Cotati City Council
Agenda Staff Report
Item type: REGULAR AGENDA (ACTION)
To: City Council
Subject: CONSIDERATION OF A RESOLUTION ADOPTING A NEW
CROSS-CONNECTION CONTROL PLAN FOR THE CITY OF
COTATI PURSUANT TO THE CALIFORNIA STATE WATER
RESOURCES CONTROL BOARD'S CROSS-CONNECTION
CONTROL POLICY HANDBOOK
Date: December 9, 2025
Written by: Craig Scott, Director of Public Works/City Engineer Recommendation
It is recommended the City of Cotati City Council adopt a resolution adopting a new CrossConnection Control Plan for the City of Cotati pursuant to the California State Water Resources Control Board’s Cross-Connection Control Policy Handbook.
Background
The California Code of Regulations, Title 17, requires public water systems to protect the potable water supply from contamination by implementing and maintaining an effective crossconnection control program. The California State Water Resources Control Board ("SWRCB") issued the Cross-Connection Control Policy Handbook ("Handbook") in 2023, establishing new minimum statewide standards for cross-connection control programs. The Handbook requires public water systems to adopt or revise their Cross-Connection Control Plans ("CCCP's" to comply with the standards and procedures outlined in the Handbook, including provisions for hazard classification, backflow prevention, inspections, enforcement, and incident response).
The SWRCB requires that all public water systems in the State adopt a CCCP no later than December 31, 2025.
Analysis/Discussion
Staff has reviewed the requirements of the Handbook and prepared a Cross-Connection Control Plan (CCCP) for the City of Cotati that aligns with State regulations and ensures the continued protection of the public water supply. Adoption of the City's Cross-Connection Control Plan reflects the City of Cotati's commitment to public health, regulatory compliance, and water quality protection.
The proposed CCCP reflects the new statewide standards set forth in the Handbook and demonstrates the City of Cotati’s commitment to protecting public health and ensuring regulatory compliance. Key elements of the plan include:
• Hazard Assessment and Service Connection Classification. The CCCP includes a riskbased classification system to evaluate service connections based on the degree of hazard they pose to the potable water system (i.e. high, moderate, or low). This classification determines the level of backflow protection required.
• Backflow Prevention Device Requirements. The plan mandates the installation of appropriate backflow prevention assemblies (e.g. air gaps, reduced pressure principle assemblies, or double check valve assemblies based on hazard level. • Testing, Maintenance, and Inspection Procedures. All backflow prevention assemblies are required to be tested annually by a certified tester. The CCCP outlines detailed testing protocols, documentation standards, and responsibilities for both the water suppliers and the customer.
• Certified Personnel Requirements. The plan reinforces all program activities – surveys, inspections, and testing – be conducted by personnel certified by an approved agency. • Recordkeeping and Data Management. The plan incorporates new digital tracking procedures for all backflow devices, inspections, and customer compliance data. The updated CCCP aligns with the SWRCB’s expectations for accurate, real-time reporting and readiness for audits.
• Enforcement and Corrective Action. The CCCP establishes enforcement procedures for noncompliance, including formal notices, service disconnection for unaddressed violations, and timelines for corrective action. This ensures the water system can effectively manage risk and take corrective action to protect public health. • Public Education and Communication. The CCCP includes outreach strategies to inform customers, especially those in high-risk categories, about their responsibilities related to cross-connection control and the importance of device maintenance. • Backflow Incident Response Plan. The plan outlines procedures for immediate containment, regulatory notification, investigation, corrective action, and documentation in response to suspected or confirmed backflow incidents to protect public health and the water system.
Impact on Existing and Future Services with Fire Sprinklers The Handbook includes specific backflow protection requirements for Public Water Systems serving water to users with fire protection systems such as fire sprinklers. The City has customers with fire protection system with no backflow prevention device which makes them subject to the stricter new requirements. The attached Guidance document from the State Water Resources Control Board seeks to clarify what these new requirements mean to existing and new commercial and residential customers with fire protection systems.
There is flexibility on how the requirements can be met. The Guidance document presents options on how these requirements can be implemented. For low hazard situations, which apply to just about all the City’s customers with fire sprinklers systems and no backflow device, have the following options:
1. Meet the criteria in section 3.2.2(e)(3) of the Handbook (residential only),
2. High Hazards
a. Require Reduced Pressure Backflow Device (Handbook, § 3.2.2(e)(1)).
3. Low Hazards
a. Require Double Check Backflow Device within 10 years per Handbook Section
3.2.2(e),
b. Propose an alternative to Double Check Backflow Device protection via its CCCP (Handbook, Section 3.2.2(e)(2)(B), or
c. Propose a compliance date extension via its CCCP (Handbook Section
3.3.3(e)(2)(A).
The CCCP includes all of these options as each customer’s situation differs and we want to provide them with the most flexibility for compliance.
Financial Considerations
There will be additional staff time in administering the expanded backflow prevention program and it is expected that there will be additional costs to hire a third-party contractor to conduct hazard surveys of every customer in the City. Depending on the customer type, compliance timeframes are 10-15 years.
While the City already has a backflow device program and requires all customers with reduced pressure backflow devices to test their devices annually, it is likely that some amount of new customers will be identified through the hazard survey. These customers will be expected to add or upgrade a backflow device on their water service. For the reduced pressure backflow device (the standard for higher hazards), there will also be an on-going annual testing cost. Assuming a relatively straightforward installation, backflow devices for typical 3/4 inch service is approximately $5,000, but can get significantly more costly for complicated situations. Annual testing costs vary between $100-200 per device per year. These costs are borne by the water customer.
For new developments, the initial hazard survey is expected to become a condition of approval for occupancy as these new properties are attached to the public water system.
Environmental Issues
Where it can be determined with certainty that there is no possibility that the activity in question may have a significant effect on the environment, the activity is not subject to CEQA review.
This general rule can be applied to activities which could be subject to the CEQA process, but which logic dictates should not be subject to CEQA review. Therefore, based on the information provided above, the proposed resolution is exempt from CEQA pursuant to Section 14.03.021 of the CEQA Guidelines in that there is no possibility that the activity may have a significant impact on the environment.