April 21, 2026
Public Works
DATE: April 21, 2026
TO: Mayor Martinez and Members of the City Council
FROM: Daniel Chavarria, Director of Public Works
Robert Armijo, Deputy Director of Public Works/City
Engineer
Tawfic Halaby, Deputy Director of Public Works
Bradley Harms, Environmental Manager
Subject:
Contract with Larry Walker & Associates for Wastewater
and Stormwater Regulatory Compliance Support
FINANCIAL IMPACT: The proposed three-year term not to exceed $900,000, will be funded through the Wastewater Enterprise Fund
for wastewater-related regulatory work and the
Stormwater Enterprise Fund for stormwater-related
regulatory work (Account Strings: 40322731-400202 and
40623431-400201). The scope of work is fully eligible for enterprise funding. This item will have no impact on the General Fund.
PREVIOUS COUNCIL
ACTION:
July 18, 2019
October 5, 2021
July 11, 2023
STATEMENT OF THE
ISSUE:
Approval of the proposed contract will allow the City to continue meeting state and federal wastewater and
stormwater regulatory requirements under its National
Pollutant Discharge Elimination System permit,
pretreatment program, sanitary sewer system
regulations, and the Municipal Regional Stormwater
Permit, consistent with the City’s executed sole-source authorization for these specialized compliance services.
AGENDA
REPORT
April 21, 2026
RECOMMENDED ACTION:
ADOPT a resolution to APPROVE a sole-source contract
with Larry Walker & Associates, Inc., to provide
wastewater and stormwater regulatory compliance
support services, in an amount not to exceed $900,000
($806,400 in anticipated costs plus an 11.6%
contingency for unanticipated regulatory responses) for a three-year term from April 22, 2026, through April 21,
2029, and AUTHORIZE the city manager to execute the
contract and any related documents – Public Works
Department (Daniel Chavarria 510-620-5478/Robert
Armijo 510-620-5477/Tawfic Halaby 510-620-
5482/Bradley Harms 510-307-8094).
DISCUSSION:
Background
The City of Richmond is responsible for compliance with state and federal requirements governing its wastewater treatment plant, sanitary sewer collection system, industrial pretreatment program, and stormwater program under the Municipal Regional Stormwater Permit (MRP). The City is a co-permittee under a jointly held National Pollutant Discharge Elimination System (NPDES) permit with the West County Wastewater District through the West County Agency and is directly accountable for meeting all applicable permit conditions and enforcement obligations.
The regulatory programs supporting the City’s wastewater and stormwater systems require highly specialized expertise in NPDES permitting, pretreatment regulations, sanitary sewer overflow compliance, stormwater quality management, and coordination with state and federal regulatory agencies, including the Regional Water Quality Control Board, State Water Resources Control Board, and the U.S. Environmental Protection Agency.
Since 2009, Larry Walker & Associates, Inc. (LWA) has provided specialized regulatory compliance and permitting support services to the City. The firm has been directly involved in development, implementation, and compliance support for the City’s current NPDES permit adopted in 2019 and has supported ongoing coordination with the West County Wastewater District and the Regional Water Quality Control Board. LWA also provides regulatory services to the West County Wastewater District under a separate agreement, ensuring consistency and alignment among co-permittees.
On July 18, 2019, the City Council approved a professional services contract with LWA in the amount of $200,000 to provide NPDES compliance support services. On October 5, 2021, the City Council approved Contract Amendment No. 1, increasing the total contract amount to $520,000. On July 11, 2023, the City Council approved a sole- source professional services agreement with LWA to continue providing wastewater and
April 21, 2026
stormwater regulatory compliance and environmental support services through June 30, 2026 (Attachment 1).
The City is currently in an active NPDES permit cycle, with increasing regulatory complexity, enhanced enforcement expectations, trash load reduction obligations under the MRP, ongoing pretreatment program requirements, sanitary sewer system regulatory reporting, and preparation for upcoming renewal processes.
Analysis
Larry Walker & Associates possesses unique institutional knowledge of the City’s facilities, permit history, compliance obligations, and regulatory relationships developed over more than a decade of continuous service. This includes direct involvement in the current NPDES permit, Municipal Regional Stormwater Permit implementation, enforcement response coordination, compliance reporting, and regulatory negotiations.
Maintaining continuity of this expertise is critical during an active permit cycle and in advance of upcoming permit renewals.
Transitioning to a new consultant at this stage would require significant duplication of effort, introduce avoidable learning curves, increase costs, and create regulatory risk during a period of heightened compliance and enforcement scrutiny. Such disruption could adversely affect the City’s ability to meet statutory reporting deadlines and maintain defensible compliance positions.
For these reasons, staff have determined that continuation of services through a sole- source professional services agreement is in the best interest of the city. A Sole-Source Justification has been prepared and approved in accordance with the Richmond Municipal Code and City procurement requirements. This procurement is authorized under Richmond Municipal Code section 2.52.326, which permits sole-source contracting when services are unique, specialized, and necessary to maintain continuity of ongoing professional services. An executed sole-source approval for Larry Walker & Associates is currently on file with the City and remains in effect, authorizing the City to procure these specialized regulatory compliance services on a sole-source basis. The proposed agreement is consistent with that approval and reflects continuation of the same core wastewater and stormwater regulatory support services.
City staff recommend that the City Council adopt a resolution (Attachment 1) to approve a sole-source contract (Attachment 2) with Larry Walker & Associates, Inc., for regulatory support to meet ongoing National Pollutant Discharge Elimination System (NPDES) requirements, pretreatment, stormwater, and sanitary sewer compliance obligations, in an amount not to exceed $900,000 (consisting of $806,400 in anticipated costs plus an 11.6% contingency for unanticipated regulatory responses to be charged on a time and material basis based on fees included in the cost proposal attached to the proposed contract) for a three-year term from April 22, 2026, through April 21, 2029, and authorize the City Manager to execute the contract. The approved sole source form and the current contract are attached (Attachments 3 and 4). Approval of this agreement will ensure continuity of specialized regulatory support necessary for the City
April 21, 2026
to maintain compliance with state and federal wastewater and stormwater requirements during an active permit cycle and upcoming permit renewals, while sustaining consistent technical expertise and maintaining fiscal and administrative defensibility.
DOCUMENTS ATTACHED:
Attachment 1 – Resolution
Attachment 2 – Proposed Contract with Larry Walker & Associates, Inc.
Attachment 3 – Approved Sole Source Justification
Attachment 4 – Current Contract with Larry Walker & Associates, Inc.