some signs of “drought
damage,” brown patches in turf, and
dead and dying trees and shrubs.

Aeriel photos of Lions Park show
brown patches that are evidence of
hydrophobic soil (see Figure 16).

Drought conditions and heatwaves in
Southern California Drought can
significantly contribute to the
development of hydrophobic soil
through several mechanisms:

Soil Drying: During prolonged
droughts, soil becomes extremely dry and causes organic compounds in the soil, such as plant oils and waxes, to coat soil particles, creating a water-repellent layer. Droughts also diminish microbial activity that plays a role in increasing the hydrophobic organic compounds.

Microbial Activity Reduction: Drought conditions reduce soil moisture, which in turn diminishes microbial activity. Microbes play a crucial role in breaking down organic matter.

When their activity decreases, the accumulation of hydrophobic organic compounds increases¹.

Increased Soil Temperature: Higher soil temperatures exacerbate the breakdown of organic matter into hydrophobic substances. These substances then coat soil particles, making them repel water.

Soil Compaction: Lack of moisture leads to soil compaction, reducing pore spaces and making it harder for water to infiltrate. This compaction can further enhance the hydrophobic properties of the soil.

Figure 16. Lions Park shows signs of climate-related
soil stress (brown patches)
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Vegetation Loss: As parched vegetation begins to die off, they stop producing organic matter inputs into the soil. This leads to a decrease in soil structure and an increase in hydrophobic conditions.

These factors combined make it difficult for water to penetrate the soil, leading to runoff and erosion when rain finally does occur. This cycle can perpetuate the hydrophobic condition of the soil, making it a persistent problem. However, recycled water irrigation mitigates this climate induced hydrophobic soil problem20. The high nutrient content of recycled water is a natural solution to revitalize hydrophobic soil. Recycled water often contains essential nutrients like nitrogen, phosphorus, and potassium. When applied to hydrophobic soil, these nutrients can help improve soil fertility and support plant growth⁴. The organic matter in recycled water can help improve the soil structure over time. This can reduce the hydrophobic properties of the soil, making it more receptive to water and nutrient absorption⁴. Recycled water can introduce beneficial microorganisms into the soil. These microbes can help break down organic matter, releasing nutrients that plants can absorb more easily⁴. Regular applications of recycled water help maintain consistent moisture levels in the soil, preventing it from becoming too dry and hydrophobic. By leveraging these benefits, the Project will enhance the overall health and productivity of hydrophobic soils at all the green space destinations, making them more fertile for turf and tree growth and more resilient to climate crisis stressors.

Points will be awarded based on how the project serves disadvantaged, underserved, or Tribal communities.

Based on the data from the U.S. Climate and Economic Justice Screening Tool shown in Figure 17, census tracts in Banning and surrounding areas meet the definition of overburdened and underserved disadvantaged communities (shown in light gray). Federally Recognized Tribes, including the adjacent Morongo Band of Mission Indians (MBMI) reservation also meets the definition (shown in darker gray). Producing a reliable local supply of water will support economic
development,
quality of life, and
cost of living
support which is
dependent on the
availability of
water
supplies. The City
of Banning service
area includes land
owned by the
MBMI, as shown in
Figure 17.
20 https://extension.sdstate.edu/impacts-drought-soil-water-forage-and-livestock-grazing-systems.

Figure 17. Climate and Economic Justice Screening Tool
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MBMI is one of the Cabazon Groundwater Basin users and will therefore benefit from the improved effluent quality at the City’s percolation ponds. With the new upgraded treatment process, nitrate and salt concentrations in the WWTP effluent will reduce from 27 mg/L to 4 mg/L and 410 mg/L to 207 mg/L, respectively. In addition, this Project will reduce the amount of imported water from the SWP delivered to the City by approximately 2,060 AFY. This will allow more potable water to be available to meet the obligations for Local Water and Supplemental Water deliveries to Tribes in the Region.

Points will be awarded based on the extent to which the Project will honor the Federal government’s commitments to Tribal Nations.

The Project will produce higher quality effluent that will discharge to the percolation ponds near the WWTP site, improving groundwater quality in the Cabazon Groundwater Basin for end users, including MBMI and the customers of the Cabazon Water District. Once Atwell development is built, an estimated 2,060 AFY of recycled water will be delivered to Banning customers and 410 AFY will be discharged to the percolation ponds over the Cabazon Basin. As more recycled water becomes available, higher water volumes will be discharged to the percolation ponds, improving water quality and the availability of water. This Project will also improve public health and safety for the MBMI by providing better quality water with lower nitrate and salt contents than is currently discharged over the Cabazon Basin.

Does the proposed project support ReclamaAon’s Tribal trust responsibiliAes or an acAvity with a Tribe? The Project does not support Reclamation’s Tribal trust responsibilities or a Reclamation activity with a Tribe.

Evaluation Criterion 5— Reclamation’s Obligations and Watershed Perspective (10 Points) Subcriterion No. 5a— Reclamation’s Legal and Contractual Water Supply Obligations (5 points) Explain how the Project relates to Reclamation’s mission and/or serves a Federal interest.

The Project supports the Bureau of Reclamation (USBR) mission to “manage, develop, and protect water and related resources in an environmentally and economically sound manner in the interest of the American public.” The Project reduces pressure on existing groundwater supplies and reduces imported water purchases, which includes “federal water” from Reclamation sources. This protects important water resources that can be used by Reclamation to help fulfill legal or contractual obligations. The Project also offers a drought-proof and dependable water source while benefiting the environment by decreasing reliance on imported water.

Subcriterion No. 5b— Watershed Perspective (5 points)

1. Explain how the project will relate to a regional or state water or an integrated resource management plan? The Project supports various local, regional and state integrated water resources management plans and planning efforts, including the California Water Plan and California Department of Water Resources Sustainable Groundwater Management Act. 2023 Draft California Water Plan (CWP) Update has seven objectives, recommendations, and actions for advancing the themes and strategies to make California more resilient to climate resilience and water equity for all Californians. The Project addresses the following objectives:
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• Support watershed resilience planning and implementation The City is planning ahead for potential climate change impacts and competition for resources by creating sustainable, drought-resilient water supplies that are independent of climate patterns as well as interregional jurisdictions. • Improve resilience of State, Federal, and regional “backbone” water infrastructure Banning is reducing the need for imported water in the drought-susceptible region and investing in existing infrastructure which supports smart growth in developed areas. • Advance equitable outcomes in water management
The Project relieves disadvantaged residents from paying higher costs for water. Rate hikes have a disproportionate burden on lower income households. The CA Department of Water Resources identifies the entire region as disadvantaged or severely disadvantaged. • Support and learn from Tribal water and resource management practice The Project embodies Native American values and a deep respect for water resources and reciprocity, giving back to nature. It provides direct water quality benefits to the Cabazon Groundwater Basin and the region’s tribal residents who depend on it.

The California State Legislature passed the Sustainable Groundwater Management Act (SGMA) in 2014 by establishing new requirements for groundwater management in medium and high priority groundwater basins. The Project supports the SGMA by providing valuable groundwater recharge, increasing water supply resilience, mitigating the impacts of over-drafted groundwater supplies, and reducing ground water dependence. See Sections 8.31, 8.32, and

8.33 on pages 43 and 44 in Appendix B.

2. Explain how the project will meet water supply needs of a large geographic area, region, or watershed.

The San Gorgonio IRWM Region was formed in 2016 and includes the City of Banning, Banning Heights Mutual Water Company, Cabazon Water District, High Valleys Water District, Riverside County Flood Control and Water Conservation District, Morongo Tribal Lands, and the San Gorgonio Pass Water Agency; collectively known as the San Gorgonio IRWM Regional Water Management Group (RWMG) (see Figure 18).

Figure 18. City of Banning San Gorgonio Pass Water Agency Service Area 1149

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The RWMG embarked on the development of its 2018 IRWM Plan to not only meet the requirements for participation in the statewide IRWM Program, but to also articulate the needs, goals, objectives, strategies and projects that are unique to the San Gorgonio Region.

The 2018 IRWM Plan, which took input from several stakeholder meetings, was supported by three separate yet integrated technical studies: the Water Supply Reliability Study, the San Gorgonio Regional Recycled Water Study, and the San Gorgonio Integrated Watershed and Groundwater Model Technical Memorandum.

To effectively manage the San Gorgonio Region’s water resources, the San Gorgonio IRWM Plan identified ten (10) goals. The Project directly supports the following goals:

Objective #1: Increase Regional Supply Availability and Reliability (see Table 21) The Project directly addresses these objectives and performance measures by implementing regionally significant recycled water initiatives, supporting affordable agreements to enhance reliability of importable water, maximizing local groundwater recharge and storage.

Table 21. Objectives and Performance Measures for Goal #1 IRWM Plan Objectives Performance Measure
1A: Implement regional recycled water projects
within the Region and support local recycled
water projects.

Number of recycled water projects implemented
and or AFY of recycled water recharged or
delivered within the region as reported in UWMP
or other project documents.
1B: Support affordable investments and
agreements between local and external agencies
to enhance the reliability of imported water
through the Region.

Number of implemented transfers and
agreements planned and/or AFY water delivered
to water providers with the Region as reported in
UWMPs.
1C: Maximize the use of groundwater supplies,
including local storage of imported water.

Number of implemented projects and AFY of
additional groundwater recharge as reported in
UWMPs.

Objective #4: Decrease Impacts to Groundwater Quality
While this IRWM Plan goal focuses specifically on the removal of septic systems, its overarching goal is the reduction of nitrates, which the Project will accomplish.

Objective #8: Support Disadvantaged Communities (DACs) and Maintain Water Affordability The Project enhances the reliability of the City’s water supply by developing a drought-resistant source of recycled water to supplement the City’s current water supply to severely disadvantaged, disadvantaged, and tribal users.

Table 22. Objectives and Performance Measures for Objective #8 IRWM Plan Objectives Performance Measure
8: Seek funding opportunities to ensure all
communities have access to a reliable water
supply and adequate wastewater treatment.

Number of grant proposals submitted by and on
behalf of DACs and/or amount of funds received
to benefit DACS within the Region.
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Objective #10: Adaptation and Mitigation to Climate Change The Project will offset the potable water demands currently met with imported water deliveries from the SWP.

3. Will the Project promote collaboraAve partnerships with mulAple stakeholders represenAng diverse interests? This Project will discharge high-quality effluent into a major groundwater basin—the Cabazon Groundwater Basin—thereby enhancing water quality for all agencies within the regional groups that draw from this basin.

By upgrading the WWTP with MBR and RO treatment, the effluent that percolates into the Cabazon Groundwater Basin will have significantly reduced nitrates and salts. Therefore, users downgradient that pump water from this basin, including the City of Cabazon and MBMI, will have higher quality drinking water than is currently in the Basin.

To further promote collaboration, the City will also host quarterly update meetings with the stakeholders (recycled water customers), neighboring groundwater jurisdictions, and tribal leaders.

4. Will the project include public outreach and opportuniAes for the public to learn about the project? Explain.

The City will conduct the following outreach activities to increase publicity for the proposed Project:

1. Community workshops
• Interactive workshops where residents can learn about the Project, ask questions, and provide input. This can include presentations, Q&A sessions, and small group discussions.

2. Public meetings
• Regularly scheduled meetings for the community to be updated on the Project’s progress and all to garner public comment.

3. General education
• Distribute brochures, fact sheets, and FAQs that explain the benefits and safety of recycled water.

4. Website page
• Dedicate a page on the City’s website with detailed information about the Project, educational resources, and opportunities for public engagement.

5. Updates via social media (i.e., Facebook and Instagram) • Share Project updates, educational content, and respond to public inquiries.

END OF 40 PAGE TECHNICAL REPORT

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5. PROJECT BUDGET

5.1 Funding Plan
The total cost of the Project is estimated at $64,778,300. Under this NOFO, the City is therefore requesting $16,194,575, which would be 25% of the Project cost. Remaining costs will be covered by non-federal funding sources to provide the minimum 75% funding match. Table 23 includes more detail regarding the funding contributions by source for the Project.

Table 23. Funding Contributions by Source
Funding Source Amount
Non-Federal Entities
City of Banning $48,583,726.50
Federal Entities
Requested Reclamation Funding $16,194,575.50
Total Cost $64,778,302.00
The City’s cost share will be provided by the City’s Water OperaAons and Wastewater OperaAons Funds. There is a current fund balance in the Water OperaAons Fund of $17.5M and a fund balance in the Wastewater OperaAons Fund of $3.7M. In addiAon to operaAng and capital revenues related to rates, the City has conAnued to charge a monthly TerAary Surcharge of $2.72/month per account to fund capital improvements at the wastewater treatment plant. The Wastewater TerAary Fund has a fund balance of $7.7M of which $7M would be allocated to the Proposed Project. AddiAonally, the City has the capability to fund projects through either cash payment or debt issuance. See SecAon 9.4, pages 49-51, in Appendix B for more details on the City’s Project Funding Plan.

City staff Ame will not be documented as a Project cost. Invoices will be provided to ReclamaAon following grant award, or at ReclamaAon’s request. The City anAcipates that the Project’s costs will be incurred by September 30, 2027. All Project costs are presented in Table 24.

The construction cost of $51,760,500 listed in Table 24 is based on the Opinion of the Construction Cost (OPCC) estimate developed using the American Associations of Cost Engineers guidelines and recommendations. The OPCC was completed by the City’s Owner’s Engineer consultant following the AACE Class 4 cost estimating methodology. The estimate was developed based on the industry standards, adjusted to the anticipated Project’s complexity, and market conditions and cost escalation at the time of the estimate. This construction cost does not include any additional soft costs, such as CEQA and Permitting, Planning and Design, Construction Administration, and overall Project contingencies. Section 5 of this application covers all of these additional costs and provides the estimating methodology. 1152

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The variance between the total construcAon cost of $51,760,500 listed in Table 24 and the total construcAon cost of $70,490,400 that was developed in the 2023 Feasibility Study (Appendix B, SecAon 4.3, page 31) is due to the value engineering and scope opAmizaAon performed by the City and City’s Owner’s Engineer consultant.

5.2 Budget Narrative
A detailed explanation of the costs incurred under each budget category is included in Table 24.

Salaries and wages
The City will account for its staff time for this Project as part of its normal operating costs and will not be tracking or submitting staff time for match or reimbursement. As such, these costs are not included in the total Project cost. Contractor salaries and wages are included in the contractor costs, under the Construction section of the proposed budget.

Key Personnel for the Project will include staff from the City of Banning, along with project managers for each of the consultants and contractors hired to support the Project. The Program Manager for the Project is Arturo Vela, Director of Public Works for the City of Banning.

Compliance with Reporting Requirements will be completed through combined efforts of the Program Manager, Administrator, and Finance Specialist, and is expected to require a combined total of 30 hours per submittal. Each submittal is anticipated to include a Financial Report and an Interim Program Performance Report. Submittals are expected to be provided quarterly. The Final Program Performance Report is expected to require an additional 60 hours for the final Project and evaluation.
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Table 24. Project’s Overall Costs
Fringe benefits
Like salaries and wages, fringe benefits for employees as they relate to the Project will be accounted for by the City through normal operating costs. As a result, incurred fringe benefit costs related to the Project will not be sourced from grant funds. Contractor fringe benefits are incorporated into contractor billing rates under the Construction section of the proposed budget.

Travel
Travel costs related to the Project will not be sourced from grant funds. All City staff travel costs incurred over the duration of the Project will be absorbed by the City as normal operating costs.

Contractor travel costs are incorporated into contractor costs under the Construction section of 1154

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the proposed budget. All reimbursable travel costs will be reimbursed at a rate consisted with federal allowance.

Construction contractors are anticipated to participate in weekly or bi-weekly in-person meetings with City of Banning Staff, including the Project Manager and Project Engineer.

Construction contractors are anticipated to be local, and no mileage reimbursement, flights, car rentals, hotels, or per diem anticipated.

Travel expenses are incorporated into consultants’ fee estimates, and any travel costs billed to the grant will be consistent with applicable state or federal rates.

Equipment
Equipment costs for the Project are incorporated into the Contractor costs under the Construction section of the proposed budget.

Supplies and Materials
Supplies and materials costs for the Project are incorporated into the Contractor costs under the Construction section of the proposed budget.

Construction
As indicated in the Budget Table (Table 24), the Project will include support from consultants and contractors. The Project’s design consultant will be procured in Winter of 2024.

Construction-related soft costs (i.e., Design and Construction Administration) have been confirmed by percentage methodology guidelines outlined in the 2023 California Multi-Agency CIP Benchmarking Study shown in Table 25.

Table 25. 2023 California Multi-Agency Benchmarking Study, in 2023 dollars21 21 California Multi-Agency CIP Benchmarking Study | Bureau of Engineering (lacity.gov) Type Design Construction
Management
Total
Project
Delivery
Median
Total
Construction
Cost
Number
of
Projects
Municipal Facilities 21% 14% 35% 1.54 77
Parks 28% 21% 50% 1.19 52
Pipe Systems 17% 20% 37% 1.63 205
Streets 27% 27% 54% 1.71 155
Wastewater & Water Facilities 25% 24% 50% 1.98 58
ALL TYPES 23% 22% 44% 1.64 548
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Task 1: CEQA and Permitting – It is assumed that the Project will require preparation of CEQA (CEQA Plus) documentation by developing an Initial Study/Mitigated Negative Declaration (IS/MND), based on the Project footprint of less than 20 acres. At minimum, three technical studies are to be conducted to support the IS/MND:

1. Biological Resources report that allows for federal consultation with U.S. Fish & Wildlife under the Endangered Species Act

2. Cultural Resources report that allows for federal consultation with the State Historical Preservation Office under the National Historic Preservation Act

3. AB 52: Tribal Consultation

4. Air Quality Modeling report that allows for federal approvals under the Clean Air Act.

Compilation of a complete IS/MND that addresses the above-referenced federal laws and all other federal cross-cutters includes preparation of a public review draft, circulation and noticing, and preparation of a final IS/MND. Total CEQA costs are estimated at $180,000.

Additional costs anticipated to be incurred by the City over the duration of this Project include permitting fees totaling an estimated $120,000.

Task 2: Design – Design level of effort is estimated at 7% of the construction cost, confirmed by the percentage methodology guidelines outlined in the 2023 California Multi-Agency CIP Benchmarking Study. The activities for the Project are shown in Table 24.

Task 3: Construction – Construction costs were estimated based on the American Association of Cost Engineers Class 4 guidelines utilizing various factors, such as market conditions, cost escalation, and construction level of difficulties. The estimate will be validated after the receipt of the bid results during the contractors’ procurement process. The estimated construction cost is $51,760,500.

Task 4: Construction Administration

1. Construction Administration – Estimated at 6% of the construction cost, confirmed by the percentage methodology guidelines outlined in the 2023 California Multi-Agency CIP Benchmarking Study.

2. Environmental Monitoring and Support during Construction – Estimated at $100,000.

Environmental and Regulatory Compliance Costs
Costs incurred under this budget category have already been accounted for under Permitting and Construction.

Other Expenses
Additional costs incurred by the City include a contingency of 10% of the overall Project cost. 1156

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Indirect costs
The City does not anticipate that the Project will require any indirect costs that will not otherwise be recovered or accounted for under other proposed budget categories.

6. ENVIRONMENTAL AND CULTURAL RESOURCES COMPLIANCE
The City does not anticipate that the Project will have significant impacts on endangered or threatened species, public health or safety, hydrology and water quality, regulated waters of the United States, or cultural resources. The City also does not anticipate that the Project will have significant environmental effects as defined by State and Federal environmental laws. As such, the City will prepare a Negative Declaration to obtain CEQA coverage and expects that USBR will adopt a Finding of No Significant Impacts (FONSI) to obtain NEPA coverage for the Project. The City completed an Initial Study-Mitigated Negative Declaration (IS-MND) in October 2007. The 2007 IS-MND covered significant elements of the current proposed Project. The findings of the 2007 IS-MND were either “Less Than Significant Impact” or “No Impact”. The 2007 IS-MND provided a basis for the following sections, but the City will conduct an IS-MND for the new proposed Project.
• Will the proposed project impact the surrounding environment (e.g., soil [dust], air, water [quality and quanHty], animal habitat)? Please briefly describe all earth-disturbing work and any work that will affect the air, water, or animal habitat in the project area. Please also explain the impacts of such work on the surrounding environment and any steps that could be taken to minimize the impacts.

Air Quality:

Around 17 acres of excavation activities will be required for construction of the Project.

An air quality analysis will be completed as part of the CEQA analysis. Project construction will comply with local air quality requirements. Typical dust control measures, such as watering and reducing off-road vehicle speeds, will be employed. Project operations will be evaluated for consistency with the State greenhouse gas reduction targets found in AB 32 and SB 32.

Emissions from operation of the proposed facilities are not expected to exceed applicable significant thresholds.

Biological Resources:

Construction of the Project facilities is not expected to impact biological resources. Biological resources will be surveyed prior to design, and sensitive species and their habitats will be avoided in the Project design. The Project is not expected to impact wetlands or waters of the U.S. as regulated by U.S. Army Corps of Engineers, RWQCB, and California Department of Fish and Wildlife. The Project will comply with the adopted Habitat Conservation Plans and Natural Community Conservation Plans.

The Project is not anticipated to affect biological resources, as all O&M activities will be constrained to the WWTP site. Operations will be sustainable and will have no impact on riparian and aquatic habitats.

Hydrological Impacts:
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Hydrologic impacts, including erosion and siltation during construction of the proposed facilities would be minimized through compliance with existing regulations, including enrollment in an NPDES construction general permit, completion of a storm water pollution prevention plan, and implementation of required BMPs.

The City will characterize the RO brine discharge to evaporation beds to verify the quality of the solids before final disposal.

The proposed Project is not within the 100-year floodplain. During the design, this conclusion will be confirmed.

Noise:

Construction noise is considered a nuisance and is regulated by the City’s Noise Ordinance. The majority of construction activities for the Project will be in the vicinity of the WWTP site which is located in an isolated part of the City. Construction equipment will be fitted with approved mufflers and other measures may be utilized to comply with the existing regulations.

The City will ensure all Project components comply with mitigation measures identified to further reduce impacts. It is expected that impacts to hydrology and water quality as well as animal habitats would be less than significant with the incorporation of mitigation measures, while air quality impacts would be significant and unavoidable. As described above, a projectlevel air quality analysis will be conducted to determine air quality impacts resulting from the Project. Mitigation measures will be incorporated as necessary to reduce impacts to the extent feasible.
• Are you aware of any species listed or proposed to be listed as a Federal threatened or endangered species, or designated criHcal habitat in the project area? If so, would they be affected by any acHviHes associated with the proposed project? The City is currently not aware of any species listed or proposed to be listed as a Federal threatened or endangered species nor any designated critical habitats in the Project area. The Project will comply with the adopted Habitat Conservation Plans and Natural Community Conservation Plans. Operation of the Project is not anticipated to affect biological resources, as all O&M activities will be constrained to the WWTP site. The City will carry out all mitigation measures identified and required by the CEQA analysis to minimize impacts to special-status species and critical habitats. At the project-level, a biological resources assessment will be conducted to identify Project activities that may further adversely affect special-status species.

Such findings will be incorporated into the analysis to identify actions that minimize any additional impacts to special-status species or designated critical habitats to the extent feasible. • Are there wetlands or other surface waters inside the project boundaries that potenHally fall under CWA jurisdicHon as “Waters of the United States”? If so, please describe and esHmate any impacts the proposed project may have.

There are no wetlands or surface water inside the Project boundaries that potentially fall under the CWA jurisdiction as “Waters of the United States”, and therefore, no wetlands or surface water will be impacted by the Project. All Project components will comply with applicable permitting requirements if impacts to jurisdictional waters are to occur. 1158

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• When was the water delivery system constructed?
The iniAal water system was developed in the early 1900’s and has conAnued unAl today. • Will the proposed project result in any modificaHon of or effects to, individual features of an irrigaHon system (e.g., headgates, canals, or flumes)? If so, state when those features were constructed and describe the nature and Hming of any extensive alteraHons or modificaHons to those features completed previously.

The Project will not result in any modification to the individual features of an irrigation system, e.g., headgates, canals, or flumes.
• Are any buildings, structures, or features in the irrigaHon district listed or eligible for lisHng on the NaHonal Register of Historic Places? A cultural resources specialist at your local ReclamaHon office or the State Historic PreservaHon Office can assist in answering this quesHon.

No buildings, structures, or features located within the Project area are listed or eligible for listing on the National Register of Historic Places. The City does not anticipate that the Project will have any adverse effects on historic properties.
• Are there any known archeological sites in the proposed project area? There are currently no known archeological sites within the Project area. However, because the Project includes excavation, there is the potential that the Project may impact archaeological resources. A Phase 1 Archeological Resources Assessment will be conducted at the project-level. A Phase 2 Archeological Resources Assessment will be conducted if resources are identified during the Phase 1 assessment. Based on findings from the Phase 1 and 2 assessments, mitigation measures will be identified in the CEQA/NEPA analysis to reduce impacts to archeological resources.

Cultural resources will be surveyed prior to design and the Project will be designed to avoid any potential identified cultural sites. Onsite construction monitoring mitigation may be necessary to ensure that discovery of any previously unidentified archeological resources is handled appropriately. The City will comply with California Assembly Bill 52 regarding formal consultation with Native American tribes about the proposed Project. Archeological sensitivity training for construction personnel and the presence of a qualified archeological monitor to supervise all excavations activities will be included as a mitigation measure. The archaeologist will have the authority to temporarily halt or redirect ground-disturbing activity, if necessary. • Will the proposed project have a disproporHonately high and adverse effect on low income or minority populaHons?
The Project is not anticipated to have a disproportionately high or adverse effect on low income or minority populations. The Project will directly increase the amount of available recycled water to the City, and therefore provide benefits to all customers within the service area. The entire City of Banning is categorized as a severely disadvantaged or disadvantaged community. • Will the proposed project limit access to, and ceremonial use of, Indian sacred sites or result in other impacts on Tribal lands?
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The City does not anticipate any impacts to sacred sites or tribal lands related to the Project.

However, to comply with California Assembly Bill 52 regarding formal consultation with Native American tribes about the proposed Project, the City will implement additional mitigation in the CEQA/NEPA analysis to minimize potential impacts to sacred sites or tribal lands, as needed.
• Will the proposed project contribute to the introducHon, conHnued existence, or spread of noxious weeds or non-naHve invasive species known to occur in the area? It is not anticipated that Project will contribute to the introduction, continued existence, or spread of noxious weeds or non-native invasive species. The Project will take place primarily in disturbed, developed, and ornamental plant-covered areas and will not disturb native vegetated communities. Therefore, it is unlikely that the Project will cause the introduction of non-native invasive species within and surrounding the pPoject area.

7. REQUIRED PERMITS OR APPROVALS
Permits and approvals required for the completion of the Project are listed below. Although this list includes all permits known to be required for this Project, additional permit requirements may be identified as the design progress. All required permits and approvals will be obtained prior to beginning construction.

1. State Water Resources Control Board Division of Drinking Water (DDW) Title 22 Engineering Permit

2. Regional Water Quality Control Board – Colorado River Basin General Permit (combining Non-Discharge National Pollutant Discharge Elimination System [NPDES], Waste Discharge Requirement [WDR], and Waste Recharge Requirements [WRR])

3. RWQCB Notice of Intent (NOI)

4. RWQCB Notice of Applicability (NOA)

5. DDW – Recycled Water Customer Conversion Approval

6. Air Quality Management District (AQMD)

7. CEQA (IS-MND)
A Title 22 Engineering Report is required to be submitted for approval by DDW to meet water quality standards for recycled water. After the design documents are finalized, the City will submit the necessary reports, analyses, and applications to obtain required permits from the RWQCB. As mentioned in Section 6, the City will prepare a Negative Declaration to obtain CEQA coverage for the Project in parallel with Project design.

8. OVERLAP OR DUPLICATION OF EFFORT STATEMENT
There is no overlap between the Project and any other active or anticipated proposals or projects in terms of activities, costs, or commitment of key personnel. The proposal submitted for consideration under this program does not in any way duplicate any proposal or project that has been or will be submitted for funding consideration to any other potential funding source. 1160

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9. CONFLICT OF INTEREST DISCLOSURE STATEMENT
There are no actual or potential conflicts of interest that exist at the time of submission.

10. UNIFORM AUDIT REPORTING STATEMENT
The City of Banning will submit a Single Audit report for FY 2024, prior to the grant award.

11. SF-LLL: DISCLOSURE OF LOBBYING ACTIVITIES
This section is not applicable to the City of Banning’s Project, as the City has not made or agreed to make payments to any lobbying entity for influencing or attempting to influence an officer or employee of any agency, a Member of Congress, an officer or employee of Congress, or an employee of a Member of Congress in connection with a covered Federal action.

12. LETTERS OF SUPPORT
The City has received letters of support for the Project from the following organizations:
• Rosilicie Ochoa Bogh, California State Senator
• Laphonza Butler, United States Senator
• Raul Ruiz, United States House Representative
• Yxstian Gutierrez, District 5 Commissioner of the County of Riverside • Paula Rasmussen, Executive Officer, Colorado River Basin RWQCB Copies of these letters are provided as Appendix D of this application.

13. OFFICIAL RESOLUTION
A City Council resolution (see Appendix E for draft) in support of the Project is being planned for adoption in December 2024.

Per Section D.2.2.11 of the NOFO, the official resolution may be submitted prior to the award date, if an applicant is selected, after the application deadline.

14. LETTERS OF FUNDING COMMITMENT
The third-party cost share currently is not anticipated for the Project.

15. REFERENCES
Carollo Engineers, Inc. 2018 Integrated Master Plan. March 2018.

City of Banning Water/Wastewater Utilities Department. Initial Study/Mitigated Negative Declaration. October 2007.

Stantec Consulting, Inc., et al. California Multi-Agency CIP Benchmarking Study. December 2023.

West Yost & Associates Engineering, Inc. and John Robinson Consulting, Inc. 2020 Urban Water Management. June 2021.

Woodward & Curran, Inc. San Gorgonio Region Recycled Water Study. February 2018. 1161

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Appendix A – Signed Executive Memorandum

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Appendix B – Feasibility Study (Appendices not included)

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City of Banning
Wastewater Treatment Plant
and Recycled Water Upgrades
Feasibility Study (Revision 1)
January 5, 2024
N2W Engineering, Inc. T 714.716.1711
3240 El Camino Real, Suite 150, Irvine, CA 92602 [email protected] 1165
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Prepared by: Iris Jimenez and Jamal Awad
Reviewed by: James Wang

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EXECUTIVE SUMMARY
The City of Banning (City) has prepared this feasibility study to support a grant application for WaterSMART: Title XVI WIIN Act Water Reclamation and Reuse Projects for Fiscal Years 2023 and 2024 per Funding Opportunity Announcement No. R23AS00464. This study evaluates the feasibility of upgrading the City’s Wastewater Treatment Plant (WWTP) to tertiary disinfected recycled water standards for non-potable reuse under the terms of the U.S. Bureau of Reclamation (USBR) Water Reclamation and Reuse (Title XVI) program. This study is structured to follow the Bureau of Reclamation Manual, Directives and Standards, “WTR 11-01.” The existing WWTP consists of preliminary treatment, primary treatment, secondary treatment, solids handling, disinfection (currently not in use), and evaporation/percolation ponds. The WWTP effluent is currently in compliance with discharge requirements, but it requires significant upgrades to comply with impending water quality discharge limits by the Regional Water Quality Control Board (RWQCB). In addition, the Trickling Filters, which perform secondary treatment, have reached their end of life. WWTP effluent discharges to percolation ponds that recharge into the Cabazon Groundwater Basin but is not entirely extracted by Banning - the percolated water flows to other water agencies located downgradient.

The proposed Wastewater Treatment Plant and Recycled Water Upgrades Project (Project) evaluated by this study consists of three phases: I) upgrading the existing WWTP to recycled water standards and building pipelines to connect the WWTP to customers currently using ground water from non-potable wells, II) building pipelines to connect the WWTP to the future recycled water customers, and III) building pipelines to connect the WWTP to a groundwater recharge basin upgradient of the Cabazon storage unit. Phase I will be implemented in the near term, and Phases II and III will be implemented in the long-term. Phases II and III are not included in this Feasibility Study for clarity. The City has only requested funding for Phase I in the WaterSMART funding application but will seek additional funding for Phases II and III in the future and will provide an updated Feasibility Study at that time.

Currently, there are no non-potable recycled water uses that have been implemented in the City.

By implementing both project components, non-potable reuse and indirect potable reuse, the supply and usage of locally sourced non-potable water supply will increase by an estimated 4,035 AFY (3.6 MGD) of recycled water.

The City relies upon purchasing water from the San Gorgonio Pass Water Agency (SGPWA) for groundwater recharge. The increased supply of local non-potable water supplies produced from this Project would decrease demands on the SGPWA, and on its supplier, the California State Water Project, thereby reducing diversions from natural watercourses in the Sacramento-San Joaquin Delta. The Project also provides non-quantifiable benefits including improving nonpotable water supply reliability and drought resiliency. 1167
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1. INTRODUCTION
Prelude
The proposed Wastewater Treatment Plant and Recycled Water Upgrades Project (Project) is the subject of this feasibility study, which supports a grant application for WaterSMART: Title XVI WIIN Act Water Reclamation and Reuse Projects for Fiscal Years 2023 and 2024 per Funding Opportunity Announcement No. R23AS00464. This study is structured to follow the Bureau of Reclamation Manual, Directives and Standards, “WTR11-01," which was intended for reclamation projects. The purpose is to evaluate Project feasibility under the terms of the U.S. Bureau of Reclamation (USBR) Water Reclamation and Reuse (Title XVI) program.

The Project evaluated by this study involves upgrading the existing Wastewater Treatment Plant (WWTP) at the City of Banning (City) to Title 22 standards for recycled water use.

At this time, effluent from the WWTP meets the effluent water quality discharge requirements.

However, the WWTP will not be able to meet the impending discharge limits proposed by the Colorado River Basin Regional Water Quality Control Boad (RWQCB). In addition, many treatment facilities at the plant have reached the end of their useful life. WWTP effluent is currently discharged to percolation ponds that recharge into the Cabazon Groundwater Basin but is not entirely extracted by Banning - the percolated water flows to other water agencies located downgradient.

By replacing existing equipment with new facilities that can treat the water to tertiary disinfected recycled water standards, the WWTP effluent can be used to meet current and future nonpotable water demands in the City. This allows the City to both meet the impending RWQCB requirements as well as benefit from their WWTP effluent. These benefits include reducing the City’s reliance on imported water and improving the reliability of groundwater for drinking water purposes. Since the City is considered a Disadvantaged Community, a reliable local supply of water will also support City growth and economic development, which are dependent on the availability of water supplies.

Non-Federal Project Sponsor
The City of Banning is serving as the non-federal project sponsor. The City was incorporated as a Charter City in 1913, pursuant to the California Constitution Article XI and the California Government Code and is governed by an elected five-member council. It is a full-service city, providing water and wastewater services through its Water and Wastewater Utilities Department, under the purview of the City Council.

Study Area and Project Map
The City of Banning is in the northwestern portion of Riverside County, approximately 25 miles east of downtown Riverside and approximately 30 miles west of the City of Palm Springs. The City 1168
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is bounded by the San Bernardino Mountains to the north; Cherry Valley to the northwest; the City of Beaumont to the west and southwest; unincorporated County area to the south; the San Jacinto Mountains to the southeast; and the Morongo Band of Mission Indians and unincorporated community of Cabazon to the east. The City’s total land area is 14,848 acres or

23.2 square miles. See Figure 1 on the following page for a map of the City boundaries.

The City’s water service area comprises 100 percent of the population residing within the City limits, and a small unincorporated area of Riverside County. The City's Water Service Area comprises about 16,908 acres or 26.4 square miles.

The City is a retail agency and within the San Gorgonio Pass Subbasin portion of the Coachella Valley Groundwater Basin. The City is a member of the San Gorgonio Pass Regional Water Alliance (Alliance). The Alliance was created to identify challenges in water supply and water quality in the region and to improve coordination and communication among local, state, and federal governments and water purveyors and other water resource stakeholders in the San Gorgonio Pass region.

Since 2015, the City has participated in the following two additional agreements:

1. San Gorgonio Integrated Regional Water Management Group, which includes: City of Banning, Banning Heights Mutual Water Company, Cabazon Water District, High Valleys Water District, Riverside County Flood Control and Water Conservation District (CFCWCD), and the San Gorgonio Pass Water Agency.

2. San Gorgonio Pass Subbasin Groundwater Sustainability Agency, which includes: the Desert Water Agency, Banning Heights Mutual Water District, Cabazon Water District, Mission Springs Water District, San Gorgonio Pass Water Agency and the City of Banning.

3. San Timoteo Groundwater Sustainability Agency, which includes: City of Banning, Beaumont-Cherry Valley Water District, City of Redlands, Yucaipa Valley Water District, San Gorgonio Pass Water Agency.

The City participates in the Beaumont Management Zone (BMZ) Maximum Benefits Program, which is under the oversight of the RWQCB and is intended to ensure the long-term sustainability of water quality in the BMZ. Yucaipa Valley Water District, Beaumont Cherry Valley Water District, and City of Beaumont also participate in the program.

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Figure 1. City of Banning Project Map (courtesy of 2018 Integrated Master Plan (2018 IMP)) 1170
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1.3.1 Land Use
The City includes a mixture of residential uses and equestrian estates, combined with more recently planned residential housing developments. The community focal point is an extended commercial downtown stretching along Ramsey Street. Ramsey Street largely parallels Interstate 10; consequently, one can find almost any type of restaurant, bank, or service station here - a wider variety than one would expect in a city of this size. Table 1 provides some basic statistics on current land use and economy for the County of Riverside and the City. Figure 2 on the following page shows the City’s known developments, which includes the agricultural, open space, and community areas.

Table 1. Current Land Use & Economic Statistics for Riverside County and City of Banning Land Item Riverside County Banning
Land Area (sq. miles) 7,206 sq. miles 23 sq. miles
Land Area (acres) 4,611,840 acres 14,720 acres
Agricultural Land 263,796 acres 1,200 acres
Developed Land 165,151 acres 428 acres
Population 2,470,546 31,125
Housing Units 857,148 10,991
Median Home Price $350,100 $234,900
Owner Occupancy Rate 66.3% 65.9%
Employed (16yrs +) 59.7% 44.5%
Median Household Income $67,005 $42,274
Percent in Poverty 11.3% 20.6%
Manufacturing $15.1 Billion $72.8 Million
Agriculture/Crops $3.9 Billion N/A
Retail & Wholesale Sales $43.8 Billion $248.7 Million
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Figure 2. City of Banning – Known Developments (courtesy of 2018 IMP) 1172
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1.3.2 Climate
The City is located within the San Gorgonio Pass, which is a transitional zone where coastal climates transition to desert, resulting in significantly differing landscape and geology. The climate can best be characterized by hot, dry summers and short, mild winters. The region receives an average annual rainfall of approximately 19.7 inches, most of which takes place between December and March. Evapotranspiration (ETo) in the area ranges from 7.88 inches in July to 1.94 inches in December.

As the State of California and the Riverside County region has undergone a several-year drought, rainfall has been much lower in the City. Recent ETo and rainfall for the City is listed in Table 2.

Table 2. Recent Climate Characteristics (2022 – 2023)
CIMIS Station 239 (Hemet)
(cimis.water.ca.gov)
Month Rainfall (in.) Eto (in.)
Mar (2022) 0.69 2.30
Apr (2022) 0.27 3.15
May (2022) 0.00 4.21
Jun (2022) 0.02 6.14
Jul (2022) 0.00 7.89
Aug (2022) 0.00 7.70
Sep (2022) 0.17 9.16
Oct (2022) 0.25 8.34
Nov (2022) 1.77 6.47
Dec (2022) 1.18 4.65
Jan (2023) 0.91 2.87
Feb (2023) 0.69 2.13
Totals 5.95 65.01

1.3.3 Population
According to the 2020 Census Data, the resident population of the City is 29,528, and estimated to be 30,273 as of July 1, 2021. Since the City's water service area comprises 100 percent of the population residing within the City limits, the total current resident population served by the City’s water system is approximately 31,125 persons, including those outside City limits. The City is currently experiencing a peak population, based on State of California Department of Finance estimates. Since the City is a commercial and government-services center for the region, daytime population increases demand for potable water beyond the City's resident population. 1173
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Reclaimed Water Area
There are no non-potable reclaimed water uses that have been implemented in Banning.

Currently, the City’s existing non-potable water system delivers water from a non-potable groundwater well, Well M7, to Sun Lakes Country Club for irrigation use. The City has begun constructing a 24-inch diameter pipeline to connect the existing non-potable water pipe to the WWTP. The backbone pipeline is expected to be completed, tested, and accepted by the end of 2023. Once reclaimed water becomes available from the upgraded WWTP, the WWTP will replace Well M7 to serve Sun Lakes Country Club and other irrigation customers as part of this Project. The existing non-potable water system and planned backbone pipeline are shown in Figure 3 below.

Figure 3. City of Banning Reclaimed Water Area (courtesy of 2018 IMP) 1174
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2. STATEMENT OF PROBLEM AND NEEDS
Introduction
This section reviews the City’s need for water reclamation, as well as short- and long-term recycled water demands and supplies. This section also includes discussions of sources of additional supplies and water quality concerns.

Need for Water Reclamation
With climate change bringing on more unpredictable and severe variations in weather which have recently been more frequent, and longer duration droughts in California and the entire Western United States, it is crucial for water agencies to engage in comprehensive planning to develop and implement sustainable sources of water. The effects of drought are clearly demonstrated with the Governor of California declaring a statewide State of Emergency due to drought. The Governor’s State of Emergency declaration is accompanied by a call for all state residents to cut down on water use by 15%.

The last severe drought to affect the State occurred only a few years ago between 2012-2017 with 2013-2014 having extraordinarily dry conditions. The current drought may even be on a more dire path as the 2020 water year was the third driest water year on record in the last 127 years. With climate change resulting in hotter, drier summers and reduced precipitation, severe and prolonged droughts are forecast to be a normal part of California’s future.

This water reclamation Project will generate sustainable supplies to the City’s water supply portfolio that will help Banning better prepare for future water supply challenges.

In addition to drought preparation, water reclamation will help reduce the City’s reliance on imported water. Currently, the City has access to imported water from the Sacramento-San Jaquin River Delta in Northern California through the San Gorgonio Pass Water Agency (SGPWA).

The Bay Delta water system provides Southern California agencies with over 1 million acre-feet of water annually. According to the City’s 2020 Urban Water Management Plan (2020 UWMP), the City purchased an average of 847 acre-feet per year (AFY) per year between 2010 – 2015, and an average of 752 AFY per year between 2015 – 2020 for groundwater recharge. By providing recycled non-potable water from the WWTP to irrigation customers, this will allow the City to rely less on imported water and depend on its local water supply to meet non-potable water demands.

Current Water Supplies

2.3.1 Water Sources and Supplies
The City currently uses potable water and non-potable water to meet the water needs of its service area. The City’s water is obtained entirely from groundwater through nineteen (19) potable groundwater wells, one (1) non-potable groundwater well, and three (3) co-owned wells 1175
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with the Beaumont-Cherry Valley Water District (BCVWD). The City also has access to imported water from the Sacramento-San Joaquin River Delta in Northern California through the SGWPA and surface water from the Whitewater River. Both imported and surface water are used to recharge the groundwater aquifers.

Imported Water Sources
The SGPWA is one of 29 agencies in the State that have a State Water Project (SWP) Water Supply Contract with the Department of Water Resources (DWR). These agencies receive an allocation from the SWP each year. SGPWA also acquires water supplies through contracts with other agencies and annual water transfers and exchanges. Currently, as a wholesale agency, SGPWA distributes imported SWP water to three (3) member agencies: the City of Banning, BCVWD, and Yucaipa Valley Water District.

Table 3 shows the City’s recent imported water purchases from 2015 to 2020 and compares them to the years 2010 to 2015. As shown in the table, the City purchased an average of 752 AYF per year from 2015 to 2020.

Table 3. Imported Water Purchases, courtesy of the 2020 Urban Water Management Plan (2020 UWMP)
Year Purchases (AFY)
2015 686
2016 1,477
2017 1,350
2018 500
2019 250
2020 250
2015-2020 Avg. 752
2010-2015 Avg. (2015 UWMP) 847
Groundwater Sources
The City is within the boundaries of the Coachella Valley Hydrologic Unit, which encompasses several groundwater basins, including the Coachella Valley Groundwater Basin (Basin), within which the City is located. The Basin extends from Banning to the Salton Sea.

The City is underlain by the San Gorgonio Pass Subbasin (SGP Subbasin) portion of the Basin. The SGP Subbasin is divided into water storage units. The City extracts groundwater from the Banning 1176
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Storage Unit, the Banning Bench Storage Unit, the Cabazon Storage, the Beaumont Storage Unit, and the Banning Water Canyon Storage Unit.

Over the past five years of operation, groundwater extraction has averaged 7,513 AFY. Table 4 displays the City's groundwater supplies from 2015 to 2020.

Table 4. Imported Water Purchases, courtesy of the 2020 UWMP Year Production (AFY)
2015 6,723
2016 7,035
2017 7,576
2018 7,924
2019 7,226
2020 8,596
Average 7,513
2010 – 2015 Avg. (2015 UWMP) 8,246
Currently, the City does not utilize the entire capacity of all of its storage units. The maximum annual amount pumped by the City in the past 10 years is just under 9,000 AFY. Due to the projected developments, the City expects pumping to increase by 25% within 10 years and over 50% by the end of 2045. Table 5 below shows the City’s projected water supplies and available volumes.

Table 5. Projected Water Supply Availability in AFY, courtesy of the 2020 UWMP Year 2025 2030 2035 2040 2045
Basin Projected
(Available)
Projected
(Available)
Projected
(Available)
Projected
(Available)
Projected
(Available)
Beaumont Basin(1) 1,491
(1,491)
1,267
(1,267)
1,077
(1,077)
916
(916)
778
(778)
West Banning
Basin
1,430
(1,430)
1,430
(1,430)
1,430
(1,430)
1,430
(1,430)
1,430
(1,430)
Cabazon Basin 853
(N/A)
960
(N/A)
1,054
(N/A)
1,136
(N/A)
1,208
(N/A)
Banning Bench 1,055
(1,330)
1,187
(1,330)
1,304
(1,330)
1,330
(1,330)
1,330
(1,330)
Banning Water
Canyon
3,679
(3,730)
3,730
(3,730)
3,730
(3,730)
3,730
(3,730)
3,730
(3,730)
Imported Recharge
into Beaumont
Basin
250 500 1,000 1,750 2,500
Water Supply
Deficit(2)
999 2,126 3,156 4,128 4,991
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Total Available
Local
Groundwater
Supply
8,508 8,574 8,595 8,542 8,476
Storage Banked in
the Beaumont
Basin
42,169 38,422 30,291 19,510 7,622
Notes:
(1) The City’s appropriated water rights will continue to decrease over time due to overlying water rights or demand increases. (2) The water supply deficit is currently covered by Beaumont storage.

Surface Water
The Whitewater Flume was built to provide water and power to the City and Banning Heights Mutual Water Company (BHWMC). BHWMC utilizes approximately 1,000 AFY of the Whitewater River diversions in the Flume, and the remainder of the diverted water flows into the San Gorgonio River below the Banning Heights Mutual Water Company (BHMWC) extraction point.

A portion of the natural runoff and the Whitewater River diversions are diverted into spreading ponds located approximately one mile north of the Banning Bench in order to increase groundwater recharge.

Since 1913, surface water from the Whitewater River has been diverted into the Banning Water Canyon Storage Unit, with an average of 1,500 AFY diverted into Banning Water Canyon since 1961.

Rights to Groundwater
The City’s rights to annual groundwater extraction are shown in Table 5. The City will pull the differential amounts between the “Projected” and “Available” from the Beaumont Basin Storage Account. Water recharged (i.e., imported water) in the Beaumont Basin will also be credited in the City’s storage account, allowing the “Projected” volume to increase. The City also anticipates that it would recharge more during wet years so that water supply can be available during drought periods when local groundwater levels are impacted.

The amount of “Available” yield not produced in the Beaumont Basin by the Overlying Water Right holders is issued to the retail agencies, with the City of Banning receiving 31.43% of the “Available” yield. The amount of Unused Overlying Water from the Beaumont Basin that will be allocated to the City of Banning is projected to decrease by 15% every five years from 2024 on.

Planned Supply Projects
The City continually reviews practices that will provide its customers with adequate and reliable supplies. Trained staff continue to ensure the water quality is safe and the water supply will meet present and future needs in an environmentally and economically responsible manner. The City coordinates its long-term water shortage planning with SGPWA and other local agencies through the development of their respective UWMPs. The City also meets bi-monthly with the San 1178
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Gorgonio Pass Regional Water Alliance, which is comprised of thirteen (13) local water purveyors, to discuss local issues with different agencies.

Any new City water supply projects will be to add, replace, or upgrade wells to support population growth and new development. The projects that have been identified to improve the City’s water supply reliability and enhance the operations of the City's facilities include replacement of water meters, fire hydrants, valves, and pipelines and construction of new storage reservoirs.

2.3.2 Wastewater Treatment Plant Flows
The City provides sewer service to the area within City limits and to unincorporated areas of Riverside County that surround the southeast portion of the City. The City of Banning is responsible for the collection, conveyance, treatment, and disposal of wastewater generated within its service area. Municipal wastewater in the City’s service area is generated from residential, commercial, and institutional sewer discharges. The City does not currently have any major industrial sewer discharges (i.e., brine). However, there are some cannabis cultivation facilities that will be operational soon, which will need to be monitored and regulated.

The City’s wastewater collection system drains primarily from west to east. The wastewater discharged from the City is collected from a network of 112 miles of gravity sewer mains. The local collector sewers discharge into larger sewer trunk mains, then to the Banning WWTP, located in the southeast corner of the City (see Figure 4 on Page 14).

The WWTP has a current capacity of 3.6 million gallons per day (MGD) and is designed to treat wastewater to secondary standards. The WWTP consists of preliminary treatment, primary treatment, secondary treatment, solids handling, disinfection (currently not in use), and evaporation/percolation ponds. The preliminary treatment system consists of a mechanical bar screen, compactor, grit removal system, and cyclone separator. Effluent from the preliminary treatment system is gravity fed to two primary clarifiers. Primary effluent is pumped to two Trickling Filters, each rated for 1.8 MGD. The Trickling Filter effluent is sent to two secondary clarifiers. Secondary effluent flows through a chlorine contact chamber and is then discharged to 10 unlined evaporation/percolation ponds which recharges the Cabazon Groundwater Basin. This recharge is provided only through surface percolation, and no injection wells are used by the City.

Primary and secondary sludge is processed via two primary anaerobic digesters. A second-stage digester is currently used as a sludge holding tank before thickened sludge is sent to the sludge drying beds. Sludge is allowed to dry and then is hauled offsite for final disposal. A gravity thickener was used to thicken secondary sludge but is currently not in service. An overall process schematic of the existing WWTP is shown in Figure 5 on Page 15.

The quantities of wastewater generated are proportional to the City’ population and the water used by its residents. The wastewater flows are metered at the influent point to the WWTP. Total wastewater collected in the City between 2018 and 2022 is shown in Table 6.

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Table 6. Wastewater Flows Collected in City
Year Wastewater (AFY) Wastewater (MGD)
2018 2,259 2.02
2019 2,234 2.00
2020 2,185 1.95
2021 2,226 1.99
2022 2,307 2.06
Average 2,242 2.00
Due to projected housing developments within the City’s service area, wastewater flows are expected to significantly change. Based on review of available data, it was determined that the most accurate forecasting methodology for projected sewer flow included a combination of population and land use flow factors. Table 7 below shows the projected wastewater flows from the years 2023 through 2027:

Table 7. Projected Wastewater Flows Collected in City

Year Flows (AFY) Flows (MGD)
2023 2,352 2.10
2024 2,430 2.17
2025 2,520 2.25
2026 2,610 2.33
2027 2,700 2.41
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Figure 4. City of Banning Reclaimed Wastewater Treatment Plant Location (courtesy of 2018 IMP)
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Figure 5. Process Schematic for Existing WWTP

2.3.3 Non-Potable Groundwater Well Capacities
The City has been operating one well (Well M7) and estimates that this well produces an average capacity of approximately 350 gpm. In addition, the City also started to operate a second well (Well M12) in mid-year 2017 with an estimated capacity of approximately 1,000 gpm. A third well (Well NP-1) is located near the WWTP, which was recently equipped. The status and capacities of the wells are summarized in Table 8.

Table 8. Existing City Non-Potable Groundwater Well Capacities Well Number Current Status Future Status Estimated
Capacity (AFY)
Estimated
Capacity (MGD)
Well M7 Operational Potable 560 0.5
Well M12 Operational Potable 1,568 1.4
Well NP-1 Recently
Equipped
Non-Potable 1,344 1.2
Total 3,472 3.1
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As listed in Table 8, the total estimated capacity of the three wells with the addition of Well NP1 is approximately 3,472 AFY (3.1 MGD) of non-potable water. Although Wells M7 and M12 are both equipped, City staff plans to eventually convert Well M7 and Well M12 over to the potable water system by the end of year 2025 and year 2040, respectively, to supplement the potable water supply. Along with this conversion, it is assumed that Well NP-1 will supplement the recycled water system supply. With only Well NP-1 and Well M12 online by the end of year 2025, the groundwater well supply is estimated to provide up to 2,912 AFY (2.6 MGD) of non-potable water. By the end of year 2040, only Well NP-1 is assumed to be online, which results in a groundwater well supply of 1,344 AF (1.2 MGD). The capacities listed in MGD reflect the assumption that wells would be pumping 24 hours per day.

2.3.4 Recycled Water Production
As mentioned in Section 2.3.1, the Banning WWTP is the only wastewater treatment facility for the City. The WWTP currently provides only secondary treatment, and the treated wastewater does not meet Title 22 Standards. Further, the City does not use any recycled water produced by any other neighboring agencies. Thus, no wastewater has been “recycled” (re-used) within the City’s service area from 2019 to 2023, as Table 9 indicates.

Table 9. Recycled Water Produced and/or Used in City
Year Recycled Water
Produced or Used
(AFY)
2019 0
2020 0
2021 0
2022 0
2023 0
The amounts indicated in Table 9 above coincide with the projections in the City’s 2020 UWMP.

That is, the 2020 UWMP did not project any recycled water use through the year 2020.

Current and Projected Water Demands

2.4.1 Current Water Demands
Annual water consumption from 2016 to 2020 listed in Table 10 range from a high of 8,325 AF in 2020 to a low of 6,712 AF in 2016, with an average of 7,648 AF.

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Table 10. City Recent Water Use
Year Total Consumption
(AFY)
Per Capita (GPCD)
2016 6,997 203
2017 7,381 213
2018 7,927 228
2019 7,297 209
2020 8,369 240
Average from 2016 to 2020 219

2.4.2 Projected Water Demands
Future water use projections must consider significant factors on water demand, such as development and/or redevelopment, and climate patterns, among other less significant factors that affect water demand. Climate conditions will continue to be a major influence on demand as drought conditions will increase demand at a time when these supplies are limited.

The City's projected water use for 2025-2045 is broken down by sector in Table 11 below.

Table 11. Projected Water Demand by Sector in AFY, courtesy of the 2020 UWMP Sector 2025 2030 2035 2040 2045
Water Service Area
Population
38,180 45,235 52,290 59,345 66,400
Consumption Rate (GPCD)
Including 1.0% Annual
Passive Savings
222 211 201 191 181
Demands
Single Family Residential 4,505 5,071 5,569 6,004 6,382 Multi-Family Residential 92 103 114 123 130
Commercial 2,263 2,548 2,798 3,016 3,206
Industrial 195 220 241 260 276
Institutional/Governmental 26 29 32 35 37
Landscape Irrigation 977 1100 1208 1,302 1,384
Total Water Sales 8,059 9,070 9,961 10,739 11,415
Unaccounted for Water 1,448 1,630 1,790 1,930 2,052
Total Water Consumption
(Total Supply into System)
9,507 10,701 11,751 12,670 13,467

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2.4.3 Projected Recycled Water Demands
The City currently serves one customer, Sun Lakes Country Club, with non-potable water from Well M7 and Well M12. Typical annual demand for the Sun Lakes Country Club is 850 AFY (0.76 MGD). Since the Sun Lakes Country Club is located on the westerly end of the City, once the City constructs the recycled water backbone pipeline to reach the Sun Lakes Country Club, other potential customers would be within proximity to receive recycled water. Therefore, construction of recycled water facilities would prove feasible if the funding for recycled water improvements and pipeline infrastructure was covered, at least in-part, by developers, and an agreement was in place for the use of recycled water. The City would then be able to provide recycled water to its customers. The City’s previous 2006 Recycled Water Master Plan (2006 RWMP) identified potential customers across the Interstate 10 Freeway. The methodology to determine these customers and their demands is described in Section 3.3. However, the 2018 Integrated Master Plan indicated that these potential customers were not feasible, due to the challenges to cross the 10 Freeway. The potential recycled water customers are listed in Table 12 below and shown in Figure 6 on the following page.

Table 12. Potential Recycled Water Users
Customer Recycled Water Demand
(AFY)
Recycled Water Demand
(MGD)
Existing Customers Currently Using Potable Water or Ground Water from Non-Potable Wells
Sun Lakes Country Club 850 0.76
Banning High School 175 0.16
Dysart Park 87 0.08
Lions Park 79 0.07
Subtotal 1,191(1) 1.07
Projected Future Developments
Rancho San Gorgonio
Development
217 0.19
Five Bridges Development 223 0.20
Neighborhood Park 35 0.03
Subtotal 475(2) 0.42
Total 1,666 1.49
Notes:
(1) Will serve in Phase I of the Project.
(2) Will serve in Phase II (future phase) of the Project. 1185
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Figure 6. City of Banning Potential Recycled Water Customers (courtesy of 2018 IMP)

2.4.4 Projected Water Supply and Demand Imbalances
Table 13 shows the imbalances between the projected water supplies and demands of the City.

As shown in the table, demand continues to increase as supplies decrease. This indicates the need for a new, drought-proof local supply of water to meet the demands of the City.

Table 13. Projected Water Supply and Demand Imbalances
2025 2030 2035 2040 2045
Total Available Local
Groundwater Supply in AFY
(see Table 5)
8,508 8,574 8,595 8,542 8,476
Total Water Consumption in
AFY (Total Supply into
System) (see Table 11)
9,507 10,701 11,751 12,670 13,467
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Local Groundwater Supply
Shortage in AFY Supplied by
Storage Banked in
Beaumont Basin
-999 -2,127 -3,156 -4,128 -4,991
Storage Banked in the
Beaumont Basin in AFY (see
Table 5)
47,169 43,422 35,291 24,510 12,622
Future Recycled Water Supplies
The City plans to upgrade the existing WWTP treatment to meet tertiary treatment standards and facilitate infrastructure to supply recycled water. This proposed expansion described in the 2018 IMP is also in accordance with the City’s 2006 RWMP. The proposed WWTP upgrade will include enhancing biological treatment and constructing recycled water laterals along the backbone pipeline. Facilities to be constructed would include recycled water pipelines to transport recycled water to the recycled water customers.

Upon completion of the upgrades, approximately 4,035 AFY (3.6 MGD) – the total projected WWTP effluent – of recycled water will be available to recycled water customers. Assuming that the improvements would be completed by the year 2027, projected recycled water use would be as shown in Table 14 below.

Table 14. Projected Recycled Water Production and/or Use Year Phase Recycled Water
Produced / Used (AFY)
Recycled Water
Produced / Used (MGD)
2025 N/A 0 0
2027 I 4,035/1,191 3.6/1.07
The projected quantities shown in Table 14 above show the recycled water produced and used in Phase I of the project (described further in Section 4.2). Once the WWTP upgrades are completed, 4,035 AFY (3.6 MGD) will be available for recycled water use. Phase I will serve the existing customers currently using potable water or ground water from non-potable wells (Sun Lakes Country Club, Banning High School, Dysart Park, and Lions Park) with a total demand of 1,191 AFY.

Water Quality Concerns
The main water quality concerns are the standards and regulations that the potential recycled water sources currently do not meet. These include the Regional Water Quality Board Order, Title 22 Requirements, and Beaumont Basin Plan requirements.

2.6.1 Regional Water Quality Control Board Order
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On June 30, 2016, the RWQCB adopted Board Order R7-2016-0015 (Board Order), which describes the Waste Discharge Requirements (WDRs) and other terms and conditions of operation for the WWTP. The Board Order requires the WWTP to remove constituents that present the greatest risk to groundwater quality such as nitrogen, coliforms, and total dissolved solid (TDS). According to the United States Environmental Protection Agency (US EPA), the maximum contaminant level (MCL) for Nitrate as Nitrogen is 10 mg/L. Per the Board Order, it is assumed all nitrogen available converts to nitrate/nitrite so Total Nitrogen (TN) is used as the measurement of concern. The wastewater effluent limitations per the Board Order are outlined in Table 15.

Table 15. Banning WWTP Effluent Concentrations and Limitations Parameter Units Impending Effluent Limits
30-Day Mean 7-Day Mean
Flow MGD 3.6 N/A
20C BOD5 mg/L 30 mg/L 45 mg/L
TSS mg/L 30 mg/L 45 mg/L
pH -- 6.0 – 9.0
TDS mg/L Not to Exceed 300 mg/L of the Water Supply
TN(1) mg/L 10 mg N/L
Notes:
(1) City does not need to comply with this limit at this time.

The WDRs identified TN and TDS as constituents of concern. Currently, the average TN concentration in the WWTP’s effluent is 27 mg-N/L, well above the future TN limit of 10 mg-N/L specified in the Board Order. The two existing Trickling Filters used for secondary treatment at the WWTP are therefore not able to meet the impending water quality limits by the Board Order.

Based on a recent structural condition assessment, both Trickling Filters are also nearing the end of their lifecycle. This Project therefore involves implementing a new biological treatment system with nitrification/denitrification (NDN) to ensure nitrogen levels in the WWTP’s effluent meet the impending Board Order TN requirement. The selected system to replace the existing Trickling Filters is Membrane Bioreactor (MBR). Section 4.6 describes the analysis that was done to select MBR as the recommended biological treatment option for the City.

The WDRs also state that effluent TDS is not to exceed a level of 300 mg/L above the potable water supply “reasonably protects present and anticipated beneficial uses of groundwater in the area,” (typical incremental addition of dissolved salts from domestic water usage is 150 to 380 mg/L.) The level of TDS in Banning’s potable water supply is approximately 200 mg/L, which would result in an effluent TDS limit of approximately 500 mg/L. Currently, the average TDS in the treated wastewater is about 390 mg/L, so future TDS limits in an updated WDR would not require additional treatment.
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2.6.2 Title 22 Requirements
In order for the WWTP effluent to be used as recycled water to meet the current and project non-potable irrigation water demands, it must meet tertiary disinfected recycled water standards. The current WWTP effluent does not comply with State Water Resources Control Board, Division of Drinking Water (DDW) water recycling criteria outlined in the California Code of Regulations Title 22 requirements. To comply with Title 22, the effluent must meet the following requirements for “Disinfected Tertiary Recycled Water”:
• Average daily turbidity less than 2 nephelometric turbidity unit (NTU); approximately 3 – 5 mg/L TSS.
• Effluent cannot exceed 5 NTU more than 5% of the time. • Effluent cannot exceed 10 NTU at any time.
• Coagulant must be added if the influent to the filter exceeds 5 NTU for more than 15 minutes, or 10 NTU at any time.
• The disinfection process must provide a chlorine residual that provides 450 milligram minutes per liter (mg-min/L) under minimal modal contact time (CT) of 90 minutes. o This corresponds to a residual of 5 mg/L or less, or any process that achieves 5-log virus removal.
• Total coliform cannot exceed the average most probable number (MPN) of 2.2 per 100 milliliters (mL).
• No more than one sample per month can exceed an MPN of 23 per 100 mL.

In order to supply recycled water, the City will be required to improve the removal efficiency of the existing WWTP to comply with the TN, turbidity, and disinfection requirements. The Project involves implementing MBR and chlorine disinfection at the WWTP. These proposed treatment systems ensure that the WWTP will comply with Title 22 requirements for disinfected tertiary recycled water.

2.6.3 Beaumont Basin Plan Requirements
In order to serve Sun Lakes Country Club, which is located above the Beaumont Basin, the WWTP and Well NP-1 must meet the Beaumont Basin maximum benefit objectives of 330 mg/L for TDS.

Currently, the WWTP effluent and Well NP-1 have an average TDS of 390 mg/L and 430 mg/L, respectively. Therefore, neither source currently meets this limit. Due to this restriction, and potential stricter TDS limits for the San Gorgonio region in the future, a TDS treatment is required.

The proposed TDS treatment for this Project is a two-stage reverse osmosis (RO) system to be implemented as the last step in the WWTP treatment process. Details about the RO requirements for the WWTP and Well NP-1 can be found in the RO Analysis Technical Memo in Appendix A.

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3. WATER RECLAMATION, RECYCLING OPPORTUNITIES
Introduction
This section provides a discussion of the City’s water reclamation and reuse opportunities including:
• Potential uses for reclaimed water and sources to be reclaimed • Markets available to use the water produced
• Considerations that may prevent implementation of a water reuse project • Water and wastewater agencies with jurisdiction and their facilities • Current water reuse
• Water reclamation and reuse technology currently in use and opportunities for improvement
Uses for Reclaimed Water
The available market is the non-potable demand from the existing customers currently using potable water or ground water from non-potable wells as well as the future recycled water customers listed in Section 2.4 Table 12. These customers consist of parks, schools, and other landscape irrigation users. The market for water produced by Phase I of this Project (described further in Section 4.2) is expected to be 1,191 AFY (1.07 MGD).

Appendix B includes the Rancho San Gorgonio Water Supply Assessment, which states that the Rancho San Gorgonio Development must utilize recycled water for all common area irrigation demands (see Appendix B, Section 5 “Recycled Water System,” pages 37-41 of the document, page 38-42 of the PDF). For the other customers, discussions have been initiated to obtain letters of intent.

Water Market Available to Utilize Reclaimed Water
The future recycled water demand projections listed in Section 2.4 Table 12 are based on a review of the identified potential customers in the 2006 RWMP. This section describes the methodology used to project the future demand potential.

It should be noted that the future demands described herein do not necessarily represent the actual future demands. This section is limited to identifying the future demand potential.

3.3.1 Methodology
As described in Section 2.4, the 2006 RWMP identified potential 18 recycled water customers based on the following three criteria:

1. Location shall be near a recycled water distribution pipeline or in proximity of other potential customers.

2. ADD exceeds 10,000 gpd. Potential customers with ADD less than 10,000 gpd may be eligible if their location is near a recycled water pipeline. 1190
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3. Location within City limits.

The list of potential recycled water customers was reviewed to determine the current irrigation status of each customer and the feasibility of tying into the recycled water system, resulting in an updated list of 15 customers.

3.3.2 Potential Customers
Since the 2006 RWMP, several customers, including Caltrans, Repplier Park, and Gilman Ranch Museum, have reduced demands due to changes such as drought tolerant landscaping. Based on an initial review of the recycled water system layout, connecting these customers was not considered cost effective. In addition, customers north of the Interstate 10 would require a second pressure zone, resulting in an additional pump, large lengths of pipeline, and additional storage to serve these customers. Since those customers were not large users, City staff decided to keep the recycled water system south of the Interstate 10. The customers that are included in this analysis and their demands are summarized in Section 2.4, and the location of the recycled water customers is shown in Figure 6.

Considerations That Will Prevent Implementing Water Reclamation One consideration of concern is water quality, particularly TN and TDS levels of the WWTP. As mentioned previously in Section 2.5, the WWTP must comply with the Board Order, Title 22, and Beaumont Basin Plan requirements to supply recycled water. One of the main objectives of this Project is therefore to overcome these water quality limitations by implementing treatment systems that will effectively lower TN and TDS to allowable levels.

Another consideration is community push back for tertiary recycled water. With this in mind, the community will be involved with this Project through public meetings to voice their concerns. It is, however, expected that the reliability and high water quality of recycled water will help to stimulate recycled water demand and mitigate the public’s concerns.

Agencies with Jurisdiction Over Sources of Reclaimed Water The WWTP and groundwater wells are solely owned by the City.

Potential Sources to be Reclaimed
Effluent from the City of Banning WWTP and Well NP-1 are two potential sources to be reclaimed.

Descriptions of the two sources are described in Section 2.3.

Description and Location of Source Water Facilities
Effluent from the City of Banning WWTP and Well NP-1 are two potential sources to be reclaimed.

Descriptions of the two sources are described in Section 2.3.

Current Water Reclamation Taking Place in Study Area
As discussed in Section 1.4, there is no water reclamation taking place in the City of Banning. 1191
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Other Current and Projected Wastewaters and Disposal Options If the WWTP does not get upgraded to Title 22 standards, the current disposal option will remain; the effluent from the WWTP will continue to percolate into the 10 unlined percolation ponds within the Cabazon Groundwater Basin, with no benefits to the City.

In order to meet the Board Order TN restriction, however, the biological treatment process at the WWTP would need to be upgraded regardless of whether the WWTP effluent was used for reclaimed water purposes.

Water Reclamation Technology Use in Study Area
As discussed in Section 1.4, there is no water reclamation taking place in the City of Banning.

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4. DESCRIPTION OF ALTERNATIVES
Non-Federal Funding Condition
If Federal funding were not provided for the Project, the City would delay the project and continue to apply for funding under other opportunities as described in Section 9.5.

Specific Objectives Alternatives Are Designed to Address The objectives of the proposed Project are to:
• Increase water supply availability, reliability, and drought resiliency by supplementing a local water supply, and
• Improve local water supply reliability by proactively planning for facilities needed to meet future demand.

There are three proposed potential recycled water project alternatives to achieve these objectives. These alternatives include:
• Alternative 1: Do Nothing
• Alternative 3: Non-Potable Reuse
• Alternative 4: Hybrid Non-Potable Reuse and Indirect Potable Reuse

4.2.1 Alternative 1 - Do Nothing
This alternative involves no recycled water upgrades of the WWTP. The existing facilities would remain at the WWTP, and effluent from the WWTP would continue to discharge to the percolation ponds near the WWTP site. Under this alternative, due to the WWTP’s current high TN levels, the plant would not meet the impending Board Order requirements. In addition, the existing non-potable water customers would continue to be served by potable water or ground water from non-potable wells, and therefore Wells M7 and M12 would not be converted to the potable water system. In order to recharge the groundwater to serve these customers, the City would continue to purchase imported water from the Sacramento-San Joaquin Delta through SGPWA. However, with worsening climate change conditions, State water supplies are becoming scarcer. Because of this, competition for water allocations to water retailers will increase, making it more challenging for the City to receive imported water. Therefore, imported water should not be solely relied on to meet future demands that exceed the City’s local supply.

The O&M costs for the “Do Nothing” alternative include the purchase of imported water and pumping costs to serve the existing non-potable water customers. The current estimated annual O&M cost to deliver imported water is estimated at $463,848 per year. This includes an average (based on 2015-2020) purchase of 752 AF of imported water at $399/AF, or $300,048, plus $163,800 for pumping, or $463,848 per year. The projected O&M cost for imported water in 2045 is $2,779,000 for purchase and $1,517,090 for pumping for a total of $4,296,090. This is based on a purchase of 2,500 AF of imported water (see Table 5 in Section 2.4) and a 5% price escalation rate of imported water purchases and pumping per year.
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4.2.2 Alternative 2 - Non-Potable Reuse
Alternative 2 involves three phases. Phase I will begin early 2025 to meet the current demands of Sun Lakes Country Club. Phase II will begin by 2029 to meet the demands of the future remaining recycled water customers.

Phase I
Since Well M7 is planned to be converted to the potable water system by the end of 2025, Phase I involves using Well NP-1 to supply 850 AFY (0.76 MGD) to Sun Lakes Country Club in place of Well M7.

A recent Well NP-1 pump test shows an 800-gpm capacity, which exceeds the demand of the Sun Lakes Country Club. As a result, Well NP-1 will operate intermittently to satisfy the current recycled water demand.

Construction of the backbone pipeline along Lincoln Street to connect Well NP-1 to the Sun Lakes Country Club will be completed by the end of 2023. The design of the two reservoirs/forebays and booster stations needed to store the Well NP-1 supply and pump the water to the backbone pipeline, respectively, will be completed during the first quarter of 2024. The City is currently developing environmental documentation and will begin construction of the reservoirs/forebays and booster stations within the second quarter of 2024.

To meet Beaumont Basin requirements for TDS and TN, a 1 MGD RO system will be implemented at Well NP-1, and evaporation beds will be constructed for the RO brine. The RO permeate will travel through the backbone pipeline to Sun Lakes Country Club, with the forebay storing Well NP-1 supply and the booster station pumping the water from the forebay to the backbone pipeline.

Well NP-1 will continue to serve Sun Lakes Country Club until the WWTP upgrades are completed at the end of 2027.

The next step of Phase I is to upgrade the WWTP. The existing Trickling Filters and secondary clarifiers will be decommissioned, and a new 3.6 MGD MBR facility and chlorine disinfection tank will be installed to meet Title 22 recycled water standards. Other miscellaneous upgrades of the WWTP, including headworks, primary clarifier, and digester facilities, will also be implemented in this phase.

Laterals with pipeline diameters ranging from 6-12 inches will be constructed to connect the remaining customers currently using potable water or ground water from non-potable wells listed in Section 2.4 (Banning High School, Dysart Park, and Lions Park).

Once the construction of the WWTP upgrades is complete, the RO system and brine evaporation ponds used for Well NP-1 will be repurposed for WWTP effluent use. 1,191 AFY (1.07 MGD) of the WWTP effluent will serve the demands for Sun Lakes Country Club, Banning High School, Dysart Park, and Lions Park, and the rest will continue to discharge to the percolation ponds. 1194
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Since the WWTP effluent will be used to meet the recycled water demands, Well NP-1 will be used as a backup source.

Phase II
In Phase II, laterals will be constructed to connect the future recycled water customers, including Rancho San Gorgonio Development, Five Bridges Development, and Neighborhood Park to the main recycled water system.

In order to meet the Beaumont Basin requirements to serve these remaining customers, an additional RO module will be installed at the WWTP. The permeate from the RO modules will blend for a total of 1,666 AFY (1.49 MGD) of WWTP effluent to serve the recycled water customers. The remaining WWTP effluent will continue to discharge to the percolation ponds.

Figure 6 in Section 2.4 shows the proposed layout of Alternative 2.

4.2.3 Alternative 3 – Hybrid Non-Potable Reuse and Indirect Potable Reuse Alternative 3 is similar to Alternative 2 but incorporates an additional phase for indirect potable reuse. Instead of the WWTP effluent that is not used to meet recycled water demands discharging to the percolation ponds, in Alternative 3, the remaining effluent will flow to one of two groundwater aquifers for indirect potable reuse. By percolating to new basins upgradient of the Banning groundwater storage unit, this will keep groundwater recharge within the City’s wells.

Options for recharge of groundwater aquifers via recharge basins include North Basin and Five Bridges. The requirements to recharge to North Basin and Five Bridges Basin are described in the sections below. Figure 7 on the next page shows the proposed layout of Alternative 3.

Due to the limited surface recharge capacity of the proposed groundwater basins, injection wells may be required to recharge groundwater in the targeted area. In order to allow for indirect potable reuse through injection wells, ultraviolet advanced oxidation (UVAOP) will be required.

The current facility plan would include needed infrastructures (e.g., transformer size, space allocation, etc.) to facilitate this addition in the future when needed. The surface recharge at these basins will take into account ground water travel time to the nearest potable groundwater wells and appropriate monitoring wells for full compliance with Title 22 regulations.

North Basin
North Basin is in the northeastern part of the City boundary. This site is not owned by the City.

Since the site has been mined and a large pit exists, it is assumed that minimal earthwork will be required. The site improvements included as part of this analysis include a berm on all four sides of the basin, a berm to create two cells for operational flexibility, basin piping, maintenance ramps, security, and monitoring equipment. Since the potential recharge basin is at a higher elevation than the WWTP, an 800 hp pump and 15,000 feet of 16-inch diameter pipeline will be 1195
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required to convey water from the WWTP to the recharge basin. The City will also need to add monitoring wells and lysimeters.

Five Bridges Basin
This option involves groundwater recharge at the future Five Bridges Recharge Basin, which is located at the southwest part of the City within the Five Bridges Development. The site will likely be owned by the City. Although the Five Bridges development is not anticipated to occur until the build-out phase, City staff believe that the basin can be constructed beforehand. It is anticipated that site improvements will include earthwork, berms on all four sides of the basin, a berm to create two cells for operational flexibility, maintenance ramps, security, and monitoring equipment. This alternative will require an approximately 2,000 feet of 16-inch diameter pipeline to convey water from the WWTP to the recharge basin. The City will also need to add monitoring wells and lysimeters.

Figure 7. Preliminary Site Layout for Alternative 3 (courtesy of 2018 IMP) 1196
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Description of the Proposed Water Reclamation Project
The selected alternative is Alternative 3. This alternative includes non-potable reuse with a total demand of 1,666 AFY (1.49 MGD). The remaining recycled water supply from the WWTP will be used for indirect potable reuse at either North Basin or Five Bridges. With the combination of both non-potable reuse and indirect potable reuse, the City will have seasonal flexibility and will be able to maximize the use of recycled water throughout the year. Since the City will be able to maximize the recycled water supply from the WWTP, the estimated net yield is 4,035 AFY (3.6 MGD).

This Project (i.e. Alternative 3) will be done in 3 Phases, however, only Phase I will be implemented at this time. Phases II and III are future phases that will be implemented in the longterm. The City has only requested funding for Phase I in the WaterSMART funding application but will seek additional funding for Phases II and III in the future at which time the City will develop updated feasibility studies to includes Phases II and III.

As mentioned in Section 4.2, Phase I involves constructing an RO system and brine evaporation ponds for Well NP-1, which will later be repurposed for WWTP use. A new 3.6 MGD MBR facility and chlorine disinfection tank will be installed to meet Title 22 recycled water standards, and other miscellaneous upgrades of the WWTP will also be implemented in this phase. Laterals will be built along the backbone pipeline to connect the WWTP to the existing customers currently using potable water or ground water from non-potable wells that can utilize recycled water to meet irrigation demands.

The preliminary cost estimates for Phase I of the proposed Project are summarized in Table 16 below. A breakdown of the capital costs and replacement costs (over a 50-year period – the expected lifecycle of the Project) associated with Phase I of the Project are shown in Tables 17 and 18, respectively. Lifecycle costs over the 50-year span of the Project can be found in Appendix C, and a preliminary detailed site plan and process flow diagram for the Project can be found in Appendix D.

Table 16. Preliminary Cost Estimate
Estimated
Annual Yield
(AFY)
Capital Cost(1) O&M Cost Annual
Cost
($/year)
Unit
Cost
($/AF)
Phase I 1,191 $93,487,328 $3,500,000 $3,890,000 $3,668
Notes:
(1) Capital costs include a construction contingency of 25% and additional markups for mobilization (5%), general conditions (5%), contractor profit (5%), and escalation to-point of construction (5%). Cost estimates and cost assumptions are provided in detail in Appendix E. 1197
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Table 17. Cost Summary of Phase I of the Proposed Project, in 2023 dollars Item Cost
CEQA
CEQA (Biological, Cultural, Air Quality, and IS/MND) $180,000 Permitting $120,000
Subtotal $300,000
Design
Preliminary Design $1,409,808
Final Design $5,639,232
Subtotal $7,049,040
Construction
RO system $3,497,500
Brine Drying Beds and Evaporators $5,256,100
MBR Facility (3.6 MGD) $52,887,000
Primary Clarifier $1,944,100
Chlorine Tank $2,377,700
Upgrade Ferric Sulfate Feed/Storage System $298,100
Digester Coating $463,500
Replace Piping in Grit Chamber $58,300
Replace TF Center Drives $499,300
Replace East Primary Clarifier Center Drive $99,900
Replace Existing PVC Digester Gas Piping $16,700
Replace Digester Hot Water Boiler $176,400
Replace TF Effluent Distribution Valves (4) $174,800
Replace TF Recirculation Pumps (2) $124,900
Replace Grit/Cyclone Unit $299,600
Replace Two Old Grit Pumps $174,800
Recycled Water Laterals $2,141,700
Subtotal $70,490,400
Construction Administration
Construction Management and Inspection $7,049,040
Environmental Monitoring and Support During Construction $100,000 Subtotal $7,149,040
Other
Contingency $8,498,848
Subtotal $8,498,848
TOTAL ESTIMATED PROJECT COSTS $93,487,328
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Table 18. Replacement Costs, in 2023 dollars
Description of Replacement
Requirement
Replacement
Frequency
Year(s) Cost
Civil/Structural, Mechanical,
Electrical/Controls Replacements Every year
Every Year from 2028
to 2077 $868,658.82
RO Membrane Replacement and
MBR Membrane Replacement Every 5 years
2032, 2037, 2042,
2047, 2052, 2057,
2062, 2067, 2072,
2077 $2,200,000.00

Estimated Costs of Alternatives
Estimated capital and annualized costs were developed for each of the project options and are summarized in Table 19.

Table 19. Monetary Analysis
Estimated Annual
Yield (AFY)
Capital Cost O&M Cost Annual Cost
($/year)
Unit Cost
($/AF)
Alternative 1 752 (from
groundwater)
$0 $463,848 $493,848 $657
Alternative 3
(Phase I only)
1,191 $93,487,328 $3,500,000 $3,890,000 $3,668
As seen in Table 19, the proposed Project (Alternative 3 Phase I) has higher capital and annual costs than the “Do Nothing” Alternative. However, most of the benefits resulting from the implementation are difficult to quantify, as they include climate change and environmental impacts, as well as improved water supply quality and reliability.

Waste-Stream Discharge Treatment
The following waste streams will be involved in the Project: screenings, grit, primary sludge, secondary sludge and RO brine.

The WWTP currently has a mechanical bar screen and a grit chamber to remove debris and solid materials from the wastewater. These screenings and grit are then hauled offsite to a landfill.

Downstream of the headworks, there are two primary clarifiers that separate settleable solids from wastewater. After primary treatment, the effluent flows to the Trickling Filters then the secondary clarifiers, which separate biological floc from the treated wastewater. Sludge from the primary and secondary clarifiers is processed by two primary anaerobic digesters. A second-stage digester is used as a sludge holding tank before dewatered sludge is sent to the sludge drying beds. Sludge is allowed to dewater in these beds and is then hauled offsite for final disposal. 1199
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For Phase I of the Project, an additional primary clarifier will be added to the treatment process for redundancy in the system and to allow for peak flows in the WWTP influent. Additionally, the Trickling Filters will be replaced by MBR treatment, and the secondary clarifiers will be decommissioned. Therefore, the sludge from the primary clarifiers will combine with the waste activated sludge from the MBR system, rather than from the secondary clarifiers, to be processed by the digesters.

An additional waste stream that will be included in the Project is RO brine from the RO system.

There is expected to be around 0.035 MGD of RO brine that will require approximately 15 acres of salt evaporation ponds and 10 evaporators. This amount will increase as recycled water demand increases and more RO modules are needed. The brine evaporation ponds will be constructed on the WWTP property near the existing percolation ponds.

Alternative Technologies
Four viable biological treatment options were selected for evaluation to treat the anticipated average daily flow of 3.6 MGD. The treatment alternatives include:

1. Return Flow from Trickling Filter Effluent to Primary Clarifier

2. Conventional Activated Sludge

3. Moving Bed Biofilm Reactor

4. Membrane Bioreactor
See Appendix F for the Nitrogen Removal and Plant Reliability Technical Memo comparing the four alternatives. Due to its high effluent water quality, operational ease, flexibility to meet more stringent permit regulations, and scalability, a Membrane Bioreactor was recommended in the Technical Memo to be considered for future implementation. 1200
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5. ECONOMIC ANALYSIS
Introduction
The following sections provide an economic analysis of the Project compared to other alternatives.

Economic Analysis
Currently, no non-potable water reuse is being practiced in the City, and the effluent from the City’s WWTP is discharging to percolation ponds that Banning gains no benefits from. Producing reclaimed water would significantly enhance the City’s drinking water reliability and increase its economic advantage because of the sustainable growth and profit from selling the WWTP effluent to irrigation customers. The City has taken significant steps in establishing a water recycling program in the City including:
• Identifying existing and future customers that can utilize recycled water • Serving existing customers from non-potable groundwater wells • Constructing 24-inch backbone pipelines that extend across the City with easy access to existing customers that can utilize recycled water and future recycle water customers When the proposed facilities are complete (Phase I is constructed), the City will be able to convert all non-potable wells to potable, thus benefiting from the investments made in drilling and equipping these wells.

At this time, the City uses imported water for groundwater replenishment. By supplying these irrigation customers with a reclaimed local water supply instead of pumped groundwater (as is currently done), this will reduce the amount of required imported water for the City, thereby reducing the City’s overall water costs.

Another economic benefit of the Project is its impact on City growth. City growth is dependent on the availability of water supplies to meet various demands for new City population. Increasing the reliability of drinking water will therefore allow the City to meet its needs for growth.

As mentioned in Section 2.6, there is a compliance order from RWQCB that limits the TN from the WWTP. MBR, the selected treatment system, will be a reliable process that would meet these requirements. Among the alternatives proposed in Section 4.6, MBR would produce the best water quality. With the addition of RO, effluent from the WWTP would consistently meet the Beaumont Basin Plan requirements as well, allowing the City to supply recycled water to Sun Lakes Country Club and the remaining customers with significant irrigation demand.

Cost Comparison of Alternatives that Would Satisfy Demand of Proposed Project See Section 4.4 for a cost comparison of the proposed alternatives. 1201
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Description and Benefits of Water Supply Alternatives
Table 20 below compares the non-monetary criteria of the three Alternatives.

Table 20. Non-Monetary Criteria
Alternative 1 Alternative 3
(Phase I only)
Regulatory Compliance 1 5
Reliability/Process Robustness 2 5
Enhancement of Indirect
Potable Reuse
1 2
Groundwater Quality
Enhancement
1 5
Flexibility for Future Water
Reuse
1 5
Operational Simplicity 5 4
Ease of
Implementation/Funding
5 5
Total 16 31
As seen in Table 20, the proposed Project (Alternative 3 Phase I) has a higher ranking in terms of non-monetary criteria than the “Do Nothing” alternative (Alternative 1). Alternative 1 will keep the current WWTP system as is, keeping facilities that have reached their end of life, and therefore remaining non-compliant with the impending Board Order restrictions. Therefore, Alternative 1 is ranked the lowest in terms of regulatory compliance, enhancement of indirect potable reuse, groundwater quality enhancement, and flexibility for future water reuse.

Alternative 3 (Phase I only) is ranked the highest for regulatory compliance, reliability/process robustness, groundwater quality enhancement, and flexibility for future water reuse, as this alternative involves upgrading the treatment from the existing Trickling Filters to MBR to meet Board Order requirements and Title 22 standards (with the addition of chlorine disinfection).

Alternative Most Likely to be Implemented in Absence of Project The Alternative that would most likely be implemented in the absence of the Project is Alternative 1 – do nothing.

However, In order to meet the impending Board Order TN restriction which will exceed the WWTP treatment capacity, the biological treatment process at the WWTP would need to be upgraded regardless of whether the WWTP effluent was used for reclaimed water purposes.

Qualitative Benefits and Justification of Water Reclamation The non-quantifiable benefits are numerous. The sustainable recycled water supply will be tolerant to drought and will benefit the City’s customers through improved water supply reliability. 1202
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Another benefit is the reduction of reliance on imported water and the implementation of regional management of water supplies and groundwater quality.

Reclaiming treated wastewater also has environmental impacts. By using a local supply of water, energy is saved by not pumping imported water from the Bay Delta. By not using water resources imported from other regions, more water is available for environmental uses in those areas.

Additionally, since onsite treatment systems and the existing WWTP do not effectively remove nitrate from wastewater, another benefit of this Project would be the reduction of the amount of nitrate that percolates into the groundwater. This would not only help the City meet the Board Order requirements, but also alleviate the rising nitrate levels observed in some wells in the Region.

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6. SELECTION OF THE PROPOSED WATER RECLAMATION PROJECT
Introduction
This section describes the benefits of water reclamation for the City.

Justification of Water Reclamation as Selected Alternative The Project meets the objective of providing a cost-effective non-potable water supply. The Project has numerous qualitative and environmental benefits. These benefits are as follows:
• Increases local supply of non-potable water,
• Improves non-potable water supply reliability,
• Environmental benefits,
o Reduction of nitrate in the groundwater,
o Energy savings from less imported water from the Sacramento-San Joaquin Delta,
o Decreases demand on the regional wholesale water agency, SGPWA, which makes more water available for environmental uses from imported supply areas, o Reduces the use of existing diversions from natural watercourses. By implementing the Project, the City will reduce dependence on imported water supplies which are diverted from natural watercourses in the Sacramento-San Joaquin Delta The proposed facilities do not pose significant impacts to the environment and the City does not anticipate opposition to the Project. No obstacles have been identified that would prevent implementation of the project.

Analysis of Water Reclamation

6.3.1 Reduction, Postponement, or Elimination of Development of New or Expanded Water Supplies and Reduction of Diversions of Natural Water Courses To the extent that agencies like the City of Banning can develop local supplies, the wholesale agencies forego the need to expand their own supply sources or can reduce their reliance on other sources. Most of the imported supplies are obtained from diversions from natural water courses, including the Sacramento and San Joaquin Rivers. Local supply projects like this Project result in reduced development efforts by the wholesalers.

6.3.2 Reduction of Demand on Existing Federal Water Supply Facilities The California State Water Project (SWP) and the federal Central Valley Project share the Sacramento-San Joaquin Delta as a water supply. The imported water supply utilized by the SGPWA and the City comes from the SWP facilities. Although the Project would not reduce demand on the federal facilities, it could indirectly reduce the demand on the shared state and federal supply. 1204
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6.3.3 Reduction, Postponement, or Elimination of new or Expanded Wastewater Facilities This Project involves expansion of limited processes, including a new primary clarifier. Although the two existing primary clarifiers at the plant accommodate an average flow of 3.6 MGD, they do not allow for peak flow of redundancy. Therefore, a new primary clarifier will be installed to handle daily peak flow rate. The rest of the facilities at the plant are sized for the expected influent flow of 3.6 MGD and will not require expansion.

Expanding the primary treatment system and upgrading other systems at the WWTP, including headworks, secondary treatment, and digester facilities, will eliminate the need for a new wastewater facility.

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7. ENVIRONMENTAL CONSIDERATIONS AND POTENTIAL EFFECTS
Introduction
This section describes the potential environmental impacts and effects of the proposed Project, the environmental analysis and documentation prepared to date, how the project will affect water supply and water quality, and a discussion of public outreach and regional cooperation.

The governing laws are the State of California Environmental Quality Act (CEQA) and the National Environmental Policy Act (NEPA).

Potential Environmental Impacts and Effects
The City does not anticipate that the Project will have significant impacts on endangered or threatened species, public health or safety, hydrology and water quality, regulated waters of the United States, or cultural resources. The City does not anticipate that the Project will have significant environmental effects as defined by State and federal environmental laws. As such, the City will prepare a Negative Declaration to obtain CEQA coverage and expects that USBR will adopt a Finding of No Significant Impacts (FONSI) to obtain NEPA coverage for the Project. The City completed an Initial Study-Mitigated Negative Declaration (IS-MND) in October 2007. The IS-MND covered significant elements of the current proposed project. The findings of the October 2007 IS-MND were either “Less Than Significant Impact” or “No Impact”. The City has identified the potential environmental impacts described in Table 21, along with best management practices (BMPs) and potential mitigation measures.

Table 21. Potential Environmental Impacts and Mitigation Measures Potential Impact Potential Mitigation
Air quality and
greenhouse gases
An air quality analysis will be completed as part of the CEQA analysis. Project construction will comply with local air quality requirements. Typical dust control measures, such as watering and reducing off-road vehicle speeds, will be employed. Project operations will be evaluated for consistency with the State GHG reduction targets found in AB 32 and SB 32. Emissions from operation of the proposed facilities are not expected to exceed applicable significance thresholds.

Biological resources Construction of the project facilities is not expected to impact biological resources. Biological resources will be surveyed prior to design and sensitive species and their habitats will be avoided in the project design. The Project is not expected to impact wetlands or waters of the U.S. as regulated by U.S. Army Corps of Engineers, RWQCB, and California Department of Fish and Wildlife. The Project will comply with adopted Habitat Conservation Plans and Natural Community Conservation Plans.
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Operation of the Project is not anticipated to affect biological resources as all O&M activities will be constrained to the WWTP and associated brine minimization and drying beds, Operation will be sustainable and will have no impact on riparian and aquatic habitats.

Cultural resources No Cultural resources are known to exist on the Project site.

Cultural resources will be surveyed prior to design and the Project will be designed to avoid any identified cultural sites.

Onsite construction monitoring mitigation may be necessary to ensure that discovery of any previously unidentified
archeological resources is handled appropriately.

The City will comply with California Assembly Bill 52 regarding formal consultation with Native American tribes about the proposed Project.

Hydrology and water
quality
The City will characterize the RO brine (concentrate) discharge to the evaporation (drying) beds to verify quality of the solids before final disposal.

The proposed Project is not within the 100-year floodplain.

During the design This conclusion will be confirmed.

Hydrologic impacts, including erosion and siltation during construction of the proposed facilities would be minimized through compliance with existing regulations, including enrollment in an NPDES construction general permit,
completion of a storm water pollution prevention plan, and implementation of required BMPs.

Groundwater levels,
supplies, and recharge
during operation
The Project will result in directing a portion of the WWTP effluent for non-potable water reuse. This will reduce the amount of WWTP effluent currently discharged to the
percolation ponds. The Project will not impact any drinking wells.

Transport, use, and disposal
of hazardous materials
during construction and
operation
The RO system will use a variety of chemicals typically used in water treatment, possibly including scale inhibitors, membrane cleaning solutions, chlorine, ammonia, and caustic soda. Some of the chemicals will be delivered to the plant while others may be generated on-site. Chemical storage will have full containment structures to prevent spills along with alarms. Proper handling of these chemicals will be
incorporated into the Standard Operating Procedures.

Compliance with existing regulations is expected to minimize impacts to a less than significant level.
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Noise Construction noise is considered a nuisance and is regulated by the City’s Noise Ordinance. The majority of construction activities for the Project will be in the vicinity of the WWTP which is located in an isolated part of the City. Construction equipment will be fitted with approved mufflers and other measures may be utilized to comply with the existing
regulations.

Traffic impacts during
construction
Construction traffic associated with the proposed facilities construction will be temporary, and the impacts will be insignificant. Construction traffic controls will be employed to reduce public hazards.

Public Outreach
The majority of the proposed facilities will be within the footprint of the existing WWTP. As such the City does not anticipate any public opposition to this Project. Also, the City will add significantly needed upgrades to its WWTP, which would enhance its reliability. The City plans to implement more public outreach and enhance publicity for the proposed Project. The upgraded WWTP and non-potable reuse are expected to promote growth in this disadvantaged community.

The City has constructed a significant portion of the non-potable reuse conveyance system, and this Project would complement the completed facilities.

Effect of Historic Properties
The City does not anticipate that the project will have any adverse effects on historic properties.

The majority of construction will be within the WWTP footprint.

Avoiding Public Health and Environmental Quality Issues Associated with Use of Reclaimed Water
The proposed treatment facilities for the WWTP upgrades including MBR and partial RO will result in a reliable high-quality effluent suitable for non-potable reuse for irrigation purposes.

The effluent water quality will consistently meet all State Title 22 requirements.

The City will apply the treatment technologies described in Section 4.2 so that the product water will meet state and federal non-potable reuse water quality requirements for irrigation purposes.

The primary requirements are outlined in the State Title 22 requirements. The City will work closely with the SWRCB the State’s enforcement agency, in developing and permitting the Project. Typical steps include:
• Meetings and coordination,
• Submittal of the Project application,
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• Review and approval of the preliminary design,
• Review and approval of the project plans and specifications, and operating plan, • Inspection of plant construction and witness of start-up testing, and • Amendment of the City’s discharge permits.

Future phases of the Project include groundwater recharge of the Banning groundwater storage unit. The planned upgrades at the WWTP will incorporate space and hydraulic head for additional advanced treatments to be added in the future.

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8. LEGAL AND INSTITUTIONAL REQUIREMENTS
Introduction
This section focuses on the legal and institutional requirements which must be considered prior to implementation of the Project. The following is a discussion of water and wastewater rights, legal and institutional requirements, interagency agreements, permitting requirements, unresolved issues, and wastewater discharge requirements.

Analysis of Water Rights Issues
There are no anticipated water rights issues potentially resulting from implementation of the proposed project. Through various adjudications and overlying water rights, the City owns and operates the sources of water supply (WWTP and groundwater wells).

Discussion of Legal and Institutional Requirements with Potential to Affect Implementation of Project

8.3.1 Department of Water Resources – Sustainable Groundwater Management Act The Sustainable Groundwater Management Act (SGMA) was passed by the California State Legislature in September 2014, establishing new requirements for groundwater management in medium and high priority groundwater basins. The act requires the development and implementation of Groundwater Sustainability Plans (GSPs) for each groundwater basin and subbasin. The GSP must contain objectives and actions to achieve and maintain groundwater sustainability and to avoid the undesirable results of overdraft. SGMA also requires the establishment of Groundwater Sustainability Agencies (GSAs) to oversee development and implementation of GSPs and provides authority to GSAs to sustainably manage groundwater.

Local water authorities and counties have primary responsibility and authority for the development and implementation of GSPs and GSAs; however, the State has been given authority to intervene if specific requirements are not met.

8.3.2 Groundwater Sustainability Agencies
SGMA requires that high and medium priority groundwater basins, as designated by the California Department of Water Resources (DWR), create groundwater sustainability agencies by June 30, 2017. The bill authorizes any local agency or combination of agencies to become a GSA with the purpose of developing and implementing GSPs in order to meet the goals and standards of sustainable management of groundwater basins as described in SGMA. Multiple GSAs and GSPs in a single basin are allowed under the law; however, multiple GSPs within a basin must be coordinated and meet all requirements for achieving sustainable groundwater management within the entire groundwater basin or be subject to state intervention. A combination of agencies creating a GSA can be formed by a joint powers agreement, a memorandum of agreement, or other legal agreement.
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8.3.3 Groundwater Sustainability Plans
SGMA requires that GSAs develop and implement groundwater sustainability plans. GSPs must be completed by January 31, 2020 for basins deemed by DWR to be in critical overdraft. For all remaining medium and high priority basins, GSPs must be completed by January 31, 2022.

Implementation of the GSPs must result in groundwater quantity and quality sustainability within 20 years (by 2040 or 2042 based on the basin overdraft situation). DWR may grant up to two extensions of an additional five years to GSAs to achieve sustainability upon a showing of good cause. If the GSPs are not completed within the above timeframe, or if the SWRCB, in consultation with DWR, determines that groundwater sustainability is not being achieved in the time given, authority for developing and implementing a GSP will be designated to the RWQCB.

8.3.4 San Gorgonio Pass Subbasin
The SGP Subbasin (DWR Basin 7-021.04) is located in Southern California between the San Bernardino Mountains to the north, the San Jacinto Mountains to the south, Coachella Valley to the east and San Bernardino Valley to the west. The SGP Subbasin adjoins the San Timoteo Groundwater Subbasin to the west and the Indio Subbasin to the east. The SGP Subbasin boundaries generally correspond to the DWR’s California’s Groundwater Bulletin 118.

The San Gorgonio Pass (SGP) Subbasin (7-021.04) is one of several alluvial basins and subbasins identified by the California Department of Water Resources (DWR) as being in a medium-priority subbasin in Bulletin 118 (2003). Beginning in 2015, GSAs within the SGP Subbasin formed to address the long-term reliability of groundwater through the development a single GSP. The SGP Subbasin GSP (SGP GSP) was developed in a coordinated fashion by the Desert Water Agency GSA, San Gorgonio Pass GSA, and Verbenia GSA with the goal of achieving sustainability for the SGP Subbasin as a whole. The SGP GSP was adopted by the respective GSAs and submitted to DWR on January 25, 2022, ahead of the January 31, 2022, deadline.

The SGP GSP jurisdiction includes the Desert Water Agency GSA, San Gorgonio Pass GSA, and Verbenia GSA. Desert Water Agency GSA consists of the Desert Water Agency. San Gorgonio Pass GSA consists of Banning Heights Mutual Water Company (MWC), the City of Banning, Cabazon Water District (WD) and San Gorgonio Pass Water Agency (SGPWA). Verbenia GSA consists of Mission Springs WD and SGPWA. The SGP Subbasin GSAs are not required to develop a Coordination Agreement. Despite this, the GSAs entered into a cooperative Memorandum of Agreement for development of the GSP and grant funding. The three GSAs have cooperatively worked together to coordinate SGP GSP development. The SGP Subbasin includes a portion of an adjudicated area, known as the Beaumont Basin, that resides outside the Plan Area. Since it was previously adjudicated, the portion of the Beaumont Basin located in the SGP Subbasin is not subject to SGMA regulations.
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8.3.5 Santa Ana River Basin Plan
An updated Water Quality Control Plan for the Santa Ana River Basin (Basin Plan) was adopted by the Regional Board on March 11, 1994, approved by the State Water Resources Control Board (SWRCB) on July 21, 1994, and approved by the Office of Administrative Law (OAL) on January 24, 1995. The Basin Plan identifies the Region’s ground and surface waters, designates beneficial uses for those waters, establishes water quality objectives for the protection of those uses, prescribes implementation plans and establishes monitoring and surveillance programs to assess implementation efforts. Amendments to the Basin Plan to incorporate a revised Total Dissolved Solids and Nitrogen Management Plan (Salt Management Plan) into the 1995 Basin Plan were approved by the Regional Board on January 22, 2004, by the State Water Resources Control Board on October 1, 2004 and by the Office of Administrative Law on December 23, 2004. The surface water standards provisions of the amendments were approved by the U.S. Environmental Protection Agency on January 20, 2007. This amendment included revised groundwater subbasin boundaries (now called management zones), revised TDS and nitrate-nitrogen (nitrate-N) groundwater quality objectives, revised TDS and nitrogen waste load allocations, revised reach designations, and revised TDS and nitrogen objectives and beneficial uses for specific surface waters.

Antidegradation water quality objectives set forth by the Basin Plan amendment restricted the use of recycled water for irrigation and groundwater recharge for certain groundwater management zones, including the Beaumont Management Zone (BMZ) and the San Timoteo Management Zone (STMZ). In particular, the ambient TDS concentrations of these management zones exceeded the antidegradation objectives, meaning that no assimilative capacity existed for which the Regional Board could allocate the use of the City’s recycled water within the BMZ or STMZ. Under the antidegradation objectives, the use of recycled water would require mitigation even though the reuse would not materially impact future TDS concentrations or impair beneficial uses. Thus, alternative maximum-benefit objectives were specified for the BMZ and the STMZ. The maximum-benefit objectives were established based on demonstrations by the involved agencies that antidegradation policies were satisfied.

Discharge of recycled water over the BMZ by the City of Banning as a result of the project will be in full adherence to the requirements set forth in the Basin Plan.

Discussion of Need for Multi-Jurisdictional or Interagency Agreements As the sole retail supplier of water in the service area, and the agency responsible for wastewater processing, the City of Banning is able to produce recycled water for distribution within its service area without agreements with any other agency.

Discussion of Permitting Procedures Required
The following permits will be required for the Project:

1. DDW Title 22 Permit
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2. California State Water Resources Control Board General Permit (combining NonDischarge National Pollutant Discharge Elimination System [NPDES], Waste Discharge Requirement [WDR], and Waste Recharge Requirements [WRR])

3. AQMD

4. CEQA (IS-MND)
A Title 22 Engineering Report is required to be submitted for approval by DDW for meeting water quality requirements of the treated recycled water and groundwater recharge requirements.

After the WWTP’s design documents are finalized, the City will submit the necessary reports, analyses, and applications to obtain required permits from both DDW and the RWQCB.

As described in Section 7, the City will prepare a Negative Declaration to obtain CEQA coverage for the Project in parallel with Project design.

Discussion of Unresolved Issues Associated with Implementing Proposed Project There are no unresolved issues associated with implementing the proposed project.

Identification of Current and Proposed Discharge Requirements The current discharge requirements for the WWTP are laid out in the RWQCB Board Order, which describes the WDRs and other terms and conditions of operation for the WWTP.

The Board Order can be found in Appendix G.

Rights to Wastewater Discharges
The City’s rights to groundwater extraction are in Table 5 in Section 2.3.

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9. FINANCIAL CAPABILITY OF SPONSOR
Introduction
The City has developed an implementation schedule and general funding plan that demonstrates that at the Feasibility Study stage, the City has the financial capability if the project moves to construction.

Schedule
The proposed schedule for the Project includes three phases, however only Phase I will be implemented in the near term. In Phase I, the RO system for Well NP-1 and WWTP upgrades will be installed, as well as the recycled water laterals for Banning High School, Dysart Park, and Lions Park.

The preliminary and final design of Phase I is expected to be completed by the 2nd quarter of 2026. Design includes initiating the necessary permits, completing CEQA/NEPA documentation, completing design, going out to bid, obtaining the authority to award the construction contracts, awarding contracts, and issuing notices to proceed.

The first step of construction for Phase I will be installing the Well NP-1 upgrades, including the RO system and brine evaporation ponds, and WWTP upgrades, including the new MBR facility, primary clarifier, chlorine tank, and lab and control building. Once easements have been obtained for the recycled water laterals, construction of the laterals will occur in parallel with construction of the WWTP upgrades. Development and testing of the new facilities will follow. Phase I is estimated to be completed in 3 years by the 4th Quarter of 2027, as shown in Table 22 on the following page.
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Table 22. Project Schedule – Phase 1
2024 2025 2026 2027
Project Component Duration Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Well NP-1 RO System and Brine Evaporation
Ponds
12 months
Predesign 3 months
Final design 3 months
Bidding 3 months
Construction/startup 3 months
WWTP Upgrades 33 months
Predesign 6 months
Final design 6 months
Bidding 3 months
Construction/startup 18 months
Recycled Water Laterals 24 months
Easements 6 months
Bidding 3 months
Design 6 months
Construction/development 6 months
Testing 3 months
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Willingness and Capability of the City of Banning to Fund the Project The Project will be funded through the City's capital replacement and operating budgets, as well as development activity revenues via the City’s local development impact fee program. The City also has the capability to fund projects through debt issuance.

Project Funding Plan

9.4.1 Operating Budgets
The City owns and manages both a water utility and wastewater utility as individual selfsupporting enterprises. Therefore, the utilities must develop financial plans that provide sufficient revenues to meet all operation and maintenance expenses, water purchases, wastewater treatment, debt service requirements, capital improvements funded from current revenues, and other expenditures.

In 2022, the City Council of the City of Banning approved a Water and Wastewater Rate Study (Rate Study). The Rate Study developed financial plans that projected operating revenue, expenses, and capital financing costs for the utilities over a five-year planning period beginning July 1, 2022 and ending June 30, 2027. The financial plans projected future rate revenues under existing rates, operation and maintenance (O&M) expenses, principal and interest expense on debt, transfers, and capital improvement program (CIP) requirements.

For the water utility, the Rate Study identified:
- Operation and Maintenance Expenses: The O&M expenses increase from $7.9M in FY 2023 to $10.0M in FY 2027.
- Debt Service: There is an existing revenue bond with an annual payment of $2.0M.

There is no future debt planned.
- Capital Improvements: The CIP identified an average of $6.2M per year in capital projects from FY 2023 to FY 2027.
- Reserves: Continue to maintain the operating fund reserve level. The operating fund reserve is designed to help cover fluctuations in day-to-day expenses. The new target, consistent with industry reserve guidelines, will be 90 days of O&M expenses, a change from the existing 10% of O&M expenses and debt service payments.

For the wastewater utility, the Rate Study identified:
- Operation and Maintenance Expenses: The O&M expenses increase from $3.7M in FY 2023 to $4.6M in FY 2027; increases in cost to operate and maintain the proposed Wastewater Treatment Plant and Recycled Water Upgrades Project are included as part of the Rate Study projections.
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- Debt Service: There is an existing revenue bond with an annual payment of $290k associated from a 2019 Refunding Revenue Bond. The City anticipates a net debt issuance of $25.0M in FY 2025, which will add an annual payment of $1.9M starting in FY 2025. The primary expense for the new debt issuance is for the Wastewater Treatment Plant and Recycled Water Upgrades Project. The Rate Study ensures the appropriate level of debt service coverage.
- Capital Improvements: The CIP identified an average of $12.1M per year in capital projects from FY 2023 to FY 2027.
- Reserves: Continue to maintain the operating fund reserve level. The operating fund reserve is to help cover fluctuations in day-to-day expenses. The scheduled target will be 90 days of O&M expenses, a change from the existing 10% of O&M expenses and debt service payment.

The revenue requirements listed above for the water and wastewater utilities set the basis for the development of suitable rate schedules to produce revenues adequate to meet financial needs while recognizing customer costs of service. In November of 2022, City Council held a public hearing resulting the approval of the rate increases for a period of five years as shown in Table 23.

Table 23. Rate Increases
Fiscal Year Effective Month Water Utility Wastewater Utility FY 2022-2023 January 10.75% 40.00%
FY 2023-2024 July 0.00% 25.00%
FY 2023-2024 January 10.75% 25.00%
FY 2024-2025 January 10.75% 3.00%
FY 2025-2026 January 10.75% 3.00%
FY 2026-2027 January 10.75% 3.00%
There is a current fund balance in the Water Operations Fund of $17.5M and a fund balance in the Wastewater Operations Fund of $3.7M.

In addition to operating and capital revenues related to rates, the City has continued to charge a monthly Tertiary Surcharge of $2.72/month per account to fund capital improvements at the wastewater treatment plant. The Wastewater Tertiary Fund has a fund balance of $7.7M of which $7M would be allocated to the Proposed Project.

Additionally, the City has the capability to fund projects through either cash payment or debt issuance.

9.4.2 Development Impact Fees
In 2018 the City Council of the City of Banning completed and approved an Integrated Master 1217
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Plan (2018 IMP) that evaluated the performance and condition of the City’s potable water, wastewater and recycled water system (future) systems under current and future conditions through year 2040. The 2018 IMP includes a capital improvement plan (CIP) to guide the City in the planning and development of facilities required to meet system performance for existing and future customers.

In September 2019, the City Council approved new and updated the development impact fees, including impacts fees to cover the costs for water, recycled water, and wastewater facilities.

The Water Impact Fee fund balance is approximately $3.3M of which $1.5M would be allocated to the Proposed Project.

The Wastewater Impact Fee fund balance is approximately $10.8M of which $7.5M would be allocated to the Proposed Project.

The City of Banning is currently witnessing a significant amount of growth in the residential sector. It is expected the available funding in the utility impact fee funds will continue to increase allowing for additional allocations to the Proposed Project.

The City has the capability to fund projects through either cash payment or debt issuance.

Over time, staff will present updated rate studies to City Council in order to ensure that rate revenues are sufficient to cover ongoing operations, maintenance, replacement costs and debt service coverage obligations.

Other Funding Sources
The City is also considering, as possible funding sources, the Water Infrastructure Finance Innovation Act (WIFIA) and Clean Water State Revolving Fund (CWSRF).

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10. RESEARCH NEEDS
The proposed water reclamation Project includes basic research needs and will solely use proven technologies and conventional system components. Further research to implement the proposed water reclamation project will not be necessary.

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11. REFERENCES
Carollo Engineers, Inc. 2006 Recycled Water Master Plan. 2006.

Carollo Engineers, Inc. 2018 Integrated Master Plan. March 2018.

West Yost & Associates Engineering, Inc. and John Robinson Consulting, Inc. 2020 Urban Water Management. June 2021.
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Appendix C – 50-Year Lifecycle Costs
1221
Lifecycle Costs for Proposed Project
Inflation 3.75%
Discount Rate (Nominal) 5.00%
Capital Labor Power Chemicals
Spare Parts /
Replacements
RO Membrane
Replacement and MBR
Membrane
Replacement Total Cost
2028 $ 64,778,302 $ 1,242,000 $ 1,577,600 $ 33,750 $ 326,475 $ - $ 67,958,127 2029 $ - $ 1,288,575 $ 1,636,760 $ 35,016 $ 338,718 $ - $ 3,299,068 2030 $ - $ 1,336,897 $ 1,698,139 $ 36,329 $ 351,420 $ - $ 3,422,784 2031 $ - $ 1,387,030 $ 1,761,819 $ 37,691 $ 364,598 $ - $ 3,551,138 2032 $ - $ 1,439,044 $ 1,827,887 $ 39,104 $ 378,270 $ - $ 3,684,306 2033 $ - $ 1,493,008 $ 1,896,433 $ 40,571 $ 392,456 $ 2,644,620 $ 6,467,087 2034 $ - $ 1,548,996 $ 1,967,549 $ 42,092 $ 407,173 $ - $ 3,965,810 2035 $ - $ 1,607,083 $ 2,041,332 $ 43,671 $ 422,442 $ - $ 4,114,527 2036 $ - $ 1,667,349 $ 2,117,882 $ 45,308 $ 438,283 $ - $ 4,268,822 2037 $ - $ 1,729,874 $ 2,197,302 $ 47,007 $ 454,719 $ - $ 4,428,903 2038 $ - $ 1,794,745 $ 2,279,701 $ 48,770 $ 471,771 $ 3,179,097 $ 7,774,084 2039 $ - $ 1,862,047 $ 2,365,190 $ 50,599 $ 489,462 $ - $ 4,767,299 2040 $ - $ 1,931,874 $ 2,453,885 $ 52,497 $ 507,817 $ - $ 4,946,073 2041 $ - $ 2,004,320 $ 2,545,905 $ 54,465 $ 526,860 $ - $ 5,131,550 2042 $ - $ 2,079,482 $ 2,641,377 $ 56,508 $ 546,617 $ - $ 5,323,983 2043 $ - $ 2,157,462 $ 2,740,429 $ 58,627 $ 567,115 $ 3,821,591 $ 9,345,224 2044 $ - $ 2,238,367 $ 2,843,195 $ 60,825 $ 588,382 $ - $ 5,730,769 2045 $ - $ 2,322,306 $ 2,949,814 $ 63,106 $ 610,447 $ - $ 5,945,673 2046 $ - $ 2,409,392 $ 3,060,432 $ 65,473 $ 633,338 $ - $ 6,168,636 2047 $ - $ 2,499,744 $ 3,175,199 $ 67,928 $ 657,089 $ - $ 6,399,959 2048 $ - $ 2,593,485 $ 3,294,269 $ 70,475 $ 681,729 $ 4,593,934 $ 11,233,892 2049 $ - $ 2,690,740 $ 3,417,804 $ 73,118 $ 707,294 $ - $ 6,888,956 2050 $ - $ 2,791,643 $ 3,545,971 $ 75,860 $ 733,818 $ - $ 7,147,292 2051 $ - $ 2,896,330 $ 3,678,945 $ 78,705 $ 761,336 $ - $ 7,415,316 2052 $ - $ 3,004,942 $ 3,816,906 $ 81,656 $ 789,886 $ - $ 7,693,390 2053 $ - $ 3,117,628 $ 3,960,040 $ 84,718 $ 819,507 $ 5,522,368 $ 13,504,260 2054 $ - $ 3,234,539 $ 4,108,541 $ 87,895 $ 850,238 $ - $ 8,281,213 2055 $ - $ 3,355,834 $ 4,262,611 $ 91,191 $ 882,122 $ - $ 8,591,759 2056 $ - $ 3,481,678 $ 4,422,459 $ 94,611 $ 915,202 $ - $ 8,913,950 2057 $ - $ 3,612,240 $ 4,588,302 $ 98,159 $ 949,522 $ - $ 9,248,223 2058 $ - $ 3,747,699 $ 4,760,363 $ 101,840 $ 985,129 $ 6,638,437 $ 16,233,468 2059 $ - $ 3,888,238 $ 4,938,876 $ 105,659 $ 1,022,071 $ - $ 9,954,845 2060 $ - $ 4,034,047 $ 5,124,084 $ 109,621 $ 1,060,399 $ - $ 10,328,151 2061 $ - $ 4,185,324 $ 5,316,238 $ 113,732 $ 1,100,164 $ - $ 10,715,457 2062 $ - $ 4,342,274 $ 5,515,596 $ 117,997 $ 1,141,420 $ - $ 11,117,287 2063 $ - $ 4,505,109 $ 5,722,431 $ 122,421 $ 1,184,223 $ 7,980,064 $ 19,514,249 2064 $ - $ 4,674,050 $ 5,937,022 $ 127,012 $ 1,228,632 $ - $ 11,966,717 2065 $ - $ 4,849,327 $ 6,159,661 $ 131,775 $ 1,274,705 $ - $ 12,415,469 2066 $ - $ 5,031,177 $ 6,390,648 $ 136,717 $ 1,322,507 $ - $ 12,881,049 2067 $ - $ 5,219,846 $ 6,630,297 $ 141,844 $ 1,372,101 $ - $ 13,364,088 2068 $ - $ 5,415,590 $ 6,878,934 $ 147,163 $ 1,423,555 $ 9,592,833 $ 23,458,075 2069 $ - $ 5,618,675 $ 7,136,894 $ 152,681 $ 1,476,938 $ - $ 14,385,188 2070 $ - $ 5,829,375 $ 7,404,527 $ 158,407 $ 1,532,323 $ - $ 14,924,632 2071 $ - $ 6,047,977 $ 7,682,197 $ 164,347 $ 1,589,785 $ - $ 15,484,306 2072 $ - $ 6,274,776 $ 7,970,279 $ 170,510 $ 1,649,402 $ - $ 16,064,968 2073 $ - $ 6,510,080 $ 8,269,165 $ 176,904 $ 1,711,255 $ 11,531,543 $ 28,198,947 2074 $ - $ 6,754,208 $ 8,579,258 $ 183,538 $ 1,775,427 $ - $ 17,292,432 2075 $ - $ 7,007,491 $ 8,900,981 $ 190,421 $ 1,842,005 $ - $ 17,940,898 2076 $ - $ 7,270,272 $ 9,234,767 $ 197,562 $ 1,911,081 $ - $ 18,613,681 2077 $ - $ 7,542,907 $ 9,581,071 $ 204,970 $ 1,982,746 $ - $ 19,311,695 $ 569,777,671
$ 181,380,020
50-Year Future Cost
50-Year Present Cost
1222
Lifecycle Costs for Alternative 1
Inflation 3.75%
Discount Rate (Nominal) 5.00%
Capital Imported Water Cr6 Treatment Total Cost
2028 $ - $ 2,329,860 $ 927,000 $ 3,256,860
2029 $ - $ 2,417,230 $ 961,763 $ 3,378,992
2030 $ - $ 2,507,876 $ 997,829 $ 3,505,704
2031 $ - $ 2,601,921 $ 1,035,247 $ 3,637,168
2032 $ - $ 2,699,493 $ 1,074,069 $ 3,773,562
2033 $ - $ 2,800,724 $ 1,114,347 $ 3,915,071
2034 $ - $ 2,905,751 $ 1,156,135 $ 4,061,886
2035 $ - $ 3,014,717 $ 1,199,490 $ 4,214,207
2036 $ - $ 3,127,769 $ 1,244,470 $ 4,372,239
2037 $ - $ 3,245,060 $ 1,291,138 $ 4,536,198
2038 $ - $ 3,366,750 $ 1,339,556 $ 4,706,306
2039 $ - $ 3,493,003 $ 1,389,789 $ 4,882,792
2040 $ - $ 3,623,991 $ 1,441,906 $ 5,065,897
2041 $ - $ 3,759,890 $ 1,495,978 $ 5,255,868
2042 $ - $ 3,900,886 $ 1,552,077 $ 5,452,963
2043 $ - $ 4,047,170 $ 1,610,280 $ 5,657,449
2044 $ - $ 4,198,938 $ 1,670,665 $ 5,869,604
2045 $ - $ 4,356,399 $ 1,733,315 $ 6,089,714
2046 $ - $ 4,519,764 $ 1,798,314 $ 6,318,078
2047 $ - $ 4,689,255 $ 1,865,751 $ 6,555,006
2048 $ - $ 4,865,102 $ 1,935,717 $ 6,800,819
2049 $ - $ 5,047,543 $ 2,008,306 $ 7,055,849
2050 $ - $ 5,236,826 $ 2,083,618 $ 7,320,444
2051 $ - $ 5,433,207 $ 2,161,753 $ 7,594,960
2052 $ - $ 5,636,952 $ 2,242,819 $ 7,879,771
2053 $ - $ 5,848,338 $ 2,326,925 $ 8,175,263
2054 $ - $ 6,067,651 $ 2,414,185 $ 8,481,835
2055 $ - $ 6,295,188 $ 2,504,717 $ 8,799,904
2056 $ - $ 6,531,257 $ 2,598,643 $ 9,129,900
2057 $ - $ 6,776,179 $ 2,696,093 $ 9,472,272
2058 $ - $ 7,030,286 $ 2,797,196 $ 9,827,482
2059 $ - $ 7,293,922 $ 2,902,091 $ 10,196,012
2060 $ - $ 7,567,444 $ 3,010,919 $ 10,578,363
2061 $ - $ 7,851,223 $ 3,123,829 $ 10,975,052
2062 $ - $ 8,145,644 $ 3,240,972 $ 11,386,616
2063 $ - $ 8,451,105 $ 3,362,509 $ 11,813,614
2064 $ - $ 8,768,022 $ 3,488,603 $ 12,256,625
2065 $ - $ 9,096,823 $ 3,619,425 $ 12,716,248
2066 $ - $ 9,437,953 $ 3,755,154 $ 13,193,107
2067 $ - $ 9,791,877 $ 3,895,972 $ 13,687,849
2068 $ - $ 10,159,072 $ 4,042,071 $ 14,201,143
2069 $ - $ 10,540,037 $ 4,193,649 $ 14,733,686
2070 $ - $ 10,935,289 $ 4,350,911 $ 15,286,199
2071 $ - $ 11,345,362 $ 4,514,070 $ 15,859,432
2072 $ - $ 11,770,813 $ 4,683,347 $ 16,454,160
2073 $ - $ 12,212,219 $ 4,858,973 $ 17,071,191
2074 $ - $ 12,670,177 $ 5,041,184 $ 17,711,361
2075 $ - $ 13,145,308 $ 5,230,229 $ 18,375,537
2076 $ - $ 13,638,257 $ 5,426,362 $ 19,064,620
2077 $ - $ 14,149,692 $ 5,629,851 $ 19,779,543
$ 460,384,424
$ 111,796,439
50-Year Future Cost
50-Year Present Cost
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CRITICAL WASTEWATER TREATMENT RECYCLED WATER UPGRADES
Appendix D – Letters of Support

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December 6, 2023
Ms. Camille Touton
Commissioner
Bureau of Reclamation
1849 C Street NW
Washington, D.C. 20240-0001
RE: Support for the City of Banning’s Application for its Wastewater Treatment Plant and Recycled Water Upgrades Project
Dear Commissioner Touton:

I write in support of the City of Banning, a Disadvantaged Community, and its application for funding from the WaterSMART grant program for Water Reclamation and Reuse Projects, administered through the United States Bureau of Reclamation.

The City of Banning is requesting funding for its Wastewater Treatment Plant and Recycled Water Upgrades Project, which would produce recycled water for irrigation customers and reduce the City’s reliance on imported water. Upgrading the treatment plant will go a long way to help increase the City’s water supply independence and protect the integrity of the local groundwater sources that the City relies on.

If awarded funding, the City will implement a Membrane Bioreactor, chlorine disinfection, and two-stage reverse osmosis system at the Wastewater Treatment Plant to produce tertiary disinfected recycled water.

This supply of recycled water will improve the reliability of local water supplies, decrease dependence on outside water sources, and ensure that the City of Banning is better prepared for future water supply challenges.

For these reasons, I fully support the City of Banning’s application. If you have any questions, please do not hesitate to contact my District Office at (909) 335-0271.

Sincerely,

ROSILICIE OCHOA BOGH
Senator, 23rd District
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U.S. SENATOR LAPHONZA BUTLER COMMITTEE ON THE JUDICIARY

CALIFORNIA - CHAIR, SUBCOMMITTEE ON THE CONSTITUTION

COMMITTEE ON BANKING, HOUSING, AND URBAN AFFAIRS

COMMITTEE ON HOMELAND SECURITY AND

GOVERNMENTAL AFFAIRS

COMMITTEE ON RULES AND ADMINISTRATION
December 6, 2023
The Honorable Camille Touton
Commissioner
Bureau of Reclamation
1849 C Street, N.W.

Washington, D.C. 20240
Dear Commissioner Touton,
I write in support of the City of Banning’s application for funding from the WaterSMART Grant Program: Title XVI WIIN Act Water Reclamation and Reuse Projects, administered by the Bureau of Reclamation, U.S. Department of Interior.

The City of Banning is requesting funding for its Wastewater Treatment Plant and Recycled Water Upgrades project. Home to approximately 29,500 residents, the City of Banning is situated in the San Gorgonio Pass region of Riverside County and is identified as a disadvantaged community by the Council for Environmental Quality’s Climate and Economic Justice Screening Tool. The city’s wastewater treatment plant currently provides for the collection, treatment, and disposal of municipal sewage.

If awarded, this grant would enable the City of Banning to make upgrades to its existing wastewater treatment plant to produce recycled water for irrigation customers, thereby reducing reliance on imported water. Specifically, the project would implement a Membrane Bioreactor, chlorine disinfection, and a two-stage reverse osmosis system at the wastewater treatment plant to produce tertiary disinfected recycled water. These improvements would improve the reliability of local water supplies and decrease dependence on imported water resources, ensuring that the disadvantaged residents of Banning and the greater Inland Empire region are better prepared for future water supply challenges.

I urge you to give the City of Banning’s application every consideration. Please keep my office informed of the status of this request, and if I can be of further assistance, please do not hesitate to contact my Los Angeles office at (310) 914-7300.

Sincerely,
A
Laphonza Butler
United States Senator
1226
The Honorable Camille Calimlim Touton
Commissioner
U.S. Bureau of Reclamation
1849 C Street NW
Washington, D.C. 20240
Dear Commissioner Touton:

I write in support of the City of Banning and their application for WaterSMART Water Reclamation and Reuse Projects grant funding administered through the United States Bureau of Reclamation. If awarded, this funding would upgrade the city’s treatment plant and help to increase the city’s water supply independence in Banning, California.

The City of Banning’s Wastewater Treatment Plant and Recycled Water Upgrades Project would enable the city to produce recycled water for irrigation customers, thereby reducing its reliance on imported water. The grant funding would also allow the city to implement a membrane bioreactor, chlorine disinfection, and two-stage reverse osmosis system at the Wastewater Treatment Plant to produce tertiary disinfected recycled water. This increased water supply will benefit my constituents while promoting resiliency against future droughts that may affect Southern California.

As the Representative of California’s 25th Congressional District, I understand the impact that the City of Banning’s water recycling projects and water supply independence would have on the lives of the individuals I serve and represent. Efforts to reclaim water, like the innovative recycled water projects that the City of Banning proposes, would improve the reliability of local water supplies, decrease dependence on imported water sources, and ensure that the City of Banning is better prepared for future water supply challenges. Addressing drought impacts and working towards alternative sources of water are essential to fortifying the region’s water infrastructure to withstand the increasingly evident effects of climate change.

The City of Banning is a disadvantaged community in my district. The city is home to over 30,000 individuals and in desperate need of environmentally responsible ways to increase water supply independence as the demand grows greater. For this reason, I believe the city has the RAUL RUIZ, M.D.

Member of Congress
25th District of California
Washington, D.C. Office:
2342 Rayburn House
Office Building
Washington, D.C. 20515
Phone: 202-225-5330
November 29, 2023
1227
capacity to successfully implement the Wastewater Treatment Plant and Recycled Water Upgrades Project, and I urge full and fair consideration, consistent with all relevant program rules and regulations. If you have any additional questions, please feel free to contact my Washington, D.C. office at (202) 225-5330.

Sincerely,
Raul Ruiz, M.D.

Member of Congress
1228
1229
1230
1231

BANNING, CA

CRITICAL WASTEWATER TREATMENT RECYCLED WATER UPGRADES
Appendix E – Authorizing Resolution
1232
Resolution 2024-XX

RESOLUTION 2024-XX

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF BANNING, CALIFORNIA, AUTHORIZING THE SUBMITTAL OF A WATERSMART: TITLE XVI WIIN ACT WATER RECLAMATION AND REUSE PROJECTS FOR FISCAL YEARS 2023 AND 2024 AND

AUTHORIZING THE CITY MANAGER OR DESIGNEE TO SIGN AND SUBMIT ALL

REQUIRED DOCUMENTS RELATED TO THE GRANT APPLICATION
WHEREAS, the United States Bureau of Reclamation (USBR) is soliciting applications for authorized projects for WaterSMART: Title XVI WIIN Act Water Reclamation and Reuse Projects for Fiscal Years 2023 and 2024 per Funding Opportunity Announcement No. R23AS00464; and
WHEREAS, the City of Banning will be upgrading its Wastewater Treatment Plant (WWTP), also known as the Water Reclamation Facility, to reduce the City’s reliance on imported water and to keep groundwater recharge within the City’s wells.

WHEREAS, the City desires to improve the WWTP in order to treat its wastewater and produce recycled water; and
WHEREAS, the City of Banning is seeking grant funding to further fund the design/build construction of the Project; and
WHEREAS, the City of Banning prepared a grant application under this Program for Fiscal Years 2023 and 2024 with an application submitted on September 30, 2024.

WHEREAS, USBR has directed applicants to include in its application an official resolution adopted by the applicant's board of directors or governing body verifying 1) the identity of the official with legal authority to enter into an agreement, 2) the board of directors, governing body, or appropriate official who has reviewed and supports the application submitted, 3) the capability of the applicant to provide the amount of funding and/or in-kind contributions specified in the funding plan, and 4) that the applicant will work with Reclamation to meet established deadlines for entering into a grant or cooperative agreement.

NOW, THEREFORE, the City Council of the City of Banning does resolve as follows:

1. The City Manager, or his designee, is authorized to submit all required information to the United States Bureau of Reclamation (USBR) to obtain a USBR WaterSMART: Title XVI WIIN Act Water Reclamation and Reuse Projects for Fiscal Years 2023 and 2024 per Funding Opportunity Announcement No. R23AS00464 for and on behalf of the City.

NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Banning as follows:
1233
Resolution 2024-XX

SECTION 1. The City Council has reviewed and supports the application for USBR Funding Opportunities R23AS00464 submitted by the 30
th day of September 2024; and
SECTION 2. The City of Banning is able to provide the minimum 75% funding match specified in the funding plan for both applications.

SECTION 3. The City Manager, or his designee, is hereby authorized and directed to prepare the necessary data, conduct investigations, file such applications, and execute grant agreements with the USBR in association with this application process. The City of Banning will work with the USBR to meet established deadlines required for entering into a cooperative agreement to obtain the aforementioned grant funding.

SECTION 4. The City Council hereby authorizes the City Manager, or his designee, to sign and file a Financial Assistance Application for grant agreement from USBR WaterSMART: Title XVI WIIN Act Water Reclamation and Reuse Projects for Fiscal Years 2023 and 2024 per Funding Opportunity Announcement No. R23AS00464 for and on behalf of the City.

SECTION 5. The City Manager, or his designee, is authorized to represent the City in carrying out the City's responsibilities under the grants agreement, including certifying disbursement requests on behalf of the City and compliance with applicable state and federal laws.

SECTION 6. The City Manager, or his designee, is authorized to make necessary budget adjustments, appropriations and transfers related to the Financial Assistance Application for grant agreement from USBR.

SECTION 7. The City Clerk shall certify the adoption of this resolution and shall cause a certified resolution to be filed in the book of original resolutions.

1234
Resolution 2024-XX

PASSED, APPROVED AND ADOPTED this XX day of XX 2024
/

Alberto Sanchez, Mayor
City of Banning
ATTEST:

Caroline Patton, Deputy City Clerk
City of Banning
APPROVED AS TO FORM AND CONTENT:

Serita R. Young, City Attorney Richards,
Watson & Gershon·
1235
Resolution 2024-XX

CERTIFICATION:

I, Caroline Patton, Deputy City Clerk of the City of Banning, California, do hereby certify that the foregoing Resolution 2024-XX, was duly adopted by the City Council of the City of Banning, California, at a regular meeting thereof held on the XX day of XX 2024 by the following vote, to wit:

AYES:

NOES:

ABSENT:

ABSTAIN:

Caroline Patton, Deputy City Clerk City
of Banning, California
1236
LC-10100 January 14, 2025

1.3.11 VIA ELECTRONIC MAIL
City of Banning
Attn: Mr. Art Vela
Director of Public Works
99 E. Ramsey St.

Banning, CA 92220
Subject: Notice of Funding Opportunity No. R23AS00464 – WaterSMART: Title XVI Water Infrastructure Improvements for the Nation (WIIN) Act Water Reclamation and Reuse Projects – Your Application Titled, “Critical Wastewater Treatment Recycled Water Upgrades”
Dear Mr. Art Vela:

The Bureau of Reclamation (Reclamation) is pleased to inform you that your application, submitted by the second application due date of September 30, 2024, for the WaterSMART: Title XVI WIIN Act Water Reclamation and Reuse Projects Funding Opportunity was among those receiving the highest ratings and is now being considered for award with funding available under the Bipartisan Infrastructure Law (BIL), P.L. 117-58. Reclamation anticipates awarding Federal funds in the amount of $16,194,576 for your project.

In working with you to develop your financial assistance agreement, Reclamation will closely review the activities outlined in your proposal to ensure that activities eligible for funding are identified and that the proposed costs are allowable under financial assistance regulations and the Notice of Funding Opportunity (NOFO). If some costs or activities are determined to be ineligible or unallowable, Reclamation will work with you to refine the scope of work and budget for the project. In addition, Reclamation must have sufficient evidence prior to award that non-Federal cost share will be available.

The final funding amount may be adjusted if necessary. Please note that a small portion of this amount may be set aside for Reclamation to ensure the project’s Federal regulatory and statutory compliance, and to otherwise oversee the implementation of the project.

All new financial assistance awards for infrastructure projects must meet Buy America requirements.

Office of Management and Budget (OMB) implementing guidance states that the Buy America provisions apply to projects carried out through Bipartisan Infrastructure Law (BIL) funding and annual appropriations. See OMB Memorandum M-22-11 for further details. Section 41101 of the BIL requires that all laborers and mechanics employed by contractors or subcontractor in the performance of construction, alteration, or repair work on a project assisted in whole or in part by funding made available under the BIL shall be paid wages at rates not less than those prevailing on similar projects in 1237
2 the locality, as determined by the Secretary of Labor in accordance with Subchapter IV of Chapter 31 of Title 40, United States Code (commonly referred to as the Davis-Bacon Act).

All projects being considered for award of funding are required to comply with all Federal environmental and cultural resource requirements, including the National Environmental Policy Act, Endangered Species Act, Clean Water Act, and the National Historic Preservation Act. Grounddisturbing activities of any type, including fieldwork, monitoring or other activities may not occur until Reclamation has determined that all environmental and cultural resource compliance is complete.

In addition, funding for construction activities will not be released until Reclamation makes a determination of financial capability for the project.

The Reclamation regional or area office that will be responsible for awarding and administering your agreement will contact you in the coming months to finalize your award. In the meantime, if you have any questions regarding the process or your agreement, please contact Viranousack (Alex) Soubannarath, Lower Colorado Basin Regional Title XVI Coordinator, at (951) 695-5310 or [email protected].

Thank you for your interest and participation in the WaterSMART: Water Recycling and Desalination Programs. The success of the Title XVI Program depends on collaboration with partners to improve the reliability of water supplies.

Sincerely,

/s/ Diana Blake
Grants Officer
1238

CITY OF BANNING

STAFF REPORT
TO: CITY COUNCIL
FROM: Douglas Schulze, City Manager
PREPARED BY: Art Vela, Director of Public Works
MEETING DATE: December 13, 2022
SUBJECT: Consideration of Resolution 2022-14UA, Awarding a Professional Services Agreement to N2W Engineering to
Provide Owner Advisor Services and Preliminary Engineering for the Wastewater Treatment Plant Improvement Project in a Not-to-Exceed Amount of $1,576,430
RECOMMENDATION:

Staff recommend that the City Council adopt Resolution 2022-14UA:

1. Awarding a Professional Services Agreement to N2W Engineering to provide Owner Advisor services for the Wastewater Treatment Plant Improvement project in the “not-to-exceed” amount of $1,576,430.

2. Authorizing the City Manager or his designee to make necessary budget adjustments, appropriations and transfers related to the Professional Services Agreement with N2W Engineering for Owner Advisor services.

3. Authorizing the City Manager or his designee to execute the Professional Services Agreement with N2W Engineering of Irvine, California in the “not to exceed” amount of $1,576,430.

BACKGROUND:

Wastewater Treatment Plant
The City of Banning Wastewater Treatment Plant (WWTP), also known as the Water Reclamation Facility, provides for the collection, treatment, and disposal of municipal sewage. The WWTP dates back to 1925 and began to see significant additions beginning in 1950’s and the last major renovation occurring in the early 2000’s. Currently, the WWTP treatment process consists of preliminary, primary, secondary, disinfection (currently not in use), and sludge disposal.

The WWTP has a design treatment capacity of 3.6 million gallons per day (MGD) and typical average daily discharges range from 2.0 MGD to 2.1 MGD into 10 unlined evaporation/percolation ponds. The treated effluent then percolates into the groundwater of the San Gorgonio Hydraulic Unit. Groundwater from this basin is used for municipal and industrial applications.
1239
Staff Report: Resolution 2022-14UA Owner Advisor Services December 13, 2022

In 2007, the City contracted Parsons to evaluate treatment technologies for a 1.5 MGD water reclamation facility (WRF) for the production of recycled water. Treatment alternatives investigated included oxidation ditch (OD), conventional activated sludge (CAS), and membrane bioreactor (MBR). The purpose of the evaluation was to determine the best option to comply with future Title 22 requirements for the beneficial reuse of recycled water. Parsons determined an MBR system was the best treatment option and completed a 90% design package of the WRF. Unfortunately, the project never reached 100% design and was terminated for various reasons.
2016 Regional Water Quality Control Board Order
On June 30, 2016, the California Regional Water Quality Control Board, Colorado River Basin Region (RWQCB) adopted Board Order R7-2016-0015 (Board Order), which describes the Waste Discharge Requirements (WDRs) and other terms and conditions of operation for the City’s WWTP. The Board Order requires the WWTP to remove constituents that present the greatest risk to groundwater quality such as nitrogen, coliforms, and total dissolved solids (TDS).

According to the United States Environmental Protection Agency (US EPA), the maximum contaminant level (MCL) for Nitrate as Nitrogen (TN) is 10 mg/L. Currently, the average TN concentration in the WWTP’s effluent is 29 mg-N/L, well above the future TN limit of 10 mg-N/L specified in the Board Order.

As a result, the Board Order required the City to conduct a nitrogen removal analysis and to summarize the findings in a technical report that includes a tentative work plan and time schedule for the installation and implementation of nitrogen removal treatment alternatives. The final technical report (Nitrogen Removal Feasibility Study), attached hereto, was completed and submitted to the RWQCB by the due date of June 30, 2020.

The City has had plans for the development of a Title 22 compliant recycled water source dating back to the early 2000’s and for this reason, the scope of the Nitrogen Removal Feasibility Study was expanded beyond complying with TN limits and included discharge requirements related to the use of recycled water.

Additionally, the Board Order requires that the City submit a plan for capacity improvements to the RWQCB once the WWTP reaches 80% of its design capacity, or

2.88 MGD.
2018 Integrated Master Plan
In 2016 the Public Works Department set out to develop new master plans for the City’s water, wastewater and future recycled water systems, which were previously updated in 2006. The final document resulted in a combined plan titled the Integrated Master Plan (IMP). The objective of the IMP was to develop capital improvement plans that would guide the City in the planning and development of water, wastewater and recycled water system facilities to meet system performance for existing customers as well as to support anticipated demands through the City’s buildout.
1240
Staff Report: Resolution 2022-14UA Owner Advisor Services December 13, 2022

The IMP projected that the City would reach 80% capacity by 2025 (although could be later if development slows down) and have a buildout wastewater flow of 6.35 MGD. 2020 UWMP
On June 8, 2021 the City Council approved Resolution 2021-50, adopting the 2020 Urban Water Management Plan (UWMP). The UWMP is a planning document with a 20-year planning horizon that assess the water supply and water demand for the City. As part of the assessment all current water supplies and in the future water supplies are include as part of the City’s water supply portfolio, which includes the use of recycled water to supplement potable demands (i.e. irrigation demands) and for groundwater recharge.

Owner Advisor
Staff determined that to comply with the Board Order; to increase treatment capacity at the WWTP to support development; and to add to the City’s water supply portfolio by developing a recycled water source, the City would need to move forward with major improvements to the WWTP. Current staffing levels would make it challenging to successfully complete such a large capital project in a timely manner. For that reason, staff developed a Request for Qualifications to hire an Owner Advisor (OA) which would be dedicated to the project.

An OA is typically a design and/or construction consultant or consulting firm that has extensive knowledge in the specific type of project being represented. The OA, generally, is responsible for project execution including the management of communications, time, cost, quality, risk, procurement, design, construction, and acceptance.

On July 21, 2022 the City released the attached RFQ on the OpenGov ProcureNow platform as well as sent to several qualified consulting firms. Qualification submittals were due on August 15, 2022. The RFQ was downloaded 30 times from ProcureNow. As a result of the of the RFQ solicitation the City received only one submittal from N2W Engineering. An evaluation committee reviewed the qualifications of N2W Engineering and agreed that they were qualified and experienced and subsequently an interview was conducted on October 4, 2022.

Following the interview staff worked with N2W Engineering to define the scope of work and negotiated a fee for said scope, attached hereto.

It is staff’s recommendation that City Council award a Professional Services Agreement to N2W Engineering, based on qualifications and fee statement. If approved, the term of the Professional Services Agreement is estimated to extend to fiscal year 2026/2027.

JUSTIFICATION:

Based on current and future wastewater regulatory requirements, implementation of the Integrated Master Plan and the City’s strategy for developing a robust water supply portfolio, it is necessary to move forward with the improvements to the City’s WWTP. Due 1241
Staff Report: Resolution 2022-14UA Owner Advisor Services December 13, 2022

to current staff resource and size and complexity of the WWTP project, it is recommended by staff to hire an Owner Advisor to move the WWTP project forward.

City staff evaluated N2W Engineering’s experience and qualifications and interviewed the firm for the WWTP project and subsequently have found them as a qualified firm to represent the City as its Owner Advisor.

FISCAL IMPACT:

The negotiated fee for the identified scope of work is in the amount of $1,576,430.

The funding for this project was programmed in the approved 5-year Capital Improvement Plan (CIP) as follows:

Account Project Desc. FY 2023 FY 2024 FY 2025
680-8000-454.90-10 WWTP Owner Advisor $100,000 $100,000 $100,000 680-8000-454.95-12 WWTP Upgrades $130,000 $130,000 $130,000 681-8000-454.95-12 WWTP Upgrades $130,000 $650,000 $650,000 Total $360,000 $880,000 $880,000
An appropriation from Fund 680 (Wastewater Fund) and Fund 681 (Wastewater Capital Facilty Fund) fund balances will be required to allocate the needed funds in FY 2023. The appropriation would be offset by reducing/eliminating the expenditures in FY 2024 and FY 2025 as shown in the table above. The revised CIP table will be as follows:

Account Project Desc. FY 2023 FY 2024 FY 2025
680-8000-454.90-10 WWTP Owner Advisor $300,000 $0 $0
680-8000-454.95-12 WWTP Upgrades $390,000 $0 $0
681-8000-454.95-12 WWTP Upgrades $886,430 $0 $543,570
Total $1,576,430 $0 $543,570
In summary, appropriations in the amount of $460,000 from Fund 680 and $756,430 from Fund 681 are required to fund the Professional Services Agreement with N2W Engineering.

ALTERNATIVES:

1. Approve as presented.

2. Approve with modifications.

3. Do not approve Resolution 2022-14UA and provide alternate direction to staff.

ATTACHMENTS:

1. Resolution 2022-14UA
https://banningca.gov/DocumentCenter/View/11872/Att-1-Resolution-2022-14-UAOA-WWTP 1242
Staff Report: Resolution 2022-14UA Owner Advisor Services December 13, 2022

2. Nitrogen Removal Feasibility Study
https://banningca.gov/DocumentCenter/View/11873/Att-2-Banning-Nitrogen-RemovalFeasibility-Study-FINAL-REV-1-STAMPED

3. Request for Qualifications
https://banningca.gov/DocumentCenter/View/11874/Att-3-RFQ-22-019-OwnerAdvisor-COB-WaterWasterwater

4. Statement of Qualifications
https://banningca.gov/DocumentCenter/View/11868/Att-4-Statement_of_Qualifications

5. Scope of Services
https://banningca.gov/DocumentCenter/View/11869/Att-5-Scope_of_Services-11-22- 2022

6. Fee Statement
https://banningca.gov/DocumentCenter/View/11870/Att-6-Fee-11-22-2022

7. Draft Professional Services Agreement
https://banningca.gov/DocumentCenter/View/11871/Att-7-C00778-N2W-EngineeringInc Approved by:

Douglas Schulze
City Manager
1243

CITY OF BANNING

STAFF REPORT
TO: CITY COUNCIL
FROM: Robert Fisher, Acting City Manager
PREPARED BY: Shah Nawaz, Deputy Water/Wastewater Director Art Vela, Director of Public Works
MEETING DATE: February 25, 2025
SUBJECT: Consideration of Resolution 2025-30, Awarding a Progressive DesignBuild Agreement for Phase 1 to AECOM Lyles JV for Project No. 2022- 01W “Wastewater Treatment Plant and Recycled Water Upgrades” in the Amount of $3,998,627, and Approving a 10% Contingency for a Total Project Budget of $4,398,490
RECOMMENDATION:

Adopt Resolution 2025-30.

BACKGROUND:

Wastewater Treatment Plant
The City of Banning Wastewater Treatment Plant (WWTP), also known as the Water Reclamation Facility, provides for the collection, treatment, and disposal of municipal sewage. The WWTP dates back to 1925 and began to see significant additions beginning in 1950’s and the last major renovation occurring in the early 2000’s. Currently, the WWTP treatment process consists of preliminary, primary, secondary, disinfection (currently not in use), and sludge disposal.

The WWTP has a design treatment capacity of 3.6 million gallons per day (MGD) and typical average daily discharges range from 2.0 MGD to 2.1 MGD into 10 unlined evaporation/percolation ponds. The treated effluent then percolates into the groundwater of the San Gorgonio Hydraulic Unit. Groundwater from this basin is used for municipal and industrial applications.

In 2007, the City contracted Parsons to evaluate treatment technologies for a 1.5 MGD water reclamation facility (WRF) for the production of recycled water. Treatment alternatives investigated included oxidation ditch (OD), conventional activated sludge (CAS), and membrane bioreactor (MBR).

The purpose of the evaluation was to determine the best option to comply with future Title 22 requirements for the beneficial reuse of recycled water. Parsons determined an MBR system was the best treatment option and completed a 90% design package of the WRF. Unfortunately, the project never reached 100% design and was terminated for various reasons. 2016 Regional Water Quality Control Board Order
On June 30, 2016, the California Regional Water Quality Control Board, Colorado River Basin Region (RWQCB) adopted Board Order R7-2016-0015 (Board Order), which describes the Waste Discharge Requirements (WDRs) and other terms and conditions of operation for the City’s WWTP. The Board Order requires the WWTP to remove constituents that present the greatest risk to groundwater quality such as nitrogen, coliforms, and total dissolved solids (TDS). 1244
According to the United States Environmental Protection Agency (US EPA), the maximum contaminant level (MCL) for Nitrate as Nitrogen (TN) is 10 mg/L. Currently, the average TN concentration in the WWTP’s effluent is 29 mg-N/L, well above the future TN limit of 10 mg-N/L specified in the Board Order.

As a result, the Board Order required the City to conduct a nitrogen removal analysis and to summarize the findings in a technical report that includes a tentative work plan and time schedule for the installation and implementation of nitrogen removal treatment alternatives. The final technical report (Nitrogen Removal Feasibility Study), attached hereto, was completed and submitted to the RWQCB by the due date of June 30, 2020.

The City has had plans for the development of a Title 22 compliant recycled water source dating back to the early 2000’s and for this reason, the scope of the Nitrogen Removal Feasibility Study was expanded beyond complying with TN limits and included discharge requirements related to the use of recycled water.

Additionally, the Board Order requires that the City submit a plan for capacity improvements to the RWQCB once the WWTP reaches 80% of its design capacity, or 2.88 MGD, which is fast approaching due to increased development activity within the City.
2018 Integrated Master Plan
In 2016 the Public Works Department set out to develop new master plans for the City’s water, wastewater and future recycled water systems, which were previously updated in 2006. The final document resulted in a combined plan titled the Integrated Master Plan (IMP). The objective of the IMP was to develop capital improvement plans that would guide the City in the planning and development of water, wastewater and recycled water system facilities to meet system performance for existing customers as well as to support anticipated demands through the City’s buildout.

The IMP projected that the City would reach 80% capacity by 2025 (although could be later if development slows down) and have a buildout wastewater flow of 6.35 MGD. 2020 UWMP
On June 8, 2021 the City Council approved Resolution 2021-50, adopting the 2020 Urban Water Management Plan (UWMP). The UWMP is a planning document with a 20-year planning horizon that assess the water supply and water demand for the City. As part of the assessment all current water supplies and in the future water supplies are include as part of the City’s water supply portfolio, which includes the use of “recycled water” to supplement potable demands (i.e. irrigation demands) and for groundwater recharge.

Owner Advisor
On December 13, 2022, City Council adopted Resolution 2022-14UA, awarding a Professional Services Agreement to N2W Engineering ("N2W") to provide Owner Advisor ("OA") services for the Wastewater Treatment Plant Improvement project.

N2W has assisted the City in further review of available technologies and confirmed through a Feasibility Report that an MBR system would be the best solution for the City. Additionally, they prepared two grant applications for the City: (1) Water Recycling Funding Program Planning grant application which led to an award of $300,000 and (2) WaterSMART: Title XVI WIIN Act Water Reclamation and Reuse Program for which the City received a Notice of Funding Opportunity No. R23AS00464 (attached) in the amount of $16,194,576.

N2W also assisted in the preparation of a scope of work for a Request for Qualifications that led to the shortlisting of 3 design-build entities that prepared and submitted proposals for Phase 1 (Design) of the WWTP Upgrade Project.

Selection of Progressive Design Build Entity
1245
On March 22, 2024, the City issued a Request for qualification (RFQ) seeking prospective Progressive Desing-Build (PDB) entities for the project. Statement of Qualifications (SOQs) were received from PDB entities on May 3, 2024. The City evaluated responsive SOQs in accordance with the RFQ; shortly thereafter, the City shortlisted the following three (3) PDB entities:

1. AECOM Lyles JV

2. Innovative Construction Solutions

3. PERC Water Corporation
Only these three (3) PDB entities were eligible to receive the Request for Proposal (RFP) which was issued on August 9, 2024. These PDB entities were requested to advance the design and provide detailed input as to the design and construction of the Project, including benefits to the Project’s reliability, ease and extent of upgrades and expansion and interconnection, and sustainability. Award of the Progressive Design-Build Contract was made utilizing a best value selection process and consisted of an evaluation of multiple factors as listed below in this RFP:

Project Team, Experience, and Approach (25 Points)
Technical Approach (25 Points)
Construction & Startup Process (20 Points)
Phase 1 – Cost and Fee Schedule (10 Points)
Interview (20 Points)
An evaluation committee consisting of two City Employees and two Owner’s Advisors was assembled to score each proposal based on the evaluation factors listed above. The resulting evaluation scores are as follows:

PDB Entity Score (out of 100)
AECOM Lyles JV 82.44
Innovative Construction Solutions 81.24
PERC Water Corporation 77.75
As a result, staff recommends awarding the Progressive Design-Build Agreement ("Agreement") for Phase 1 of the Wastewater Treatment Plant and Recycled Water Upgrades project to AECOM Lyles JV in the amount of $3,998,627.

If awarded, staff anticipates the Phase 1 (Design) scope of work to commence in early March 2025 through April 2026.

Phase 1 Services
This Phase includes all the planning, engineering, and permitting to prepare a complete design-todevelop a Guaranteed Maximum Price (GMP) and a construction schedule for Phase 2.

It shall be noted that at the completion of Phase 1 scope of work and upon agreement on the GMP by the City, AECOM Lyles JV will proceed with Phase 2 (Construction) for equipment procurement, construction, engineering design support during construction, construction management, commissioning and acceptance testing. Following the completion of Phase 1, the current estimated duration for Phase 2 is approximately another 2 years.

JUSTIFICATION:

The Wastewater Treatment Plant and Recycled Water Upgrades project includes the design and construction of major complex treatment technologies that will allow the City to comply with impending wastewater discharge requirements and to produce recycled water. A PDB approach is a collaborative delivery method that involves the design-builder throughout the design and construction process resulting in a project that will meet the City’s needs for the best value. 1246
AECOM Lyles JV was ranked the highest following the RFP.

FISCAL IMPACT:

The recommended Progressive Design-Build Agreement for Phase 1 of the Wastewater Treatment Plant and Recycled Water Upgrades project to AECOM Lyles JV is in the amount of $3,998,627. Staff requests a 10% contingency in the amount of $399,862 for any unforeseen changes in scope of work or conditions. The total project budget for Phase 1, including the Agreement and contingency, is for an amount of $4,398,490.

The current adopted budget for Fiscal Year 2024/2025 includes the required funding for the Agreement, which will be funded as follows:
- Account No. 681 -8000- 454.95-12 : $1,000,000
- Account No. 682-8050-454.95-10: $3,398,490
ALTERNATIVES:

Do not approve Resolution 2025-30 and provide alternative direction to staff.

BUDGETED?:

Yes
CONTRACT/AGREEMENT:

Yes
ATTACHMENTS:

1. Resolution 2025-30, WWTP Design Build award.docx

2. Banning_DB_545_Agreement.pdf

3. Resolution No. 2021-050 (For Reference Purposes Only).pdf

4. Resolution No. 2022-14UA (For Refrence Purposes Only).pdf

5. RWQCB Order R7-2016-0015.pdf

6. Banning Nitrogen Removal Feasibility Study FINAL.pdf

7. BOR Notice of Funding Opportunity No. R23AS00464.pdf

8. AECOM-Lyles Proposal for RFP-24-074.pdf

9. AECOM-Lyles Pricing Proposal - Supporting Information.pdf

10. Banning DB 535 General Conditions.pdf
1247

CITY OF BANNING

STAFF REPORT
TO: CITY COUNCIL
FROM: Robert Fisher, Acting City Manager
PREPARED BY: Art Vela, Public Works Director
MEETING DATE: July 8, 2025
SUBJECT: Consideration of Resolution 2025-109, Authorizing the Submission of an Application to the California Infrastructure and Economic Development Bank for Financing for the Wastewater Treatment Plant and Recycled Water Upgrades Project
RECOMMENDATION:

Adopt Resolution 2025-109.

BACKGROUND:

The City’s Wastewater Fund has several pending capital projects, including the Wastewater Treatment Plant (“WWTP”) Upgrades Project (the “Project”) to comply with nitrogen removal regulations and allow the WWTP to achieve tertiary treatment (producing Title 22 recycled water which can be used to offset potable water demands).

The estimated cost of the Project is $64,778,302. To address this cost, the City plans to utilize a variety of funding sources. The Wastewater Fund has cash and reserves, and City staff have identified approximately $19 million of those reserves for the Project. Additionally, City staff have been applying for a variety of grants in an attempt to offset the cost of the project to the City’s ratepayers. The City has been awarded a $16 million United States Bureau of Reclamation WaterSMART Grant (“USBR Title XVI Grant”) for this water recycling project. The City is in the process of negotiating the grant agreement for the USBR Title XVI Grant. Staff expect to bring a separate resolution to City Council related to this grant at the July 8th City Council meeting.

As illustrated in the table below, after applying a portion of the Wastewater Fund’s reserves and the USBR Title XVI Grant receipts, there is a remaining funding need of approximately $25 million for the Project. City staff have been working with NHA Advisors, LLC, the City’s Municipal Advisor to evaluate potential funding sources to meet this remaining $25 million need.

Funding Source
Estimated Funding Source
Balance on 7/1/2025
Amount to be Allocated to
WWTP Project
Fund 661 - Water Improvement
Fund
$3,632,861.34 $3,085,000
Fund 680 - Wastewater Operation
Fund
$7,991,840.23 $1,773,726
Fund 681 - Wastewater
Improvement Fund
$11,035,587.18 $6,500,000
Fund 682 - Tertiary Fund $8,375,653.38 $9,725,000*
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Fund 683 - BUA Wastewater Fund $2,500,000 $2,500,000
FY 2024 Title XVI Program Funds $16,194,576 $16,194,576 Other Funding (IBank Loan or
Revenue Bonds)
$25,000,000 $25,000,000
TOTAL $64,778,302
Two primary funding sources evaluated are the issuance of municipal bonds or entering into a long-term loan with IBank. IBank provides loans to public agencies throughout the State of California through a loan program whereby IBank issues bonds to raise the funds and then provides those funds to public agencies through a direct loan.

The IBank program provides different rates to each borrower depending on that borrower’s term and interest rate. Holding all else constant, shorter-term to a higher rated borrower would have a lower interest rate compared to a longer-term loan to a lower-rated borrower. The City’s Wastewater Fund has no outstanding publicly-issued debt and so has no current credit rating. However, IBank staff have indicated that they can use the Water Fund’s existing “A+” credit rating as a proxy for the Wastewater Fund, after making a 1-notch downward adjustment. Accordingly, IBank would consider a potential loan to the City to be in the “A” category and would set the City’s interest rate accordingly.

Importantly, IBank offers interest rate subsidies to certain qualifying borrowers. IBank staff have notified the City’s team that since the City is a disadvantaged community (“DAC”), the City may be eligible for a median household income subsidy and an unemployment rate subsidy. Each of these subsidies can reduce the IBank interest rate by 0.25%, and when combined can reduce the IBank interest rate by a total of 0.5% compared to an IBank rate on a loan without those subsidies.

Because an IBank loan is a private loan to a State entity, there is no public sale and no disclosure document required from the City. Instead, IBank has their own evaluation and credit underwriting process that will commence in earnest once the City submits an executed copy of the contemplated Borrowers Resolution.

By comparison, a publicly-issued revenue bond would require the City engage disclosure counsel to draft a preliminary official statement, which would contain all of the material facts and information needed by a prudent investor to make a decision whether or not to buy wastewater revenue bonds issued by the City.

Additionally, the City would need to secure a credit rating on any issuance of wastewater revenue bonds.

Because IBank funds come from a bond issue, the majority of the terms and conditions on an IBank loan are similar to a revenue bond issuance, with a few notable exceptions, as outlined in the table below. In addition to the two options discussed below, the City looked into a potential State Revolving Fund (“SRF”) loan and a potential federal Water Infrastructure Finance and Innovation Act (“WIFIA”) loan. The process of securing funds from each of these loan programs is lengthy (from 18-24 months), and are not expected to deliver funds by the City’s anticipated start date of the project.

IBank Loan Revenue Bonds
Limitation on loan sizes $65M (Currently) None
Intended Project Phase Construction Primarily Planning through construction Maximum % of Project Funded 100% (up to $65M) 100%
Maximum Term 30 years 30 years
Structuring Flexibility Level Debt Service Only Flexible (“Wrap Around”) Timing from Start to Funding
Date
~6 months ~4 months
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Prepayment without Penalty
Not for 10 years
(non-negotiable)
Typically, 10 years (negotiable)
Estimated Interest Rate
(As of 6/20/25)
20-year: 4.12%*
30-year: 4.60%*
20-year: 4.33%*
30-year: 4.80%*
*All interest rates shown are indicative based on market interest rates on 6/20/2025 and are subject to change. The IBank rates shown reflect the net rate after adjusting for the 0.15% annual loan servicing fee and the median household income and unemployment subsidies of 0.5%.

JUSTIFICATION:

Based on the indicative interest rates in the table above, annual debt service payment on an IBank loan is estimated to be $1.85 million for a 20-year loan and $1.54 million for a 30-year loan, as shown in the table below. These amounts are compared to a similarly-structured revenue bond, assuming an “A” credit rating.

Estimated Annual Debt
Service
IBank Loan Revenue Bonds
20-Year Loan $1.85 million $1.89 million
30-Year Loan $1.54 million $1.59 million
Because of the potential savings to the City through an IBank Loan that has both the median household income and unemployment rate interest rate subsidies, City staff believe that IBank provides a lower cost funding source than issuing a revenue bond. Over the term of a 20-year loan, the City could see $820,000 in cumulative cashflow savings, compared to a revenue bond. Over a 30-year period, the City could see $1.3 million in cumulative cashflow savings compared to a revenue bond.

The Borrower’s Resolution attached to this staff report authorizes City staff to proceed with the IBank application process with a goal of finalizing an IBank Loan. The Borrower’s Resolution identifies a not-toexceed amount on the IBank Loan, which is commonly set to an amount slightly higher than the final anticipated loan size to provide flexibility. In the draft Resolution, the not-to-exceed amount is $30 million, even though the anticipated loan size is closer to $25 million.

In addition to setting the not-to-exceed amount, the Borrower’s resolution declares the City’s official intent to reimburse itself for previously incurred capital expenditures with the proceeds of tax exempt bonds. Because an IBank loan or a wastewater revenue bond would be issued as tax exempt debt, the City is required to make such a declaration of an intent to reimburse. Doing so gives the City the option to reimburse itself from the loan or bond proceeds for costs paid up to 60 days prior to the adoption of the resolution. It is common practice to adopt a similar resolution early on to maximize the City’s flexibility to reimburse itself from future loans or bonds. The notice of intent included in the Borrower’s Resolution would also serve as a reimbursement resolution should the City instead issue revenue bonds.

Most notably, the borrower’s resolution empowers City staff, but does not obligate the City to enter into any loan should the Project timing, amount, or IBank loan rates change significantly. City staff will continue to work with NHA Advisors to evaluate funding options and, up until a loan is presented to the IBank Board of Directors for funding approval, the City will retain the option to pursue other funding sources if a cheaper source is found.

Upon submission of a complete application packet and executed Borrower’s Resolution to IBank, Staff estimate that the City can close an IBank loan within approximately 3-6 months.

FISCAL IMPACT:
1250
As discussed, based on current (6/20/25) market rates, the annual debt service payment on a 20-year IBank loan is estimated at $1.85 million per year and the annual debt service payment on a 30-year IBank loan is estimated at $1.54 million per year. This annual debt service is expected to commence in fiscal year 2026-27. There is an annual 0.15% loan servicing fee due to IBank, but the interest rates quoted are inclusive of that annual fee.

IBank charges a 1% origination fee to cover their costs of credit review, underwriting, and legal counsel.

Based on a $25 million loan, this equates to a $250,000 fee, payable at closing. This amount can be paid out of the loan amount, or paid by one or more of the funding sources identified above. In addition to IBank’s closing day origination fee, the City would have expenses related to its own legal counsel and municipal advisor. These closing day amounts would be payable in fiscal year 2025-26 if the City elects to pay the closing costs from the City's wastewater funding sources.

ALTERNATIVES:

Do not approve and provide direction to staff, such as pursuing other funding options.

BUDGETED?:

No
CONTRACT/AGREEMENT:

No
ATTACHMENTS:

1. Resolution 2025-109.docx
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Resolution 2025-109

RESOLUTION 2025-109

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF BANNING, CALIFORNIA,

AUTHORIZING THE SUBMISSION OF AN APPLICATION TO THE CALIFORNIA

INFRASTRUCTURE AND ECONOMIC DEVELOPMENT BANK FOR FINANCING A CAPITAL IMPROVEMENT PROJECT FOR THE CITY’S WASTEWATER FUND, AUTHORIZING THE

INCURRING OF AN OBLIGATION PAYABLE TO IBANK FOR THE FINANCING OF A

CAPITAL IMPROVEMENT PROJECT IF IBANK APPROVES SAID APPLICATION,

DECLARATION OF OFFICIAL INTENT TO REIMBURSE CERTAIN EXPENDITURES FROM

THE PROCEEDS OF AN OBLIGATION, AND APPROVING CERTAIN OTHER MATTERS IN

CONNECTION THEREWITH
WHEREAS, the California Infrastructure and Economic Development Bank (“IBank”) administers a financing program to assist local governments with the financing of eligible projects in accordance with Section 63000 et seq. of the California Government Code (the “Act”); and WHEREAS, IBank created the Infrastructure State Revolving Fund Program (“ISRF Program”) pursuant to the provision of the Act; and
WHEREAS, IBank has instituted an application process for financing under its ISRF Program; and
WHEREAS, IBank’s Criteria, Priorities and Guidelines for the Selection of Projects for Financing under the ISRF Program, dated February 23, 2016, and as may thereafter be amended from time to time (the “Criteria”), establishes requirements for the financing of projects under the ISRF Program; and
WHEREAS, the City of Banning (“Applicant”) desires to submit an application (“Financing Application”) to IBank under the ISRF Program for financing and refinancing the costs of the Wastewater Treatment Plant and Recycled Water Upgrades Project (“Project”) in an amount not to exceed $30,000,000; and
WHEREAS, the Act and the Criteria require the Applicant to make, by resolution of its governing body, certain findings prior to a project being selected for financing by IBank; and WHEREAS, the Applicant expects to incur or pay certain expenditures in connection with the Project from its Wastewater Fund that are reimbursable with the proceeds of tax exempt bonds or other tax exempt securities under Federal Tax Law (defined below) prior to incurring indebtedness for the purpose of financing costs associated with the Project on a long-term basis (the “Reimbursement Expenditures”); and
WHEREAS, the Applicant reasonably expects that a financing arrangement (“Obligation”) in an amount not expected to exceed $30,000,000 will be entered into under and memorialized by one or more financing agreements and related documents (collectively, the “Financing Agreement”) and that certain proceeds of such Obligation will be used to reimburse the Applicant for Reimbursement Expenditures incurred or paid prior to incurring the Obligation; and WHEREAS, the Applicant acknowledges that IBank funds the ISRF Program, in part, with the proceeds of tax exempt bonds and, as such, has certain compliance obligations that may require it to have the Applicant enter into one or more new financing agreements to replace the 1252
Resolution 2025-109

Financing Agreement (collectively, the “Replacement Agreement”) on terms and conditions substantially identical to the original Financing Agreement.

NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Banning as follows:

SECTION 1. The City Council hereby approves confirms, ratifies, and affirms all actions of the Applicant’s representatives, employees and officers heretofore taken in connection with, or with respect to, submitting the Financing Application, and the consideration and approval of the Obligation and the Financing Agreement, if IBank approves the Financing Application and the Obligation, and in connection therewith the Council finds and certifies:
a. The Project facilitates the effective and efficient use of existing and future public resources so as to promote both economic development and conservation of natural resources;
b. The Project develops and enhances public infrastructure in a manner that will attract, create, and sustain long-term employment opportunities; c. That the Project is consistent with the General Plan of the City of Banning, and the General Plan of the County of Riverside;
d. The proposed financing is appropriate for the Project; e. The Project is consistent with the Criteria; and
f. It has considered (i) the impact of the Project on California’s land resources and the need to preserve such resources; (ii) whether the Project is economically or socially desirable; and (iii) whether the project is consistent with, and in furtherance of the State Environmental Goals and Policy Report (as defined in the Criteria)..

SECTION 2. The Applicant hereby declares its official intent to use proceeds of the Obligation to reimburse itself for the Reimbursement Expenditures with the proceeds of tax exempt bonds or other tax exempt securities issued under the provisions of the Internal Revenue Code of 1986, as amended, and those Treasury Regulations implementing such provisions (collectively, “Federal Tax Law”). This declaration is made solely for purposes of establishing compliance with applicable requirements of Federal Tax Law and its date is controlling for purposes of reimbursement under Federal Tax Law. This declaration does not bind the Applicant to make any expenditure, incur any indebtedness, or proceed with the Project.

SECTION 3. All of the Reimbursement Expenditures were made no earlier than 60 days prior to the date of this Resolution. The Applicant will allocate proceeds of the Obligation to pay Reimbursement Expenditures within eighteen (18) months of the later of the date the original expenditure was paid or the date the Project was placed in service or abandoned, but in no event more than three (3) years after the original expenditure was paid.

SECTION 4. The City Manager, Finance Director, and Public Works Director and his or her designee is hereby authorized and directed to act on behalf of the Applicant in all matters pertaining to the Financing Application, and if IBank approves the Financing Application and the Obligation, the execution of related financial documents, including but not limited to, the authority to: (i) pledge the revenues of the Wastewater Fund on a parity basis with the Applicant’s obligations in connection with the 2019 Wastewater Revenue Bonds, to the repayment of the Obligation, (ii) provide covenants relating to, among other things, maintaining the debt service coverage ratio required by IBank, rates and charges to be pledged, and as to any other security or collateral securing the Obligation, and (iii) take any other action necessary or desirable to enable the Applicant to enter into the Financing Agreement and incur the Obligation. 1253
Resolution 2025-109

SECTION 5. If the Financing Application and the Obligation is approved by IBank, the City Manager, Finance Director, and Public Works Director and his or her designee is authorized to negotiate, enter into and sign financing documents and any amendments thereto, including, but not limited to the Financing Agreement and the Replacement Agreement, with IBank for the purposes of financing the Obligation.

SECTION 6. The City Clerk shall certify to the adoption of this resolution and shall cause a certified resolution to be filed in the book of original resolutions.

PASSED, APPROVED AND ADOPTED this 8
th day of July, 2025.

Sheri Flynn, Mayor
City of Banning
ATTEST:

Caroline Patton, Administrative City Clerk
City of Banning
APPROVED AS TO FORM:

John Pinkney, Interim City Attorney
Slovak, Baron, Empey, Murphy & Pinkney,
LLP
1254
Resolution 2025-109

CERTIFICATION:

I, Caroline Patton, Administrative City Clerk of the City of Banning, California, do hereby certify that the foregoing Resolution 2025-109, was duly adopted by the City Council of the City of Banning, California, at a regular meeting thereof held on the 8th day of July, 2025 by the following vote, to wit:

AYES:

NOES:

ABSENT:

ABSTAIN:

Caroline Patton, Administrative City Clerk
City of Banning, California
1255

CITY OF BANNING

STAFF REPORT
TO: CITY COUNCIL
FROM: Robert Fisher, Acting City Manager
PREPARED BY: Barbara Mason, Chief Procurement Officer
Barbara Mason, Chief Procurement Officer
MEETING DATE: July 8, 2025
SUBJECT: Consideration of Resolution 2025-110, Approving an amendment to Purchasing Policy No. B-30 to streamline and enhance the procurement and purchasing process
RECOMMENDATION:

Adopt Resolution 2025-110.

BACKGROUND:

The City Council initially approved Purchasing Policy B-30 on June 27, 2017. The purpose of this policy is to provide the City of Banning a means of assuring continuity and uniformity in its purchasing operation, and to define the responsibilities for purchasing supplies, services, tools, equipment and installation for the City of Banning.

There have been three subsequent amendments to the policy since initial approval:
2/26/19 Incorporation of Insurance requirements
10/8/19 Adoption of CUPCCAA
1/28/25 Update of CUPCCAA spending limit.

Staff now would like to streamline the process of inventory procurements. For the past few years, City Council approved large blanket orders to the main suppliers used for inventory purchases annually prior to the beginning of each fiscal year. The amounts of these Purchase orders would range from $25,000 to a million dollars. Staff would like to streamline the process and provide greater oversight with the following changes to the Purchasing Policy B-30, Section 3-105 as summarized below:

Modify 3-105(6) Exceptions to purchasing standards to eliminate duplicity and clarify exceptions.

Some items are addressed in other areas of the policy. One or more exceptions required clarifications as redlined in the attachments herein.

Modify 3-105(7) Public Utilities Exception to remove the broad exceptions listed in the chart and limit the exception to inventory items. The B-30 addresses exceptions to the bid process within the Section 11 (4-11) Sole source section.

Under these changes, the process would allow for greater transparency for each purchase order issued over $25,000 that would be ratified by the City Council each month.

The proposed amendment to the Purchasing Policy does not require an amendment to revised the procurement Ordinance.

JUSTIFICATION:

Policies must be updated from time to time. The proposed changes would allow for greater oversight 1256
while providing more centralized procurements.

FISCAL IMPACT:

N/A
ALTERNATIVES:
1) Do not approve the proposed resolutions and continue to approve large value blanket orders, or 2) Provide alternate direction to Staff
BUDGETED?:

Yes
CONTRACT/AGREEMENT:

No
ATTACHMENTS:

1. Resolution_2025-110.docx

2. Redline Procurement Administrative Policies Sec 3-105.pdf

3. Purchasing Policy B-30.pdf
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Resolution 2025-110