TO: Mayor and City Council
FROM: Philippe Eskandar, City Manager
BY: Amber Shah, Parks & Public Works Director/City Engineer DATE: September 9, 2026
SUBJECT: MEMORANDUM OF AGREEMENT REGARDING THE
ADMINSTRATION AND COST SHARING FOR
IMPLEMENTING THE COORDINATED INTEGRATED
MONITORING PROGRAM (CIMP) AND WATERSHED
MANAGEMENT PROGRAM (WMP) FOR THE UPPER LOS
ANGELES RIVER WATERSHED MANAGEMENT AREA
STRATEGIC PLAN CRITICAL SUCCESS FACTORS
Fiscally Responsible and Transparent City Government
Well-Maintained Infrastructure
BACKGROUND
On November 8, 2012, the Los Angeles Regional Water Quality Control Board (Regional Board) adopted the 2012 National Pollutant Discharge Elimination System Municipal Separate Storm Sewer System (MS4) Permit, Order No. R4- 2012-0175. This was re-adopted in the 2021 Regional Phase I MS4 Permit Order No. R4-2021-0105. The requirements of the 2012 MS4 Permit were subsequently superseded by the 2021 Regional Phase I MS4 Permit became effective on September 11, 2021, superseding the 2012 MS4 Permit, Order No. R4-2021-0105, which became effective September 11, 2021.
The 2021 MS4 Permit established requirements for municipal stormwater systems operated by the County of Los Angeles, Los Angeles County Flood Control District, 85 cities within the coastal watersheds of Los Angeles County, the Ventura County Watershed Protection District, the County of Ventura, and 10 cities within Ventura County.
Tony Chou, Mayor
Calvin Lo, Vice Mayor
Hunter Chang, Council Member
John Chou, Council Member
Gretchen Shepherd Romey, Council Member
Within the Upper Los Angeles River Watershed Management Area (ULAR WMA), the City of San Marino is one of the local agencies responsible for complying with the MS4 Permit. The ULAR WMA also includes the City of Los Angeles, County of Los Angeles, Los Angeles County Flood Control District, and the Cities of Alhambra, Burbank, Calabasas, Glendale, Hidden Hills, La Canada Flintridge, Montebello, Monterey Park, Pasadena, Rosemead, San Fernando, San Gabriel, South El Monte, South Pasadena, and Temple City.
The MS4 Permit requires permittees to implement monitoring and watershed management activities designed to assess and improve stormwater and receiving-water quality. Because these requirements are regional in scope and affect multiple jurisdictions within the watershed, the participating agencies have elected to coordinate compliance activities through the ULAR Watershed Management Group (WMG).
The primary components of this regional effort include:
• Coordinated Integrated Monitoring Program (CIMP): The CIMP provides for coordinated monitoring of stormwater and receiving water quality conditions and progress toward achieving applicable waterquality objectives. Activities include program administration, sample collection, in-situ measurements, laboratory analyses, monitoring of stormwater and non-stormwater outfalls, tracking of required studies, data analysis, and reporting to the Regional Board.
• Watershed Management Program (WMP): The WMP requires
ongoing management, reporting, and implementation activities to demonstrate compliance with the MS4 Permit and track progress toward watershed water-quality goals. Activities include preparation of required reports, updates to the watershed management plan, trash monitoring and reporting, preparation of required regulatory submittals, and implementation of watershed-specific studies and strategies.
The City of San Marino has participated with the other ULAR WMA permittees in developing and implementing the CIMP and the WMP. The City Council has previously approved Memorandum of Agreements (MOAs) governing administration of these programs and allocation of associated costs among participating agencies, most recently in 2016, 2018 and 2023. The 2023 MOA expired on June 30, 2026, while the proposed successor MOA was being finalized. Staff recommend that the City Council approve the proposed MOA to ensure the City’s continued participation in the ULAR WMA regional compliance and cost-sharing program.
DISCUSSION
The proposed MOA provides a continuation of the regional framework through which the ULAR WMA permittees collectively implement required CIMP and WMP activities and share the associated costs.
Under the proposed MOA, the participating agencies will cooperatively fund the estimated costs of implementing the CIMP and WMP. The City of Los Angeles, as the lead agency for the ULAR WMG, will complete or manage completion of the work on behalf of the participating permittees.
Major activities anticipated under the agreement include:
• Preparation of the semi-annual Progress Monitoring Reports and Annual Watershed Report to the Regional Board;
• Preparation and implementation of an Adaptive Management Plan to update the WMP;
• Implementation of the Trash Reporting and Monitoring Plan; • Preparation of the Report of Waste Discharge;
• Completion of the load reduction strategy necessary to address applicable bacteria Total Maximum Daily Load requirements; and • Implementation of potential special studies and other watershed activities required under the MS4 Permit.
The San Gabriel Valley Council of Governments (SGVCOG) has administered the ULAR WMG since 2018 and will continue to serve as the administrative entity under the proposed MOA. This includes administering the cost-sharing arrangement and invoicing the individual permittees for their respective share of the program costs.
The proposed MOA would be retroactively effective July 1, 2026, through June 30, 2029, with an option for two additional one-year extensions through June 30, 2031.
Participation in the regional program provides the City with access to the technical, monitoring, regulatory, and administrative resources necessary to satisfy its MS4 Permit obligations. The City does not have sufficient staff or specialized technical resources to independently perform all the required watershed monitoring, laboratory, reporting, and regulatory compliance activities. Continued participation in the regional program therefore provides the most practical and cost-effective means of meeting the City's obligations.
FISCAL IMPACT & PROCUREMENT REVIEW
The cost-sharing methodology allocates program costs based on each permittee’s proportionate land area within the ULAR Watershed. Under the proposed MOA, the City’s share is approximately 0.78 percent of the total program costs.
The City’s estimated cost over the five-year period is $63,359, as follows:
FY 26-27 FY 27-28 FY 28-29 FY 29-30 FY 30-31 TOTAL
$12,214 $12,013 $14,654 $12,140 $12,338 $63,359
The SGVCOG will invoice the City annually for its applicable share of the program costs. The City’s share is budgeted for in the Public Works Operating budget, Account #101-44-4460-5170. Sufficient funds are available in the FY 2026-27 budget to fund the City’s share for the first year of the agreement.
Funding for subsequent years will be included in the City’s annual operating budgets, subject to City Council approval.
Because the proposed MOA established the City’s participation in a cooperative regional compliance program rather than the procurement of a standalone service, no separate City procurement process is required.
LEGAL REVIEW
The City Attorney's office has reviewed and approved as to form.
RECOMMENDATION
Staff recommend that the City Council enter into a Memorandum of Agreement regarding the administration and cost sharing for implementing the Coordinated Integrated Monitoring Program (CIMP) and Watershed Management Program (WMP) for the Upper Los Angeles River Watershed Management Area for FY 2027-2031. If the City Council concurs with staff’s recommendation, an appropriate motion would be:
“I move to enter into a Memorandum of Agreement between the City of Los Angeles, County of Los Angeles, Los Angeles County Flood Control District, the Cities of Alhambra, Burbank, Calabasas, Glendale, Hidden Hills, La Canada Flintridge, Montebello, Monterey Park, Pasadena, Rosemead, San Fernando, San Gabriel, San Marino, South El Monte, South Pasadena, Temple City, and the San Gabriel Valley Council of Governments regarding the administration and cost sharing for implementing the Coordinated Integrated Monitoring Program (CIMP) and Watershed Management Program (WMP) for the Upper Los Angeles River Watershed for FY 2026-27 through FY 2028-29 and authorize the City Manager to execute the Agreement on behalf of the City, as well as execute two additional one-year extensions subject to the necessary budget appropriation.”
ATTACHMENTS
1. Draft Memorandum of Agreement