City Council
Staff Report
From: City Manager
Report Type: CONSENT CALENDAR
Lead Department: Utilities
Meeting Date: June 17, 2025
Report #:2504-4486
TITLE
Approval of the 2025 update to the Sewer System Management Plan (SSMP) and Authorization for Staff to Make Future Administrative or Minor Updates to the SSMP as Needed; CEQA Status – Exempt under CEQA Guidelines sections 15301, 15302, 15308.
RECOMMENDATION
Staff recommends that the City Council:
1. Approve the 2025 update to the SSMP 1, as required by the State Water Resources Control Board (SWRCB) Order No. WQO-2022-0103-DWQ, Statewide Waste Discharge Requirements General Order for Sanitary Sewer Systems (General Order).2
2. Authorize future SSMP updates that are administrative or minor in nature to be approved by staff without returning to Council for approval.
EXECUTIVE SUMMARY
The 2025 update to the SSMP aligns the City with current regulatory requirements under SWRCB’s General Order. The SSMP serves as the City's guiding document for managing, operating, maintaining, and improving the sanitary sewer system, and aims to reduce sanitary sewer overflows (SSOs). The SSMP documents the City’s Sanitary Sewer System, defines the City’s goals for improving its sewer system infrastructure, and establishes an implementation plan and schedule for achieving these goals. This update reflects current system conditions and includes improvements in maintenance practices, spill response, and infrastructure planning.
The General Order requires that the City Council approve the document prior to submittal to the SWRCB.
1 2025 SSMP: Link to SSMP:
https://www.paloalto.gov/files/assets/public/v/1/agendas-minutes-reports/agendas-minutes/city-council- agendas-minutes/2025/june-16/staff-report-2504-4486/sewer-system-management-plan-2025-update-2.pdf 2 State Water Resources Control Board (SWRCB) Order No. WQO-2022-0103-DWQ, Statewide Waste Discharge Requirements General Order for Sanitary Sewer Systems (General Order) https://www.waterboards.ca.gov/board_decisions/adopted_orders/water_quality/2022/wqo_2022-0103-dwq.pdf
BACKGROUND
The first SSMP to be adopted by City Council was in July 2009. Since the first adoption of the SSMP, the plan has been audited and updated to remain compliant with the SWRCB’s regulations.
The 2022 General Order applies to all California municipalities that own and/or operate a sanitary sewer system greater than one (1) mile in length. Accordingly, the City is required by the State to ensure the proper management and operation of its sanitary sewer system, and to comply with the SWRCB General Order by developing, implementing, auditing, and periodically updating its SSMP in accordance with the State’s prescribed schedule.
The SSMP must be updated and certified by the City’s governing body, its City Council, every six (6) years. Upon City Council approval, the Legally Responsible Official will upload and certify the SSMP in the online California Integrated Water Quality System (CIWQS) Sanitary Sewer System Database. The last update was approved by Council in May 2023 ( Staff Report ID #2301-0789) 3 to address two (2) key requirements of the re-issued 2022 General Order, both due before June 5, 2023:
1. The designation of the Legally Responsible Official in the CIWQS database and the certification of continued regulatory coverage under the 2022 General Order, which became available for certification on April 5, 2023.
2. The update and implementation of the Spill Emergency Response Plan (SERP) within the SSMP.
An update to the existing 2023 SSMP 4 is now necessary to reflect current conditions and for compliance with the 2022 General Order, which is due on August 2, 2025. Revisions focus on improving clarity, consistency, and structure through editorial updates, elimination of duplicate content, and reorganization of sections of the Plan to align with SSMP elements. A redline version of the revised Plan is available for reference. The revisions also include updated staffing details, performance data through 2024, refined system mapping, and simplified appendices to reflect current operational practices and regulatory standards. The updated SSMP must be presented to the Council at a public meeting and formally adopted to ensure that the public has the opportunity to comment on the collection systems policies and procedures.
DISCUSSION
The City’s SSMP describes the City's wastewater collection system management activities. The purpose of these activities is to maintain and improve the condition of collection system infrastructure, control infiltration/inflow, provide appropriate sewer capacity, and minimize the number and impact of Sanitary Sewer Overflows (SSOs).
3 Staff Report ID #2301-0789 https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=11197 4 2023 Sanitary Sewer Management Plan https://www.paloalto.gov/files/assets/public/v/1/utilities/utilities- engineering/wastewater/2023-ssmp-final.pdf
The 2022 General Order requires internal audits of the SERP annually and the SSMP every three years and updates as needed. The City’s Utilities Department will complete the required audits, update the SERP and SSMP, and implement identified changes based on the audit findings. The SSMP will be reviewed and updated annually to ensure any significant program changes, after audits, or when there are changes in the Implementation Team's membership or responsibilities.
To streamline future updates, staff recommends that administrative and minor program changes be approved by staff without returning to Council. These changes will be documented in the SSMP’s Appendix O: SSMP Change Log for transparency. The SSMP will continue to be reviewed annually, audited every three (3) years, and certified by Council every six (6) years, in compliance with State requirements.
There are also two (2) significant initiatives currently in progress that will impact the SSMP but are not aligned with the deadline for the 2025 SSMP update. These will be incorporated into future SSMP updates once finalized.
1. Sewer Use and FOG Ordinance Updates – The Public Works Department’s Environmental Services Division, through the Watershed Protection Group (WPG), oversees the City’s Fats, Oils, and Grease (FOG) program. Updates to the City’s Sewer Use and Stormwater Ordinances (Chapters 16.09 and 16.11) are underway to align with new state regulations and permitting requirements. Additionally, a new FOG Ordinance (Chapter 16.13) will be introduced to enhance clarity, usability, and regulatory alignment. Final revisions are expected to be presented to the City Council in Fall 2025.
2. The 2025 Sewer Master Plan Update – The Wastewater Engineering and Operations Division is working with a consultant to complete the 2025 Sewer Master Plan Update Study, anticipated for completion in winter 2025. In the interim, the Division is relying on currently available data to evaluate and assess system needs.
FISCAL/RESOURCE IMPACT
There are no immediate fiscal or resource impacts due to adoptions of this 2025 update to the SSMP. Potential long-term impacts include additional, unquantifiable increases in operational and capital costs to comply with increasingly stringent regulatory requirements.
STAKEHOLDER ENGAGEMENT
This staff report and recommendations are intended to promote transparency and keep the public informed about the City’s sewer system management practices, offering the community an opportunity to review and provide feedback. Once approved, the updated 2025 SSMP will be made available to the public on the City of Palo Alto Utilities Department website.5
5 City of Palo Ato Utilities Department Website https://www.paloalto.gov/Departments/Utilities/Utilities-Services- Safety/Safety#panel-1-4
ENVIRONMENTAL REVIEW
Implementation of the SSMP will apply to sanitary sewer collection systems that constitute "existing facilities" of the City, or may require the installation of minor sewer system facilities which will involve either minor alterations to existing facilities, or repair or replacement of existing facilities involving negligible or no expansion of sewer capacity. Such activities are exempt from review under the California Environmental Quality Act (CEQA). (CEQA Guidelines sections 15301 and 15302.) The adoption of the SSMP is also exempt from environmental review because it requires the implementation of management operations programs and plans to enhance and protect the environment by limiting the occurrence of SSOs in the City. (CEQA Guideline section 15308.).
ATTACHMENTS
None.
Link to 2025 SSMP: https://www.paloalto.gov/files/assets/public/v/1/agendas-minutes- reports/agendas-minutes/city-council-agendas-minutes/2025/june-16/staff-report-2504- 4486/sewer-system-management-plan-2025-update-2.pdf
APPROVED BY:
Alan Kurotori, Director of Utilities
Staff: Matt Zucca, Utilities Assistant Director WGW Engineering & Operations