TO: HONORABLE MAYOR
AND CITY COUNCIL
FROM: Jeff Provenzano
SUBJECT: Stormwater Management
Annual Report 2024-2025
DATE: September 2, 2025
Approved
Date:
9/11/2025
COUNCIL DISTRICT: Citywide
RECOMMENDATION
Adopt a resolution authorizing the certification and submittal of the Fiscal Year 2024- 2025 Stormwater Management Annual Report to the San Francisco Bay Regional Water Quality Control Board by September 30, 2025, in conformance with the Municipal Regional Stormwater National Pollutant Discharge Elimination System Permit requirements, pursuant to the Federal Clean Water Act.
SUMMARY AND OUTCOME
The Municipal Regional Stormwater National Pollutant Discharge Elimination System Permit (Stormwater Permit) requires the City of San José (City) to submit an approved Stormwater Management Annual Report (Annual Report) to the San Francisco Bay Regional Water Quality Control Board (Water Board) by September 30 of each year, certifying implementation of and compliance with the Stormwater Permit requirements that adhere to the Federal Clean Water Act.
The Federal Clean Water Act and the Stormwater Permit specify actions necessary to reduce the discharge of pollutants in stormwater into municipal separate storm sewer system (MS4) and the waterways that ultimately help protect and enhance water quality in local creeks and the San Francisco Bay.
This is the third report for the five-year Stormwater Permit that became effective July 1, 2022, and it includes data on a wide range of City activities undertaken from July 1, 2024, through June 30, 2025 to meet regulatory requirements. Approval of this recommendation will result in the submittal of the Fiscal Year (FY) 2024-2025 Annual Report to the Water Board by September 30, 2025, as required by the Stormwater Permit.
COUNCIL AGENDA: 9/23/25
FILE: 25-1007
ITEM: 6.1
HONORABLE MAYOR AND CITY COUNCIL
September 2, 2025
Subject: Stormwater Management Annual Report 2024-2025
BACKGROUND
The Federal Clean Water Act requires the City to operate its MS4 in accordance with its Stormwater Permit for the discharge of stormwater into receiving waters. The Stormwater Permit specifies actions within a five-year permit term necessary to reduce and essentially prohibit pollutants and non-stormwater discharges into the MS4 that will result in protecting local creeks and the Bay. The Stormwater Permit requires reduction of pollutants to storm drains from various activities such as routine municipal operations, new and redevelopment project sites, construction projects, and industrial and commercial facilities that could potentially contribute to stormwater pollution.
The Stormwater Permit requires the City to submit an Annual Report by September 30 of each year, documenting actions and the performance of required City, resident and business actions and certifying Stormwater Permit compliance for the reporting fiscal year. The Annual Report follows a standardized reporting template approved by the Water Board, used by all 79 permitted agencies (including the City) throughout the Bay Area. The referenced Annual Report fulfills the requirement for reporting on activities undertaken from July 1, 2024, through June 30, 2025.
Collaborative citywide effort is critical to prevent stormwater pollution and protect water quality, and the following City departments are actively engaged in a One Team approach: Airport, Environmental Services (ESD); Fire, Housing, Parks, Recreation, and Neighborhood Services (PRNS); Planning, Building, and Code Enforcement (PBCE); Public Works (PW); Transportation (DOT); and the City Attorney’s Office (CAO), with support from the City Manager’s Office of Economic Development and Cultural Affairs and the City Manager’s Budget Office. ESD provides citywide permit oversight, consults and coordinates implementation across these various City departments, co-leads with Valley Water, and participates in the Santa Clara Valley Urban Runoff Pollution Prevention Program.
ANALYSIS
City departments implementing Stormwater Permit requirements worked diligently to meet the challenge of implementing both new and existing programs to comply with the new Stormwater Permit’s requirements. The final draft FY 2024-2025 Stormwater Permit Annual Report is available on the City website at
www.sanjoseca.gov/stormwaterannualreports
. Once approved by City Council, the final
document will be submitted to the Water Board by September 30, 2025.
Accomplishments during FY 2024-2025 demonstrate the collective efforts of City departments to improve the condition of local creeks and waterways and reduce pollutant loads to San Francisco Bay. The accomplishments are summarized below.
HONORABLE MAYOR AND CITY COUNCIL
September 2, 2025
Subject: Stormwater Management Annual Report 2024-2025
New Development, Redevelopment, and Green Stormwater Infrastructure (GSI) (Provision C.3)
The Stormwater Permit mandates that new development and redevelopment projects include design features and controls that reduce pollution in stormwater and prevent additional runoff into the MS4. Compliance is achieved primarily through the development review, planning, and permitting processes by ensuring water quality protection is integrated into new and redevelopment projects. For FY 2024-2025, there were 45 C.3 Regulated Projects that were approved versus 31 in FY 2023-2024. Table 1 is a breakdown of both private and public-sector developments approved during the Stormwater Permit term that met the criteria to implement GSI in their designs.
Projects Approved FY 2024-2025 FY 2023-2024 FY 2022-2023 Private Development 41 27 48
Public Development 4 4 3
Total 45 31 51
The Stormwater Permit further requires regular inspections to ensure proper installation, operation, and maintenance of GSI. In FY 2024-2025, City staff inspected 161 projects, or 24% of the total inventory of GSI projects, which complies with the Stormwater Permit requirement to inspect 20% of the GSI Project Inventory per year. Since the implementation of targeted early outreach and education efforts for GSI owners in FY 2022-2023, staff have started to see improvements in GSI maintenance and conditions, with 37% of projects inspected in FY 2024-2025 found to be compliant upon initial inspection compared to 34% prior to implementation of targeted outreach. For the remaining projects, staff issued enforcement actions as needed and worked with property owners to ensure all GSI met regulatory compliance. Staff continue to build upon and expand outreach efforts and expect to see more significant improvements in future years.
In FY 2024-2025, the City completed the Riverview Stormwater Garden, Santa Clara County’s first regional GSI installation. This project recently received the California Stormwater Quality Association’s 2025 award for Outstanding Stormwater Capture and Use Implementation Project. This project converted an existing flood management basin into a bioretention basin and park that treats stormwater runoff from approximately 340 acres of north San José, fulfilling the Stormwater Permit requirement to construct GSI.
Building off this success, PW has identified future regional GSI projects and anticipates design beginning in early FY 2025-2026 with construction completion for one project in fall 2027.
Table 1: Approved Regulated Projects per Fiscal Year
HONORABLE MAYOR AND CITY COUNCIL
September 2, 2025
Subject: Stormwater Management Annual Report 2024-2025
Trash Load Reduction (Provision C.10) and Discharges from Unsheltered Homeless Populations (Provision C.17)
The Stormwater Permit requires the City to reduce and eliminate trash passing through the MS4 to protect waterways. This provision mandates 100% trash load reduction without offsets by June 30, 2025; however, the City was granted a six-month extension due to the Water Board approving the City’s Direct Discharge Trash Control Program plan (Direct Discharge Plan) in June 2024.
Table 2: FY 2024-2025 Trash Load Reduction Percentage Calculation
Trash Control Measure Percent Credit
Full Trash Capture Systems 59.5%
On-land Trash Control Measures/Private Lands
% from private land drainage areas 18.3%
% from on-land efforts 19.9%
Subtotal 38.2%
Total without offsets or credits 97.7%
Jurisdictional Source Control credit 0%
Additional Creek and Shoreline Cleanups offset 10%
Direct Discharge Trash Control Plan offset 15%
Total with offsets and credits >100%
As shown in Table 2, for FY 2024-2025, the City’s trash load reduction as of June 30, 2025 is over 100% with offsets from the Direct Discharge Plan and Additional Creek and Shoreline Cleanups, and 97.7% without offsets. This was achieved through a combination of full trash capture systems designed and installed by PW and maintained by DOT, implementation of a new Private Lands Inspection Program led by ESD, on- land trash control efforts implemented by PRNS, DOT, PBCE and ESD, and offsets earned by implementing an approved Direct Discharge Plan (15%) and by conducting creek and shoreline cleanups (10%) through partnerships with Housing and PRNS staff, non-profit groups, and contractors. While the creek and shoreline offset has sunset and the Direct Discharge Plan offset will sunset in December 2025, the City is required to continue the direct discharge work and provide progress reports throughout the Stormwater Permit term (June 30, 2027) to comply with Provision C.17: Discharges Associated with Unsheltered Homelessness Populations.
Staff are evaluating how to increase additional full trash capture controls and expand existing and/or implement new on-land trash control measure programs to achieve 100% trash load reduction without offsets or credits by December 31, 2025, and help maintain compliance throughout the permit term which ends June 30, 2027.
HONORABLE MAYOR AND CITY COUNCIL
September 2, 2025
Subject: Stormwater Management Annual Report 2024-2025
Full Trash Capture Device Installation (Provision C.10) Since 2011, the City installed and maintains a total of 30 large full capture Hydrodynamic Separator systems consisting of 36 underground devices in the MS4 that intercept trash before it enters into waterways. The installation of three additional large systems with an estimated 2.5% trash load reduction potential has been delayed due to contractor performance issues. PW will rebid two of these three projects, with an estimated installation by fall 2026. In FY 2024-2025, PW installed 462 new small trash capture devices called Connector Pipe Screens. These new devices, combined with the 90 previously installed, are full trash capture devices installed within storm drain inlets that retain trash and debris in the catch basin until it is removed by DOT staff.
Collectively, these systems treat over 15,100 acres. The City claims 59.5% trash load reduction for full trash capture systems.
On Land Visual Assessment and Private Lands Drainage Areas (Provision C.10) Several City departments implement various programs that also help to reduce and prevent litter entering into storm drains and waterways. The impacts of these programs are estimated based on the amount of observed litter on San José streets through a standardized protocol established throughout California called On-Land Visual Trash Assessment. This process is conducted annually along approximately 150 randomly selected streets where full trash capture devices have not been installed.
In addition, the Stormwater Permit requires private parcels which are a) directly connected to the City’s MS4, b) are rated ‘moderate', ‘high’ or ‘very high’ trash generating, and c) are not treated by existing full trash capture devices to install such devices or implement acceptable alternative trash management actions to reduce trash loads by June 30, 2025. ESD assessed over 2,400 private parcels, with 234 private parcels meeting these criteria. These private parcels are required to install structural full trash capture controls or implement acceptable alternative trash management actions to meet compliance. For these two programs, the City claims a total of 38.2% towards meeting the trash load reduction goal.
Additional Creek and Shoreline Cleanups (Provision C.10) Nonprofits - Keep Coyote Creek Beautiful and South Bay Clean Creeks Coalition are invaluable partners on projects that mitigate the impacts of trash on Coyote Creek, Guadalupe River, and Los Gatos Creek. Since 2021, Keep Coyote Creek Beautiful and South Bay Clean Creeks Coalition were funded by a $1.5 million grant from the U.S.
Environmental Protection Agency to engage and educate the community about protecting waterways. This grant expired as of June 30, 2025. In FY 2024-2025, these groups held 21 volunteer creek cleanups, removed more than 33 tons of trash and debris from the City's waterways, and engaged 745 volunteers who contributed over 1900 hours to cleanup efforts. Additional creek and shoreline cleanups led by City departments, non-profits, and community groups removed over 74.8 tons of trash in FY 2024-2025. While the 10% offset for this work is no longer applicable after June 30, 2025, these nonprofit partners are integral to engaging with communities and their connection with nature and City’s watersheds, as well as contributing to the City’s
HONORABLE MAYOR AND CITY COUNCIL
September 2, 2025
Subject: Stormwater Management Annual Report 2024-2025
efforts to comply with regulatory requirements to keep waterways clean. City staff will continue to seek grant funding to support these nonprofit partners.
Direct Discharge Trash Control Program (Provisions C.10 and C.17) The City’s watersheds are severely impacted by the activities of people experiencing unsheltered homelessness who reside along the City’s waterways. The Direct Discharge Plan is intended to address the water quality impacts resulting from unsheltered homelessness and lived in vehicles near storm drains. This is accomplished by providing housing, social services, removal of trash and debris, sanitary services (such as the City’s Recreational Vehicle Pollution Prevention Program led by PRNS and port-o-potties, laundry, showers, and hand washing stations funded by the Housing Department), installing and repairing structural deterrents, and monitoring and abating as needed to ensure that “No Encampment Zones” remain clear and held along waterways and near storm drains. ESD conducts quarterly visual assessments of the waterways in the Direct Discharge Plan areas to measure the progress of these efforts on the creeks. ESD, Housing, PRNS, DOT, PW, PBCE, Library, and the Police Department partner to implement the Direct Discharge Plan with the objectives of reducing and preventing discharges from entering approximately 26 miles of Coyote Creek, Guadalupe River, and Los Gatos Creek. See Table 3 for tonnage removed. To date, approximately 16 out of 26 miles of waterway focus zones were abated.
Table 3: Tonnage removed by Direct Discharge Plan efforts
The City has invested significant effort and resources to address unsheltered homelessness, as detailed in the Direct Discharge Progress Report attached to the Annual Report. These efforts align closely with the City’s overall efforts in managing and ending homelessness. The City claimed the maximum allowable 15% trash load reduction offset for trash removed in FY 2024-2025. Please note that the 15% offset will sunset by December 31, 2025.
Fiscal Year Tons Removed
FY 2016-2017 581 tons
FY 2017-2018 890 tons
FY 2018-2019 523 tons
FY 2019-2020 446 tons
FY 2020-2021 349 tons
FY 2021-2022 432 tons
FY 2022-2023 1,289 tons
FY 2023-2024 1,645 tons
FY 2024-2025 1,884 tons
HONORABLE MAYOR AND CITY COUNCIL
September 2, 2025
Subject: Stormwater Management Annual Report 2024-2025
Mercury, Polychlorinated Biphenyls (PCBs) Controls (Provisions C.11, C.12) The Stormwater Permit requires permittees, through a Countywide Control Measure Plan, to implement specific actions through detailed steps to identify and abate mercury and PCBs from old industrial areas entering the MS4. In FY 2024-2025, the City continued investigations in designated old industrial areas to identify properties discharging elevated levels of mercury and PCBs into the City's right-of-way or MS4. To date, 10 source and one moderate properties of mercury and/or PCBs contamination have been identified, and seven source properties have been referred to the Water Board for abatement. City staff will continue required monitoring to identify contaminated sites within its jurisdiction.
The Stormwater Permit imposed additional requirements for the building demolition of applicable structures that contain PCBs testing at 50 parts per million or above. City staff reviewed 29 demolition permits and identified three potentially applicable structures in FY 2024-2025, all of which contained less than 50 parts per million PCB’s.
Information about the program is available at www.sanjoseca.gov/ManagingPCBs.
Discharges from Emergency Firefighting Operations (Provision C.15.b) Fire and ESD actively participated in two regional Firefighting Discharges Working and Task Force Groups to assess the adequacy of existing Best Management Practices and standard operating procedures to address the potential adverse water quality impacts of firefighting water and foam discharged during emergencies. These efforts culminated with the development of a Regional Firefighting Discharges Report (included in the Annual Report) to be submitted to the Water Board by September 30, 2025. Key recommendations include:
• Train firefighting personnel on use of Best Management Practices; • Improve communication and coordination procedures between firefighting personnel and cleanup crews to ensure effective communication and discharge management; and
• Purchase and use the least environmentally harmful foams.
The City will begin implementing best practices outlined in the Annual Report in FY 2025-2026.
Cost Reporting (Provision C.20)
This new provision of the Stormwater Permit is intended to provide a high-level fiscal analysis of the costs incurred by permittees to comply with the Stormwater Permit. This includes budgeted capital, implementation, operation, maintenance, and program management costs. FY 2024-2025 is the first year permittees, such as the City of San José, must report their costs. The City compiled budgeted and/or actual operational and capital costs from 10 different City departments that implement functions required to comply with the Stormwater Permit and report a total estimated cost of $123,982,000 in FY 2024-2025. Table 4 highlights the costs for three permit provisions that incurred the highest costs in FY 2024-2025 and the estimated costs for FY 2025-2026.
HONORABLE MAYOR AND CITY COUNCIL
September 2, 2025
Subject: Stormwater Management Annual Report 2024-2025
Table 4: Cost Reporting Highlights
Permit
Provision
FY 2024-2025
Costs
FY 2025-2026
Costs (estimate)
C.3 $14,665,000 $15,478,000
C.10 $28,286,000 $29,351,000
C.17 $63,982,000 $69,388,000
These funding sources are a combination of grants from federal and state sources, bond measures such as Measure E and Measure T, fees, enterprise funds such as the Storm Sewer Operating Fund and the Airport Enterprise Fund, the Storm Sewer Capital Fund, and the General Fund.
It is anticipated that the estimated total expenditure for FY 2025-2026 will increase to $132,402,000, mainly due to higher costs associated with discharges of unsheltered homeless populations.
Asset Management Plan (Provision C.21)
The purpose of this new provision is to develop and implement an Asset Management Plan to ensure all City-owned physical stormwater quality assets installed to comply with Stormwater Permit requirements are adequately maintained. These assets include full trash capture devices and green stormwater infrastructure installations inspected, operated, and maintained by the City’s departments of Airport, ESD, PRNS, DOT, and PW. The Asset Management Plan includes processes for condition assessment, risk analysis, and maintenance prioritization for the City’s 561 GSI and 588 full trash capture assets. The Asset Management Plan is attached to the Annual Report and the City began implementing it in July 2025 as required by the Stormwater Permit.
EVALUATION AND FOLLOW-UP
Staff will provide an Annual Report on FY 2025-2026 Stormwater Permit compliance to City Council in September 2026.
COST SUMMARY/IMPLICATIONS
There are no direct costs associated with the submittal of the City of San José Annual Report for 2024-2025, as the report summarizes expenditures from departments that were funded and have already occurred. The estimated total expenditure for FY 2024- 2025 was $123.9 million. It is anticipated that the estimated total expenditure for FY 2025-2026 will increase to $132.3 million. There may potentially be new expenses associated with City efforts to implement Stormwater Permit requirements or expand existing programs that would be brought forward in a future budget process.
HONORABLE MAYOR AND CITY COUNCIL
September 2, 2025
Subject: Stormwater Management Annual Report 2024-2025
COORDINATION
The Annual Report was developed by ESD in coordination with the Airport Department, CAO, City Manager’s Budget Office, City Manager’s Office of Economic Development and Cultural Affairs, Fire Department, Housing Department, PRNS Department, PBCE Department, PW Department and DOT. The Annual Report was reviewed by each of these departments to ensure that the data and information presented in the report accurately and properly reflects their respective operations.
PUBLIC OUTREACH
This memorandum will be posted on the City’s Council Agenda website for the September 23, 2025 City Council meeting.
COMMISSION RECOMMENDATION AND INPUT
There are no commission recommendations or input associated with this action.
CEQA
Not a Project, File No. PP17-009, Staff Reports, Assessments, Annual Reports, and Informational Memos that involve no approvals of any City Action.
PUBLIC SUBSIDY REPORTING
This item does not include a public subsidy as defined in section 53083 or 53083.1 of the California Government Code or the City’s Open Government Resolution.
/s/
Jeff Provenzano
Director, Environmental Services
Department
For questions, please contact Rajani Nair, Deputy Director, Environmental Services Department at (408) 799-7462 or email [email protected] .
ATTACHMENT:
City of San José Stormwater Management Annual Report 2024-2025 - Final Draft