Santa Barbara City Council
August 25, 2026

CITY OF SANTA BARBARA

CITY COUNCIL
Randy Rowse
Mayor
Kelly McAdoo
City Administrator
Kristen W. Sneddon
Mayor Pro Tempore
Oscar Gutierrez
Ordinance Committee Chair
John S. Doimas
City Attorney
Eric Friedman
Finance Committee Chair
Meagan Harmon
Mike Jordan
Wendy Santamaria
City Hall
735 Anacapa Street
http://www.SantaBarbaraCA.gov
AUGUST 25, 2026, 2:00 PM
AGENDA
IN-PERSON PUBLIC COMMENT: At the beginning of each meeting of the City Council, Finance Committee, or Ordinance Committee, any member of the public may address the City Council concerning any item not on the Council's agenda. Any person wishing to make such address should first complete and deliver a "Request to Speak" form prior to the time that public comment is taken up by the City Council. Each speaker will be given a total of 3 minutes to address the Council. Pooling of time is not allowed during general public comment. The time allotted for general public comment at the beginning of the 2:00 p.m. session is 30 minutes.

Any member of the public who did not speak during the 2:00 p.m. session but who submitted a request to do so during the 2:00 p.m. 30 minute session may do so at the end of the meeting when the additional “Public Comment (If Necessary)” is announced. The City Council, upon majority vote, may decline to hear a speaker on the grounds that the subject matter is beyond their jurisdiction.

REMOTE PUBLIC COMMENT: Members of the public wishing to speak must “raise their hand” in the Zoom platform by selecting the virtual hand icon when their item is called. The keyboard shortcut for this is Alt+Y for Windows and Option+Y for Macs. City staff will activate the speaker’s microphone when the speaker’s name is called. The speaker will then need to unmute themselves. The keyboard shortcut for this is Alt+M for Windows or Command-Shift-A for Macs.

HOW TO REMOTELY OBSERVE AND/OR SPEAK LIVE AT A MEETING
• Web: https://santabarbaraca-gov.zoom.us/j/89359334270 (Participation via Zoom) • Telephone: Dial 1-669-900-6833, Enter Webinar ID: 893 5933 4270 (press *9 to raise/lower hand; press *6 to mute/unmute) • Online Streaming: Council meetings are streamed live at www.SantaBarbaraCA.gov/CAP • TV: Each regular City Council meeting is broadcast live in English and Spanish on City TV Channel 18 and rebroadcast in English on Wednesdays and Thursdays at 7:00 p.m. and Saturdays at 8:00 a.m., and in Spanish on Sundays at 3:00 p.m.

Each televised Council meeting is closed captioned for the hearing impaired. Check the City TV program guide at www.santabarbaraca.gov/citytv for rebroadcasts of Finance and Ordinance Committee meetings.

WRITTEN PUBLIC COMMENT: Public comments may also be submitted via email to [email protected] prior to the beginning of the Council Meeting. All public comments submitted via email will be provided to City Council and will become part of the public record.
(CONTINUED ON NEXT PAGE)
ORDER OF BUSINESS: Regular meetings of the Finance Committee and the Ordinance Committee begin at 12:00 p.m. The regular City Council meeting begins at 2:00 p.m. in the Council Chambers at City Hall.

REPORTS: Copies of the reports relating to agenda items are available for review at http://www.SantaBarbaraCA.gov/CAP.In accordance with state law requirements, this agenda generally contains only a brief general description of each item of business to be transacted or discussed at the meeting. Should you wish more detailed information regarding any particular agenda item, you are encouraged to obtain a copy of the Council Agenda Report (a "CAR") online at the City's website (http://www.SantaBarbaraCA.gov/CAP). Materials related to an item on this agenda submitted to the City Council after distribution of the agenda packet are posted to the City’s website as soon as reasonably feasible.

CONSENT CALENDAR: The Consent Calendar is comprised of items that will not usually require discussion by the City Council. A Consent Calendar item is open for discussion by the City Council upon request of a Councilmember, City staff, or member of the public. Items on the Consent Calendar may be approved by a single motion. Should you wish to comment on an item listed on the Consent Agenda, after turning in your "Request to Speak" form, you should come forward to speak or raise your hand in Zoom at the time the Council considers the Consent Calendar.

LANGUAGE TRANSLATION AND INTERPRETATION: The City of Santa Barbara offers live Spanish translation and interpretation for City Council Meetings via the Wordly platform. Follow the directions below to access the service. • Go to: https://attend.wordly.ai/join/QQBV-6746
o Ensure the Session ID QQBV-6746 is displayed.
o Select “Spanish” and click on the “Attend” button.
o You can now read the captions on your device and/or listen to the translation of the City Council meeting. o Click the speaker button to hear a text-to-speech version of the translated dialogue. • If you have any questions or concerns, please contact City TV at 805-564-5311.

SPANISH INTERPRETATION: If you need interpretation of your communications to Council from Spanish into English, please contact the City Clerk’s Office at 564-5309 or by email at [email protected]. If possible, notification of at least 48 hours will usually enable the City to make arrangements.

INTERPRETACIÓN EN ESPAÑOL: Si necesita una interpretación del español al inglés, para sus comunicaciones al Consejo, comuníquese con la Oficina del Secretario Municipal al 564-5309, o por correo electrónico a [email protected]. Si es posible, la notificación de al menos 48 horas generalmente permitirá a la Ciudad hacer los arreglos.

AMERICANS WITH DISABILITIES ACT: If you need auxiliary aids or services or staff assistance to attend or participate in this meeting, please contact the City Administrator's Office at 564-5305 or by email at [email protected]. If possible, notification at least 48 hours prior to the meeting will usually enable the City to make reasonable arrangements. For those who need accessibility accommodation in using the “raise hand” function and/or registering to participate in the Zoom session, please contact the Clerk’s office by 5:00 p.m. the day before the meeting for assistance. Additionally, a speaker may email [email protected] by 5:00 p.m. the day before a meeting, stating which item they wish to speak on. Specialized services, such as sign language interpretation or documents in Braille, may require additional lead time to arrange. 08/25/2026 Santa Barbara City Council Final Agenda Page 1 AUGUST 25, 2026 AGENDA
FINANCE COMMITTEE MEETING - 12:00 P.M. IN THE COUNCIL CHAMBER

1. Subject: Reserve Policy Discussion and Direction
Recommendation: That Finance Committee:

A. Receive a report from staff regarding the City Council Reserve Policy adopted on October 10, 2023; and
B. Provide direction to staff regarding changes to the Reserve Policy.

2. Subject: Operational Sustainability Initiative and Funding for the Local Housing Trust Fund
Recommendation: That Finance Committee:

A. Receive an update and provide direction to staff regarding the Operational Sustainability Initiative, including revenue generating and expenditure control options, to replenish General Fund disaster reserves in Fiscal Year (FY) 2027; and
B. Receive an update and provide direction to staff regarding an ongoing funding source(s) for the Local Housing Trust Fund (LHTF). 08/25/2026 Santa Barbara City Council Final Agenda Page 2 REGULAR CITY COUNCIL MEETING - 2:00 P.M.

CALL TO ORDER

PLEDGE OF ALLEGIANCE

ROLL CALL

CEREMONIAL ITEMS

1. Subject: Recognition of Santa Barbara Foresters as 2026 National Baseball Congress World Series Champions

CHANGES TO THE AGENDA

CONSENT CALENDAR

2. Subject: Waiver of Reading in Full of Ordinances and Resolutions Recommendation: That Council waive the reading in full of all ordinances and resolutions on the consent agenda and the public hearing consent agenda and authorize reading by title only, pursuant to City Charter Section 511, unless otherwise requested by a member of the City Council; this waiver shall not apply to emergency ordinances, which shall be read in full as required by Section 511.

3. Subject: Introduction of an Ordinance to Amend Municipal Code Title 16 Liquid and Industrial Waste Disposal, and to Update Standard Condition and Pretreatment Program Administrative Documents [Ordinance Introduction] Recommendation: That Council:

A. Introduce and subsequently adopt, by reading of title only, an Ordinance of the Council of the City of Santa Barbara Amending Title 16 of the Santa Barbara Municipal Code Relating to Liquid and Industrial Waste Disposal by the Amendment of Various Sections to Authorize the Water Resources Director to Establish and Implement an Electronic Document Receiving System Consistent with the Federal Cross-Media Electronic Reporting Rule and to Designate the Water Resources Director in Place of the Public Works Director in Various Sections or Subsections of Title 16; and B. Authorize staff to submit an update of City of Santa Barbara pretreatment program administrative documents to the Regional Water Quality Control Board as a pretreatment program modification to be approved under 40 CFR Part 403.18.
08/25/2026 Santa Barbara City Council Final Agenda Page 3

4. Subject: Amend Agreement with OpenGov, Inc., Extending Budget and Planning (On-Line Digital Budget Book) Services for Two Years [Agreement] Recommendation: That Council approve an Amendment to Professional Services Contract 28,451 with OpenGov, Inc., for Budget and Planning (Online Digital Budget Book), extending services through July 31, 2028.

REPORT FROM THE FINANCE COMMITTEE

GENERAL PUBLIC COMMENT

PULLED CONSENT ITEMS

CITY COUNCIL ADMINISTRATIVE AND ATTORNEY REPORTS

POLICE DEPARTMENT

5. Subject: Nonrenewal of Flock Contract
Recommendation: That Council receive a report regarding the nonrenewal of the Flock Camera system and the staff recommended alternative to this system consistent with Council direction earlier this year.

COUNCIL AND STAFF COMMUNICATIONS

COUNCILMEMBER COMMITTEE ASSIGNMENT REPORTS & ENGAGEMENTS

PUBLIC COMMENT (IF NECESSARY)

ADJOURNMENT

CITY OF SANTA BARBARA

FINANCE COMMITTEE MEETING

MEETING AGENDA
Agenda Date: August 25, 2026
Meeting Time: 12:00 PM
Meeting Location: Council Chambers
Finance Committee: Eric Friedman, Committee Chair
Wendy Santamaria, Committee Vice Chair
Meagan Harmon, Committee Member
Staff: Kelly McAdoo, City Administrator
John S. Doimas, City Attorney
Keith DeMartini, Finance Director

HOW TO WATCH OR SPEAK AT A MEETING REMOTELY
Web: SantaBarbaraCA-gov.Zoom.US/s/85839766181 (Participation via Zoom).

Online Streaming: Finance Committee meetings are streamed live at SantaBarbaraCA.gov/CAP.

TV: Regular Finance Committee meetings are broadcast live in English and Spanish on City TV Channel 18. Check program guide for rebroadcast meeting schedule at SantaBarbaraCA.gov/CityTV.

Telephone: Dial 1-669-900-6833, Enter Webinar ID: 858 3976 6181 (press *9 to raise/lower hand; press *6 to mute/unmute).

REMOTE PUBLIC COMMENT: When your item is called, use the Zoom Raise Hand feature (Alt+Y on Windows or Option+Y on Mac), wait for staff to activate your microphone, then unmute to speak (Alt+M on Windows or Command+Shift+A on Mac).

PUBLIC COMMENT: Speakers may address items not listed on the agenda but under the purview of the Finance Committee at the start of the meeting. Speakers may address the Committee on any item listed on the agenda. Submit a "Request to Speak" form in advance. Each speaker will be given a total of three (3) minutes to address the Committee. Pooling time is not permitted. The Finance Committee Chair reserves the right to limit speakers’ time to less than three (3) minutes. Please note that a time cutoff may be announced during the meeting for submission of “Request to Speak” forms or raising of hands for public comment.

WRITTEN PUBLIC COMMENT: Email comments to [email protected] before the meeting. All emails are shared with the Finance Committee and will become part of the public record and may be posted online.

LANGUAGE TRANSLATION AND INTERPRETATION: The City offers live translation and interpretation for Finance Committee Meetings via the Wordly platform. Follow the directions below to access:
• Go to: Attend.Wordly.AI/Join/QQBV-6746.
o Ensure the Session ID QQBV-6746 is displayed.
o Select “Spanish” and click on the “Attend” button.
o You can now read the captions on your device.
o Select the speaker button to hear a text-to-speech version of the translated dialogue. • If you have any questions, please contact City TV at 805-564-5311.

SPANISH INTERPRETATION: If you need interpretation of your communications to Council from Spanish into English, please contact the City Administrator’s Office at 805-564-5305 or by email at [email protected]. If possible, notification of at least 48 hours will usually enable the City to make arrangements.

INTERPRETACIÓN EN ESPAÑOL: Si necesita una interpretación del español al inglés, para sus comunicaciones al Consejo, comuníquese con la Oficina del Administrador de la Ciudad al 805-564- 5305, o por correo electrónico a [email protected]. Si es posible, la notificación de al menos 48 horas generalmente permitirá a la Ciudad hacer los arreglos.

ITEMS FOR CONSIDERATION:

1. Subject: Reserve Policy Discussion and Direction
Recommendation: That Finance Committee:

A. Receive a report from staff regarding the City Council Reserve Policy adopted on October 10, 2023; and
B. Provide direction to staff regarding changes to the Reserve Policy.

2. Subject: Operational Sustainability Initiative and Funding for the Local Housing Trust Fund
Recommendation: That Finance Committee:

A. Receive an update and provide direction to staff regarding the Operational Sustainability Initiative, including revenue generating and expenditure control options, to replenish General Fund disaster reserves in Fiscal Year (FY) 2027; and B. Receive an update and provide direction to staff regarding an ongoing funding source(s) for the Local Housing Trust Fund (LHTF).

CITY OF SANTA BARBARA
Finance Committee Agenda Report
Agenda Date: August 25, 2026
To: Finance Committee
From: Finance Department
Subject: Reserve Policy Discussion and Direction
Recommendation:

That Finance Committee:

A. Receive a report from staff regarding the City Council Reserve Policy adopted on October 10, 2023; and
B. Provide direction to staff regarding changes to the Reserve Policy.

Discussion
The establishment, adherence, and continuous monitoring of a reserve policy is a local government best practice. The City strategically utilized reserves in recent years to be able to respond to local fires and other disasters, impacts from COVID, and other annual budget fluctuations to sustain operations and continue to provide services to the public. The City’s reserve policy sets reserve amounts for disaster and contingency reserves as well as laying out a process for requiring a balancing strategy and plan for replenishment.

Disaster reserves are calculated on 15.0% of the most recently adopted expenditure budget and are restricted to use in addressing impacts of natural disasters, such as storms, floods, wildfires, and droughts, among other events. Contingency reserves are calculated on 10.0% of the most recently adopted expenditure budget and may be used to address fiscal impacts of unexpected events, such as an unexpected loss of funding and damage to a City facility, among other events.

Any use of disaster or contingency reserves requires an assessment of the fiscal condition and outlook, a balancing strategy to minimize the use of reserves in the future, and a plan to replenish reserves.

Agenda Item No. 1
Finance Committee Agenda Report
Reserve Policy Discussion and Direction

The City Council has revised the reserve policy on multiple occasions over the last five years.

Those changes are summarized below:
• On December 7, 2021, the Finance Committee received a presentation from staff regarding significant pension costs and liabilities and considerations for implementing various pension management strategies to control and reduce pension costs in the future. The Committee directed staff to research and propose a pension management policy and incorporate it into the reserve policy.
• On September 27, 2022, staff proposed eliminating the requirement that 50.0% of any annual operating General Fund surplus go to capital and require that a proportional share of annual operating surpluses in the City’s General Fund, Enterprise, and Internal Service funds be allocated to address pension-related expenses and future liabilities. • On December 6, 2022, the City Council voted unanimously to approve Resolution No. 22-126 establishing one, consolidated, citywide reserve policy including staff’s proposed change that 50.0% of annual operating surplus be allocated to address pension-related expenses.
• On June 7, 2023, the City Council gave direction to staff to review Resolution No. 22-126 and direct staff to work with the Finance Committee during FY2024 to develop a plan to replenish reserves by FY2026. This direction, along with other efforts related to Vision 2030 and the Fiscal Sustainability Initiative, ultimately resulted in Measure I, the Maintaining Essential Services 0.25% sales tax measure, being placed on the November 5, 2024, ballot, which was ultimately approved by the voters. • On July 25, 2023, the Finance Committee voted unanimously to forward the following recommendations to the City Council:
o Recommend that the City Council adopt an ordinance amending the Santa Barbara Municipal Code by repealing Chapter 17.40 and transfer funds in the Harbor Preservation Fund into the Waterfront Capital Fund; o Consider opening a line of credit in the event of an emergency; o Consider reducing the disaster reserve policy target level from 15.0% by up to

5.0%, resulting in a 10.0% target level; and
o Consider directing the City Administrator to prepare and issue the City’s recommended budget in FY2025 and FY2026 with a revised policy reserve target Finance Committee Agenda Report
Reserve Policy Discussion and Direction

of 22.0% with a plan to replenish reserves to achieve the 25.0% target through the Fiscal Sustainability Initiative and Vision 2030.
• On September 12, 2023, the City Council approved staff’s recommended changes to the reserve policy and affirmed the 15.0% disaster reserve policy target, maintaining the total reserve policy target at 25.0%.
• On May 6, 2025, the City Council gave direction during the FY2026 and FY2027 budget hearing to schedule a Finance Committee meeting to discuss the reserve policy and consider reducing the contingency reserve target from 10.0% to 7.0%, which would result in an overall reserve policy target level of 22.0%, and other considerations. • On June 10, 2025, the Finance Committee received a report from staff regarding the status of General, Enterprise, and Internal Service Fund reserves. The Committee forwarded a recommendation to the City Council to agendize a future item for staff to provide an in-depth analysis of reserves, not during the budget cycle. The Committee supported the City Administrator’s recommendation for $3.0 Million in FY2026 and FY2027 for affordable housing, and an additional $2.0 Million in FY2026 to be repaid by a combination of General Fund reserves and/or Measure C and to revisit an additional appropriation for housing during the FY2027 budget process. • On October 14, 2025, the City Council received a report from staff regarding the reserve policy and did not make any amendments to the existing policy.

During the recent FY2027 budget deliberations, the City Council gave direction to staff to schedule a Finance Committee meeting to consider revisions to the General Fund reserve policy as follows:
• To be more in line with actual reserve levels;
• To clarify uses of reserves and terminology;
• To further define and prioritize the use of reserves during an emergency or disaster; and • To consider allocating any year-end General Fund surplus to remain in General Fund reserves, allocate to the pension Section 115 trust and allocate to the Local Housing Trust Fund (LHTF).

The Finance Committee can make recommendations to change the contingency reserve target of 10.0% and disaster reserve target of 15.0%. The Finance Committee can also provide direction to add a new section to the policy regarding the prioritization of General Fund Finance Committee Agenda Report
Reserve Policy Discussion and Direction

expenditures when actual contingency and/or disaster reserves are below the reserve policy target levels. For example, the policy could provide a framework to prioritize expenditures related to essential or mandated services over other General Fund programs and services. The Finance Committee can also provide direction to amend Section 8 related to the allocation of year-end surpluses to include an allocation into the LHTF as well as a prioritization as to how the surplus may be allocated among reserves, the Section 115 Trust and the LHTF.

The City Council reserve policy can be accessed on the City’s website here.

Budget/Financial Information
If the existing reserve policy were to be amended by reducing the contingency and/or disaster reserve percent, fewer reserves will be required to be set aside to adhere to the policy, which will result in fewer resources available to be used to address budget fluctuations and natural and other disasters in the future. It may also affect the City’s credit rating, which is evaluated annually and will be considered by rating agencies for future debt issuances funded by the Measure C district sales tax and other General Fund sources.

The General Fund reserves are currently well below required policy levels, projecting only

12.9% of annual expenditures in General Fund Reserves by the end of FY2026. $ MILLIONS FY2024
ACTUAL
FY2025
ACTUAL
FY2026

PROJECTION
FY2027

RECOMMENDED
BUDGET
Reserve Policy Target (25.0%) $45.4 $50.3 $53.2 $56.7
Actual / Projected Reserve Level $40.7 $35.1 $27.9 $27.0 Difference ($4.8) ($15.2) ($25.2) ($29.7)
Actual / Projected Reserve Percent 22.4% 18.4% 12.9% 12.1% With falling reserve levels and a projected operating deficit beyond FY2027, staff and the City Council will need to identify additional, ongoing funding to support existing operations to balance the General Fund budget in future years. Continuing to control expenditures will also need to be considered.

Without any additional revenue or expenditure reductions in the General Fund, an operating deficit is projected in FY2028 and beyond requiring additional reserves to be used to balance the budget. If no budget changes are made, all General Fund disaster reserves are projected to be depleted by the middle of FY2030.

Finance Committee Agenda Report
Reserve Policy Discussion and Direction

Attachment:

1. Resolution No. 23-124 Establishing Policies for Reserves for the City’s General Fund, Enterprise Funds and Internal Service Funds.

Prepared and
Submitted by: Keith DeMartini, Finance Director
Approved by: Kelly McAdoo, City Administrator
RESOLUTION NO. 23-124
A RESOLUTION OF THE COUNCIL OF THE C\TY OF SANTA

BARBARA ESTABLISHING POLICIES FOR RESERVES FOR

THE CITY'S GENERAL FUND, ENTERPRISE FUNDS AND

INTERNAL SERVICE FUNDS, AND AMENDING RESOLUTION
N0. 22-126.

WHEREAS, the City desires to establish policies regarding reserves for the various City funds for the purpose of providing consistent designations for different categories of reserves, ensuring fiscal security for the funds, and defining standards for minimum amounts to be maintained in reserves;
WHEREAS, such reserves policies will be most readily communicated and understood if they are consolidated and formally adopted in a single document; WhlEREAS, the Council has considered the proposed reserve policies applicable to the General Fund, Enterprise Funds, and Internal Service Funds at a regular Council meeting on September 12, 2023.

NOW, THEREFORE, BE IT RESOLVED BY THE COUNCIL OF THE CIT/ OF SANTA BARBARA THAT the following reserves policies are adopted SECTION 1: CALCULATION OF RESERVE AMOUNTS
Final reserve balances will be calculated at end of each fiscal year after the closing of the City's accounting records. An amount will be established for each fund, as applicable, as a commitment of fund balance for each type of reserve established by this policy.

As soon as practical after the close of a fiscal year, staff will provide City Council a report showing the status of reserves as of June 30. At any time it is proposed to utilize reserves pursuant to this policy, staff will provide a similar report on reserves and projected fiscal impact from the proposed use of reserves.

SECTION 2: DISASTER RESERVES
The amount of the required Disaster Reserve is calculated based on 15% of the most recently adopted fiscal year operating expenditure budget.

The Disaster Reserve is restricted to use in addressing the financial impacts of natural disasters, such as storm, floods, wildfires, droughts, tsunamis, earthquakes and any other event that results in significant damage to City facilities and infrastructure or a significant reduction of normal operating revenues.

ATTACHMENT
The use of Disaster Reserves should generally be limited to federal or state declared disasters. The use of Disaster Reserves is also allowable in cases where the natural disaster is less severe, such as a major fire to a City building that requires temporary facilities to be leased. Disaster reserves may be used only after other available funds are exhausted, including the Contingency Reserve.

Examples of financial impacts that would justify the use of Disaster Reserves include:
. Extraordinary costs incurred in connection with the immediate emergency response to address public safety matters.
. Revenue losses resulting from a significant decline or temporary halt in services due to major damage to facilities, infrastructure and local businesses. . Additional costs necessary to maintain City operations. . Long-term costs incurred to rebuild City facilities and infrastructure.

SECTION 3: CONTINGENCY RESERVES
The Contingency Reserve is calculated based on 10% of the most recently adopted fiscal year operating expenditure budget.

The purpose of the Contingency Reserve is to allow for the orderly implementation of a balancing strategy to address the fiscal impacts of unexpected events in order to minimize the impacts to the organization and community. The most common of these events would be an economic recession that results in a significant impact on key revenues such as sales, transient occupancy or property taxes.

Other unexpected events for which these reserves could be used include the following . Natural disasters, as described above for Disaster Reserves; . Revenue impacts resulting from State of California actions or unfunded State mandates;
. Unexpected loss of external funding from sources such as grants or entitlements, . An unplanned loss of, or damage to, a City facility such as the loss of a building due to fire;
. Mitigation of an emergency that poses a threat to public health and safety; and . An adverse judicial action that requires large cash payments to third parties and is not covered by insurance.

The general intent of the Contingency Reserve is for unexpected events or situations. In general, its purpose is not to fund known or anticipated financial impacts, such as negotiated salary and benefit increases or scheduled increases to health insurance premiums or retirement costs.

SECTION 4: COUNCIL APPROVAL OF DISASTER AND CONTINGENCY

RESERVES
Any use of the Disaster or Contingency resen/es described in Sections 2 and 3 requires a majority vote of approval by the City Council.

When the use of reserves is recommended to the City Council by staff, the justification should include the following elements:

An Assessment of the Fiscal Condition and Outlook:

This assessment should include an objective evaluation of the operating fund's fiscal condition and an evaluation of the impacts of the event that triggered the need to use reserves. The purpose of this evaluation is to measure and define the scope and duration of the problem to assist in developing an appropriate balancing strategy.

This assessment of fiscal condition should include the use of available and relevant financial and non-financial data, including economic and demographic indexes and trends; historical revenue and expenditures results; and local economic forecasts developed by recognized academic and financial institutions and paid consultants.

Balancing Strateav
The balancing strategy should include measures that minimize the use of Contingency Resen/es, such as:
. Expenditure reductions achieved through efficiency measures, cuts to programs, services and associated staffing;
. Revenue enhancement measures that generate new or increased revenues; . Use of existing one-time funds; and
. Use of available reserves in other funds, as allowable and appropriate.

The balancing strategy should also be consistent with the nature of the fiscal impact. For example, a one-time impact may be resolved fully with the use of reserves, depending on its severity. However, an event that has an ongoing financial impact, such as decline in revenues due to a major recession, wilt require a balancing strategy that includes ongoing budget and programmatic adjustments to minimize the use of reserves.

Plan of Re lenishment
The replenishment plan should include the following elements, as appropriate:
. A one-time (one-year) use of reserves should be accompanied by a specific plan for how and when the reserves will be restored.

An extended use of reserves for more than one year should be accompanied by a long-term strategy that includes a more general plan for how the reserves will be restored.

SECTION 5: ENTERPRISE FUNDS
Enterprise Funds will be subject to the same Disaster and Contingency Reserve and approval requirements as described in Sections 2, 3 and 4 of this resolution.

Each Enterprise Operating Fund will establish a Capital Reserve, funded to at least 5% of the value of its capital assets. Alternatively, the Capital Reserve may also be established at an amount equal to the average of the planned capital program budgets for the upcoming three fiscal years, excluding major capital projects that will be debt funded. Appropriations from Capital reserves are intended to address an unexpected capital project or unanticipated increase in capital projects. Capital reserves might also be funded in excess of the minimum in preparation for major (pay-go or cash funded) capital projects.

Another option for funding major future capital projects is a Working Capital reserve.

These specific capital reserves would be designated for the replacement of critical infrastructure projected to be funded within a ten-year period. There is no minimum for these reserves as they will function as a working capital reserve for funding of large and costly infrastructure on a routine basis. These include the Council approved Desalination Reserve (Resolution No. 21-082), as well as Main Replacement Reserves (restricted to maintaining, rehabilitating, and installing new main or transmission pipelines) in the Water and Wastewater Enterprise Funds.

Bond funding for the Water and Wastewater Enterprise Funds requires a rate stabilization reserve (as outlined in the 2013 and 2016 bond documents, Resolution No. 13-029 and 16-168 respectively). The minimum reserve requirement for the rate stabilization fund is $2. 9 million and $1. 0 million for the Water and Wastewater Funds respectively. These funds are differentiated from Disaster, Contingency and Capital reserves as they can be considered revenue for the purpose of debt service coverage in a given fiscal year, if they are transferred within 150 days of the end of the prior fiscal year. These reserve funds are restricted and must be maintained and used only for this purpose. Staff may make additional deposits to this reserve if there are anticipated threats to revenues that might exceed the minimum resen/e. This might include increasing probability of drought and the need for mandatory water conservation, or other negative impacts on revenues that might reasonably be expected. Deoosits into the rate stabilization fund must be reflected as reductions in revenues for the year the deposits are made.

The Solid Waste and Clean Energy Enterprise Operating Funds shall utilize the contingency reserve to buffer a significant loss in revenue or the impacts of significant rate increases. The use of these reserves should be considered one-time revenue as future rates will need to be adjusted to address any ongoing expense increases to operating the enterprise.

Where applicable, each Enterprise shall maintain any required debt service reserve to support the long-term borrowing and shall be restricted to the level of indebtedness of the utility.

The City shall also consider establishing a line of credit with a banking institution that may be leveraged for financing capital projects and in the event of a disaster. Leveraging a line of credit is a viable risk management approach and may address short-term cash flow needs and lessen the need to require disaster reserves in the future. A line of credit shall not be used to pay for operating expenses. The cost of establishing a tine of credit shall be considered in relation to the investment earnings that may be achieved through investing funds in line with the City's investment policy and other operating considerations.

SECTION 6: RESERVE REQUIREMENTS FOR INTERNAL SERVICE FUNDS Internal Service Funds are not subject to the reserve requirements for Disaster Reserves or Contingency Resen/es. Instead, Internal Service Funds will maintain an operating reserve equal to 10% of the operating budget of the most recently adopted budget. This resen/e will be available to address unexpected events and natural disasters that affect the operations and revenue streams of the Internal Service Funds.

All Internal Service Funds will be subject to the 10% reserve requirement, with the exception of the Self-lnsurance Fund, which by design builds up assets for the payment of claims several years into the future, and the Facilities Management Fund, which is based on 10% of the adopted Building Maintenance Program Budget. As a result, there should be adequate cash reserves to cover unanticipated costs. In addition, the reser/e requirements do not apply to Internal Service Funds that are specifically designed to accumulate reserves for capital, such as the Vehicle Replacement Fund.

SECTION 7: APPROPRIATED RESERVES
An Appropriated Resen/e will be included in each operating fund's adopted budget to provide for unanticipated expenditures or to meet unexpected small increases in service delivery costs within the fiscal year. For the General Fund, the appropriated reserve should be at least $250, 000. For Enterprise and Internal Service operating funds, this reserve will be at least one-half of one percent of the operating budget. Any unused portion of the appropriated reserve in each fund will be returned to fund balance at the end of the fiscal year.

SECTION 8: ALLOCATION OF GENERAL FUND, ENTERPRISE FUNDS AND

INTERNAL SERVICE FUNDS YEAR-END SURPLUS TO PENSION EXPENSES AND

LIABILITIES
At the end of each fiscal year, any General Fund, Enterprise Funds and Internal Service Funds surplus realized from actual revenues exceeding actual expenditures including the annual capital program will be used to maintain reserve balances at levels required by this policy as well as address pension-related expenses and future liabilities. The amount of reserves to be transferred to a Section 115 trust to address pension-related expenses and future liabilities will be determined based on the proportional burden of expenses and liabilities in each fund. Maintaining reserve balances will be the highest priority, followed by addressing pension-related expenses and future liabilities.

RESOLUTION NO. 23-124

STATE OF CALIFORNIA )
)
COUNTY OF SANTA BARBARA ) ss.
)

CITY OF SANTA BARBARA )
I HEREBY CERTIFY that the foregoing resolution was adopted by the Council of the City of Santa Barbara at a meeting held on October 10, 2023, by the following roll call vote:

AYES:

NOES:

Councilmembers Eric Friedman, Alejandra Gutierrez, Oscar Gutierrez, Mike Jordan, Kristen W. Sneddon, Mayor Randy Rowse.

None
ABSENT: Councilmember Harmon
ABSTENTIONS: None
IN WITNESS WHEREOF, I have hereto set my hand and affixed the official seal of the City of Santa Barbara on October 11, 2023.
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CITY OF SANTA BARBARA
Finance Committee Agenda Report
Agenda Date: August 25, 2026
To: Finance Committee
From: Finance Department
Subject: Operational Sustainability Initiative and Funding for the Local Housing Trust Fund
Recommendation: That Finance Committee:

A. Receive an update and provide direction to staff regarding the Operational Sustainability Initiative, including revenue generating and expenditure control options, to replenish General Fund disaster reserves in Fiscal Year (FY) 2027; and B. Receive an update and provide direction to staff regarding an ongoing funding source(s) for the Local Housing Trust Fund (LHTF).

Executive Summary
When the City Council adopted the budget for FY2027 on June 30, 2026, they directed staff to provide an update on the revenue generating and expenditure control options that staff initially developed in August 2025. Some of these options have already been implemented, and several are anticipated to be implemented during FY2027 to help balance the General Fund operating budget. Staff are seeking additional input and guidance from the City Council regarding the prioritization and additional options to consider to help replenish the General Fund disaster reserves.

Staff have also been focused on coordinating efforts related to budget balancing initiatives, strategic plan implementation and tracking, and other citywide efforts under a framework of Operational Sustainability Initiatives. The goal of this effort is to close the deficit and hold a balanced budget. This will create sustainable operations and promote best practices across the organization, prioritizing the most impactful initiatives from across both operational and strategic plan activity, including regular reporting to the Finance Committee and City Council as well as incorporation with the annual budget process.

Agenda Item No. 2
Finance Committee Agenda Report
Operational Sustainability Initiative and Funding for the Local Housing Trust Fund

At that same meeting, the City Council also directed staff to develop a list of possible, dedicated funding sources for the LHTF and present them to the Finance Committee. Staff have analyzed the Measure C and I district sales tax measures, in-lieu fees, transient occupancy tax (TOT), and future tax measures that would require voter approval as possible funding sources. Staff also intend to pursue private fundraising as part of building the LHTF endowment.

Discussion
General Fund Multi-Year Forecast
City staff routinely implement long-term financial forecasting best practices to serve as the City’s long-term planning and operating blueprint to ensure the City’s on-going financial sustainability spanning beyond the current budget cycle. The forecasting processes establish a framework to guide the City in planning, decision-making, and to create a purposeful approach to aligning short-term actions with long-term financial strategies.

The General Fund multi-year forecast is updated at least quarterly and presented to the Finance Committee and City Council. The table and graph below show the projected revenues and expenditures during the forecast period ending in FY2030. Note that the expenditures do not include the annual reserve contribution.

REVENUES &

EXPENDITURES
($ Millions)
FY2025
ACTUAL
FY2026

PROJECTION
FY2027
BUDGET
FY2028

FORECAST
FY2029

FORECAST
FY2030

FORECAST
Revenue $216.8 $243.4 $257.1 $263.3 $268.9 $277.5
Expenditure $221.9 $250.8 $256.7 $270.3 $280.8 $291.9
Surplus / (Deficit) ($5.1) ($7.5) $0.3 ($7.0) ($11.9) ($14.4) $140
$160
$180
$200
$220
$240
$260
$280
$300
FY2019
Actual
FY2020
Actual
FY2021
Actual
FY2022
Actual
FY2023
Actual
FY2024
Actual
FY2025
Actual
FY2026
Projection
FY2027
Budget
FY2028
Forecast
FY2029
Forecast
FY2030
Forecast
Revenues Expenditures (excl. Reserve Contr.)
Millions
Finance Committee Agenda Report
Operational Sustainability Initiative and Funding for the Local Housing Trust Fund

Although General Fund revenues are projected to grow during the forecast period, expenditures are projected to grow at a greater rate resulting in growing budget deficits each year. This structural budget deficit must be addressed by implementing ongoing revenue and expenditure control solutions.

The adopted FY2027 budget required implementing the following solutions in order to help balance the budget. As noted, most options are one-time in nature. Each option, as well as other budget balancing options, will be evaluated leading up to the development and release of the FY2028 and FY2029 financial plan and may need to be implemented going forward to continue to help balance the budget.

ITEM FY2027
($ Millions) TYPE
Tier 1 Options – Revenue Increases & Expenditure Savings $3.6 Ongoing Delay hiring of vacant positions $1.5 Temporary
Fleet replacement fund allocation into the General Fund $2.0 Temporary UUT Streets Maintenance / Paving reallocation into the General Fund $2.0 Temporary Partially defer General Fund Reserves transfer into the LHTF $1.0 Temporary Other recommended options $1.1 Temporary
TOTAL $11.2
Operational Sustainability Initiative
Staff has developed the Operational Sustainability Initiative governance structure in order to deliver on the goal of closing the deficit and holding a balanced budget, thereby creating sustainable operations and promoting best practices across the organization, prioritizing the most impactful initiatives from across both operational and strategic plan activity.

The shared values and commitments of staff across the organization working on these initiatives include the following:
• Focus: We focus on what matters most. We resist the pull of activity for its own sake and keep our effort directed at the initiatives with the greatest impact on the goal. • Accountability: When we agree to something, we follow through and work with our teams to find shared solutions.
• Collaboration: Departments, functions, and roles are different, but the goal is shared.

We support each other and escalate problems that need wider support rather than absorbing them silently.

Finance Committee Agenda Report
Operational Sustainability Initiative and Funding for the Local Housing Trust Fund

• Recognition: Delivering against the City's financial goals is hard work and a full team effort. We recognize effort and achievement at every stage, not just at the end.

Celebrating teams and individuals for their contributions and impact is important. • Learning: We reflect on what is working and what is not, and we adapt to get better over time.

Revenue Generating and Expenditure Control Options
Over the last year, staff have worked to develop a comprehensive set of revenue generating and expenditure reduction/control options for the Finance Committee to consider. More than 200 individual ideas were generated and evaluated to determine potential service delivery impacts and revenue generating and cost savings, among others. Staff also categorized the ideas into the following tiers:
• Tier 1 – Can be implemented quickly
• Tier 2 – May take more time, but still worth exploring and implementing • Tier 3 – Do not recommend at this time but to be considered in the future The Finance Committee provided direction to staff during the meetings on October 21 and November 18, 2025, as follows:

Highest priorities (recommending to proceed):
• Increase cannabis excise tax up to the 20.0% voter approved limit and explore the feasibility of adding additional licensed dispensaries in the City; • Initiate a poll to assess the viability of possible revenue tax measures for the November 2026 ballot, including tax rates increases for Real Property Transfer Tax (RPTT), TOT, Utility Users Tax (UUT), and a Parcel Tax; and
• Analyze recreational vehicle camping at the Waterfront parking lots.

Lowest priorities (not recommending to proceed):
• Library closures or reduced hours of operation;
• Allow short-term rentals (STR) throughout the City which would generate additional TOT revenue; and
• Increase parking fees.

The Finance Committee also expressed interest in pursuing the following recommendations:
• Sustainability & Resilience allocating up to $600,000 of Measure B creeks revenue for various projects and initiatives;
Finance Committee Agenda Report
Operational Sustainability Initiative and Funding for the Local Housing Trust Fund

• Consider options to adjust staff schedules for more flexibility, reduced hours, and lower operating costs;
• Consider a business tax certificate (license) modernization ballot measure; • Building electrification; and
• West Beach master plan
The City Council received a report from staff and provided direction to staff on December 2, 2025, regarding these options. Since then, staff have analyzed and have already implemented many options and proposed additional items to implement as part of the FY2027 budget. These actions include:
• Effective July 1, 2026, the cannabis excise tax rate increased from 6.0% to 8.0%, and this change is projected to generate an additional $200,000 tax revenue in FY2027. • Staff analyzed the viability and potential revenue from increasing the RPTT. The City Council directed staff to stop pursuing this option for the November 2026 election and consider it for a future election.
• Multiple positions that were previously funded by the General Fund are funded by Enterprise and/or Internal Service Funds in the FY2027 budget, and those positions will provide more effective support to operating departments. • Staff have reduced the warehouse inventory and have implemented just-in-time ordering procedures.
• Multiple General Fund positions remain vacant.

The table below summarizes the financial impact from these budget balancing options by General Fund operating department and fiscal year.

DEPARTMENT FY2026 FY2027
City Administrator’s Office $0 $150,000
Community Development $70,000 $317,335
Finance $71,000 $1,240,100
Fire $48,000 $158,900
Information Technology* $0 $74,038
Library $224,186 $67,509
Parks & Recreation $0 $91,248
Police $557,500 $1,340,000
Public Works $57,500 $376,729
Sustainability & Resilience* $315,000 $648,000
TOTAL BENEFIT TO GENERAL FUND $1,342,686 $4,463,859
*Information Technology and Sustainability & Resilience are not General Fund departments but contributed to savings or other practices which monetarily benefit the General Fund.

Finance Committee Agenda Report
Operational Sustainability Initiative and Funding for the Local Housing Trust Fund

Digital Streaming Services Audit Update
In January 2021, staff initiated an audit of the applicability of the City’s existing Video User Tax (VUT) on digital streaming services. The Tax Administrator (i.e., Finance Director) issued a notice of deficiency determination to the Disney Corporation for VUT applicability on Disney+, ESPN+, and Hulu. An independent hearing officer, the Santa Barbara County Superior Court, and the California Court of Appeals upheld the Tax Administrator’s determination. In April 2026, the California Supreme Court denied Disney’s petition for review making the Court of Appeals decision final and binding. Staff have since been initiating audits on additional digital streaming service providers as well as working with all providers to get into compliance with the City’s VUT and begin collecting and remitting the tax going forward.

To date, the City has realized $2.7 Million of past due tax, plus penalties and interest, and is projecting $600,000 of annual, ongoing tax revenue. Staff are in direct negotiations with multiple streaming service providers regarding past due audit amounts and ensure compliance with the VUT going forward. This revenue assumption was not included in the FY2027 General Fund budget because the audit program just began. When the City Council adopted the FY2027 budget on June 30, 2026, they directed staff to place the VUT revenues into the General Fund to replenish reserves. Future past due tax payments and annual revenue will continue to have a positive impact on replenishing reserves in FY2027.

Funding Options for the Local Housing Trust Fund
When the City Council adopted the FY2027 budget on June 30, 2026, they directed staff to present options for an ongoing funding source for the LHTF. Staff have identified possible funding sources for the LHTF described below.

Measure C – Santa Barbara voters passed the Measure C 1.00% district sales tax measure on November 7, 2017. This measure is projected to generate approximately $31.2 Million annually to fund critical infrastructure projects, including streets, sidewalks, storm drains, a new police station, and other City facilities. The Measure C ballot measure articulated the following priorities:

1. Police, Fire, and 911 emergency medical response;

2. Local streets, potholes, bridges, and storm drains;

3. Neighborhood fire stations/public safety infrastructure;

4. Parks, youth/senior services;

5. Address homelessness;

6. Help retain local businesses; and
Finance Committee Agenda Report
Operational Sustainability Initiative and Funding for the Local Housing Trust Fund

7. Support other general services.

On February 6, 2018, the City Council adopted a resolution establishing priorities for the first five (5) years of Measure C expenditures as follows:

1. Planning, permitting, and bonding for a new police station facility;

2. Repairing local streets throughout the City, including related street infrastructure;

3. Replacing Fire Station No. 7;

4. Community projects to support the City's parks and library;

5. Business district infrastructure projects; and

6. Maintenance of City buildings.

On December 12, 2023, the City Council adopted a resolution establishing priorities for the next five (5) years of Measure C expenditures as follows:

1. Construction and debt service payments for a new police station facility;

2. Repairing local streets throughout the City, including related street infrastructure, improving toward a Pavement Condition Index (PCI) goal of 75+ in the next 10-12 years;

3. Address drainage infrastructure by completing a full assessment of the City’s drainage infrastructure;

4. Community projects to support the City’s parks and library;

5. Business district infrastructure projects, with a focus on the State Street Promenade;

6. Maintenance of City Buildings; and

7. Address homelessness by prioritizing housing and facilities.

The FY2027 budget includes a $1.0 Million transfer of Measure C revenues into the LHTF. The City Council can continue to appropriate a transfer into the LHTF in future budget cycles. Staff have prepared a preliminary five-year financial forecast of Measure C revenues that will be finalized once the FY2028 – FY2032 Capital Improvement Plan (CIP) is published early in 2027.

Measure C Financial Forecast: Measure C revenues will continue to be the only or majority funding source for critical infrastructure and equipment replacement projects for public safety, parks and recreation, streets, facilities, and library programs for years to come. Measure C will also be the funding source for the annual debt service payment related to the new Police Station and Dwight Murphy Field Renovation. In total, the annual debt service payments will require approximately 20.0% of the annual Measure C revenues. Measure C will also be a priority funding source to implement the State Street Master Plan once approved.

Other priorities for Measure C funding going forward include: replacing the existing public safety radio infrastructure; equipment replacement for Police, Fire, Parks & Recreation, and Finance Committee Agenda Report
Operational Sustainability Initiative and Funding for the Local Housing Trust Fund

Library; the annual contribution for the Fire Regional Dispatch Center; pavement overlays and other street and sidewalk improvements; and many other City facility and parks improvements.

In total, these required and committed projects and initiatives will consume more than twothirds of the total, annual, projected Measure C revenue each year, with the burden increasing each year, primarily due to the projected inflationary costs of construction projects relative to the slower sales tax revenue growth. Measure C revenues may not be available in the forecast period for significant investment in additional projects and initiatives.

Measure I – Santa Barbara voters passed the Measure I 0.50% district sales tax measure on November 5, 2024. This measure is projected to generate approximately $15.6 Million annually to fund essential City services. The City Council adopted Resolution 24-092 on August 27, 2024, prioritizing the allocation of funds as follows:
• Maintaining 911 emergency fire, paramedic, and police response; • Making contributions to the City’s Local Housing Trust Fund, improving housing affordability, and addressing homelessness;
• Keeping local fire stations open;
• Maintaining library services;
• Keeping public areas and parks safe and clean;
• Maintaining stormwater protection;
• Improving natural disaster preparedness; and
• Retaining local businesses and jobs.

The FY2026 and FY2027 budgets included a $1.5 Million transfer of Measure I revenues into the LHTF. The City Council can continue to appropriate a transfer into the LHTF in future budget cycles.

The table below shows the budgeted distribution of Measure I support for Fiscal Years 2026 and 2027.

Finance Committee Agenda Report
Operational Sustainability Initiative and Funding for the Local Housing Trust Fund

TYPE PROGRAM FY2026 BUDGET FY2027 BUDGET
Existing Police Staff
• 31 police officers
• 3 police officers (previously frozen)
$6,298,046 $6,209,376
Existing Fire Staff
• 19 firefighters $3,542,319 $3,466,185
Existing Parks & Recreation Staff
• 8 positions
• After school program support
$955,120 $955,120
Existing Library Staff
• 5 librarians
• Security services & digital collections
previously funded by one-time sources
$952,785 $952,785
Existing
Program
& Service
Existing homeless services
• Fund 5 existing contracts to ensure
continuity of service
$351,730 $894,034
Housing & homeless services (transfer) $1,500,000 $1,500,000 New Allocation LHTF–Local Housing Trust Fund (transfer) $1,500,000 $1,500,000 TOTAL $15,100,000 $15,477,500
In-Lieu Fees – The City requires inclusionary housing—units at affordable prices—for multiunit residential developments. Inclusionary housing requires a certain number of units— calculated as a percentage of total units in a development—to be sold to middle-income households or rented to moderate-income households.  Staff are currently evaluating the current inclusionary housing requirements to inform possible amendments and to meet Housing Element goals of creating new housing and facilitating affordable housing, including the in-lieu fee rates to reflect the cost of building inclusionary units. The recently published Inclusionary Housing and In-Lieu Fee Study articulates a primary objective to “identify in-lieu fee rates that support the LHTF for affordable housing development while not negatively impacting feasibility of new market-rate residential development.” The table below shows the in-lieu fee revenue collected in each fiscal year since FY2011. In total, $1,546,667 has been collected with an average of $96,667 received per year. The collection of in-lieu fees depends on development project schedules and can be unpredictable. During this time, no in-lieu fees were collected in six (6) of the 15 years.

Finance Committee Agenda Report
Operational Sustainability Initiative and Funding for the Local Housing Trust Fund

FISCAL YEAR REVENUE
FY2011 $144,000
FY2012 $0
FY2013 $192,975
FY2014 $0
FY2015 $48,725
FY2016 $245,900
FY2017 $51,825
FY2018 $0
FY2019 $0
FY2020 $0
FY2021 $65,271
FY2022 $0
FY2023 $191,538
FY2024 $130,542
FY2025 $229,125
FY2026 $246,766
TOTAL $1,546,667
Once the financial statements are completed for FY2026, in-lieu fees totaling $1,421,667 will have transferred into the LHTF. The City Council can continue to appropriate the transfer of inlieu fees into the LHTF in future budget cycles.

The In-Lieu Fee Study can be found here (https://santabarbaraca.gov/news/InclusionaryHousing-and-In-Lieu-Fee-Study).

Vacancy Tax – Vacancy taxes are emerging policy tools in California that implement a tax on commercial or residential properties that remain unoccupied for a specified duration. Their primary objectives are to incentivize property usage, increase housing supply, disincentivize real estate speculation, and encourage landlords to reduce rents sufficiently to fill empty properties. These taxes have gained some traction in California cities as a direct response to the state's severe housing affordability crisis and high homelessness rates.

While vacancy taxes demonstrate potential in activating dormant properties, generating revenue for public services, and curbing speculative holding, their implementation in California has been met with significant legal challenges, administrative complexities including difficulty with tracking vacant priorities and compliance, and concerns regarding unintended economic consequences. Their efficacy as a standalone solution for the broader housing affordability crisis remains a subject of ongoing debate and requires further understanding and analysis.

Finance Committee Agenda Report
Operational Sustainability Initiative and Funding for the Local Housing Trust Fund

Initial discussions have included focusing on residential properties only. This tax must be approved by the electorate during an upcoming election, the next one occurring in November 2028. If the measure is presented as a general-purpose tax, it only requires a simple majority approval; however, if the measure were to be presented as a special tax (i.e., dedicated for affordable housing projects), it would require two-thirds approval.

The tax collected from such a measure would also need to cover the administrative costs of administering the tax and annual compliance as well as generate additional revenue to be appropriated by the City Council for additional priority efforts.

Other Future Funding Sources – The City Council can direct staff to analyze future funding sources to transfer into the LHTF. These sources may be future revenue measures during a general election, including a TOT increase, RPTT increase, and external fundraising, among others.

Budget/Financial Information
The General Fund reserves are currently well below policy required levels, projecting only

12.9% of annual expenditures in General Fund Reserves by the end of FY2026. $ MILLIONS FY2024
ACTUAL
FY2025
ACTUAL
FY2026

PROJECTION
FY2027
BUDGET
Reserve Policy Target (25.0%) $45.4 $50.3 $53.2 $56.7
Actual / Projected Reserve Level $40.7 $35.1 $27.9 $27.0 Difference ($4.8) ($15.2) ($25.2) ($29.7)
Actual / Projected Reserve Percent 22.4% 18.4% 12.9% 12.1% With falling reserve levels and a projected operating deficit beyond FY2027, staff and the City Council will need to identify additional, ongoing funding to support existing operations to balance the General Fund budget in future years. Continuing to control expenditures will also need to be considered.

Without any additional revenue or expenditure reductions in the General Fund, an operating deficit is projected in FY2028 and beyond requiring additional reserves to be used to balance the budget. If no budget changes are made, all General Fund disaster reserves are projected to be depleted by the middle of FY2030.

The General Fund multi-year financial forecast assumes the Measure I transfer of $1.5 Million into the LHTF continues into FY2028 and beyond. If the City Council appropriates additional Finance Committee Agenda Report
Operational Sustainability Initiative and Funding for the Local Housing Trust Fund

transfers into the LHTF beyond the $1.5 Million baseline assumption, this may contribute to depleting General Fund reserves quicker, all else being equal.

Attachment:

1. Operational Sustainability Initiatives.

Prepared and
Submitted by: Keith DeMartini, Finance Director
Approved by: Kelly McAdoo, City Administrator
ATTACHMENT 1
FY2026 FY2027
Revenue Generation Tax Related
Increase effective Cannabis Tax Rate from 6% to 8%, based on guidance provided by HdL auditor, which is lower than the voter approved maximum of 20%
$150,000
Water Resources Warehouse and associated position, previously funded by General Fund, dedicated to and funded by Water Resources
$109,600
Public Works-Facilities Mail Services, previously funded by General Fund, moved to Facilities Fund
$30,000
Sustainability & Resilience Fund one FTE for the Library on the Go and Library of Things programs $40,000 Golf increase Salary allocation of adminstrative staff from Parks & Recreations to Golf Fund by 0.2
Purchasing/Supplies Use online businesses rather than Central Store )Amazon, Costco, Office Depot, etc.)
Fleet/Travel Curtail uses of all take home vehicles except Operations Chiefs $8,000 $16,000 IT Analyst previously dedicated to Community Development made available to whole city, allowing that position's costs to be spread across other funds.
$156,535
Reduce hourly staffing where feasible $36,000 $67,500
Hold Police Services Coordinator Position vacant for 6 months $57,000 Transition downtown core/parking structure area waste collectin to Marborg contract
Eliminate vacant positiions through attrition or transfer positions to other programs not funded by the General Fund
$70,838
Relocate Purchasing staff to 220 East Ortega
Library proposed reorganization to eliminate vacant senior leadership positions, reclassify existing administration and marketing roles and expand front-line support staff
$216,686
Pursue Opportunities for commercial development on Airport property that can generate Sales Tax Revenue
$500,000 -
$800,000
Sidewalk dining on 500 block of State Street $91,200
Adjust fees to improve cost recovery $91,248
Eliminate Utility User Tax reimbursement to Land Development Engineering and increase fees to achieve cost recovery
Move environmental review to a deposit-based fee to better recapture cost of increasingly complex CEQA requirements
$17,000
Increase outdoor dining rates to pre-Thomas Fire
Increase outdoor dining rates to market $115,000
Increase Marborg Franchise Fee
Increase Waterfront Slip Fees to market rate
Increase Waterfront Slip Transfer Fees
Convert City Parking lot paid parking outside of normal business hours $60,658 Increase Parking Fee Penalty in Self-Pay lots $50,000
Increase parking for Waterfront lots $500,000
Library Rooms and Galleries $1,000 $25,000
Promote West Beach Event Space for community events, concerts, etc.

Revisit all private uses of pulbic right-of-way for rental revenue. At minimum, these uses should at least cover administrative costs (i.e. outdoor dining permits)
Library lobby for kiosk space $24,000
Formalize Waterfront event space rentals (Stearns Wharf, breakwater, parking lots, etc.) $50,000
Install RV campsites in a portion of Waterfront Chase Palm Parking Lot Reimbursement Seek reimbursement from School District for Crossing Guard and Benefits Increase Tourism Business Improvement Districts (TBID) rate/assessment to offset annual grant to Visit Santa Barbara
Utility User Tax (UUT) Increase $200,000
Asses City assets for possible sale
Targeted Fundraising (e.g. invitation to donate to the Library with holds, pickups, etc.) $5,000
Offer test profctoring service at the Library for $30/exam $1,000 Increased merchandise sales $30,000
Increase Parking Citation Revenue by over-hiring (3)_ Parking Enforcement Officers through underfilling (2) Police Officer positions $300,000 $500,000 Increase charges for franchise agreements related to use of the public right of way for private utilities (i.e. SCE, Gas, Communications) Redevelop West Beach with additional visitor service, recreation, and ocean dependent uses. Revenue generating opportunities such as restaurant, retail, rentals, event space, etc.

Redirect portion of Land Development Fees for time spent on Fire Review Fund Beach Grooming/Trash Removal Program (Measure B and Solid Waste) $250,000
Fund a Citywide Green Infrastructure Plan, including Master Drainage Study
$1,000,000 $2,000,000
Partially fund Urban Forestry, especially beyond standard repair/replacment schedule for stormwater trees
Fund Stormwater Managerment Program (SWMP) components of City proects
$400,000
Fund portion of Building Inspection Group for Stormwater Management Program (SWMP) inspections $100,000 $200,000
Encampment cleamup by Police, Fire, etc. to be reimbursed by Clean Communities program
$50,000 $50,000
Transition oversight (in collaboration with Parks & Recreation) of parkways and median maintenance to Creeks
$380,000 $380,000
Waterfront Beach Life Guards Program - Funded by Waterfront $70,000 Police Utilize opiod settlement funds to pay for co-response costs $475,000 TIER I RECOMMENDATIONS Tax Related Revenue Generation
Other
Sustainability &
Resilience Reallocation

TIER REVENUE/COST REDUCTION CATEGORY RECOMMENDATION

ESTIMATED EFFECT
Business Development
Opportunities
Fees
Parking
Rentals COMPLETE
Reallocation
Employee Related
Cost Saving/Expenditure Reduction
Efficiency Reorganization
ATTACHMENT 1
FY2026 FY2027

TIER REVENUE/COST REDUCTION CATEGORY RECOMMENDATION

ESTIMATED EFFECT
Implement Just-in-time inventory model at Warehouse, streamline parts available for Water Resource Operations
Consider bulk purchasing for certain items
Create blanket purchase order for procurement of Type 3 wildland engine $100,000 Take advantage of electric vehicle payment assistance, reducing financial outlay for new vehicle purchases while still meeting City policy and Council goals
$100,000 $100,000
Take advantage of building electrification incentives, reducing financial outlay while still meeting City policy and Council goals $100,000 $100,000
Change replacement on Administrative vehicles from 8 to 10 years for low mileage, good condition vehicles.
$150,000
Contract out maintenance for certain services (peak demand, specialized).

Delay replacement for small vehicles
Eliminate vehicles with low use, reduce carpool size in light of ride share program sunsetting
$50,000
Explore alternative approaches to fleet management (replacement schedule, incentives for longevity, minimizing fleet, etc.) Review potential for leasing standard vehicles (not public safety or specialized equipment), especially for low use vehicles Parking Reduce number of pay stations and/or expand replacement cycle $50,000 Ambassador schedules: One shift per day, no shifts City Hall $77,000 Ambassador schedules: One shift per day, 2 shifts City Hall $7,669 Centralize IT positions and services to IT (move to IT fund) Reduce cost for quarterly Manager & Supervisor meeting $15,000 $15,000 Selective hiring freeze for General Fund, non-public safety positions Reduce cost for Employee Appreciation activities (biennial picnic and alternating gifts) $35,000
Eliminate vacant positions through attrition or transfer positions to other programs not funded by the General Fund
$371,788
Move the 630 Garden Street lobby to self-service for plan viewing and cashiering
Transition Paks wast collection to Marborg contract through attrition of reallocation of positions to other functions
Dissolve Sign Committee (refer to Architectural Board of Review or Historical Landmarks Commission)
Close the business office in City Hall for in-person services and implement a “by appointment only” system
$123,000
Insurance program review to consider changing coverage on certain properties
Hire consultant to assist in expediting Workers’ Compensation Claims Expand building permit accountability/compliance (perhaps changing model to at-risk approach)
Increase dollar threshold from $12,000 to $50,000 for Accounts Payable staff reviewing invoices
$10,000
Account for Mutual Aid in special project, not as General Fund Provide public access to an AI engine to respond to questions, minimizing calls and public records requests
Increase document access on City website/platform to reduce need for public records requests
Centralize Parking Management from all departments to a single department
Centralization of Code Enforcement from all departments to a single department
Relocate Purchasing staff to 220 East Ortega
Share/pool administrative staff across divisions/departments (and with Enterprise Funds)
Enhanced Infrastructure Finance Districts – storm drains and priority transportation corridors (e.g., Milpas Street)
Laguna Channel capacity improvements (as part of a restoration project) Reallocation Employee Related Energy and Climate to take on Transportation Planning Team from Public Works
Explore capping vacation cash out benefits
Contract out services where feasible (janitorial, fleet maintenance, street sweeping, park maintenance, wildland fire fuel mitigation) $50,000 Centralize Communications from all departments to a single department Centralize Project Management from all departments into a single department
Business Development
Opportunities
Contract Grant Writer to assist with Targeting Prop $ funds for all City projects/Departments $100,000
Tax Related Charge Utility User Tax (UUT) on gross consumption of electricity as opposed to Net for solar customers
$250,000
Phase Out Mills Act Program
Assess City Assets for possible sale
Reallocation Employee Related Integrate three City janitorial staff into Airport’s Custodial team when appropriate or through attrition
Cost Savings/Expenditure Reduction Employee Related Unpaid sabbaticals with job security guarantees Other TIER II RECOMMENDATIONS
Revenue Generation TIER III RECOMMENDATIONS TIER I RECOMMENDATIONS Practice Change Reorganization
Efficiency
Infrastructure
Cost Savings/Expenditure Reduction
Efficiency
Employee Related
Reorganization
Purchasing/Supplies
Fleet/Travel
Cost Savings/Expenditure Reduction
Empoyee Related
Other
Agenda Item No. 1

CITY OF SANTA BARBARA
Council Agenda Report
Agenda Date: August 25, 2026
To: Mayor and Councilmembers
From: Water Resources Department
Subject: Introduction of an Ordinance to Amend Municipal Code Title 16 Liquid and Industrial Waste Disposal, and to Update Standard Condition and Pretreatment Program Administrative Documents [Ordinance Introduction]
Recommendation:

That Council:

A. Introduce and subsequently adopt, by reading of title only, an Ordinance of the Council of the City of Santa Barbara Amending Title 16 of the Santa Barbara Municipal Code Relating to Liquid and Industrial Waste Disposal by the Amendment of Various Sections to Authorize the Water Resources Director to Establish and Implement an Electronic Document Receiving System Consistent with the Federal Cross-Media Electronic Reporting Rule and to Designate the Water Resources Director in Place of the Public Works Director in Various Sections or Subsections of Title 16; and
B. Authorize staff to submit an update of City of Santa Barbara pretreatment program administrative documents to the Regional Water Quality Control Board as a pretreatment program modification to be approved under 40 CFR Part 403.18.

Discussion
The City of Santa Barbara (City) wastewater system operates under a National Pollution Discharge Elimination System (NPDES) permit issued by the California Regional Water Quality Control Board. This permit contains Clean Water Act requirements administered by the United States Environmental Protection Agency (EPA).

A requirement of the Clean Water Act and the NPDES permit is that the City implement an industrial pretreatment program governing the quality and quantity of wastewater discharged to the collection system by industrial dischargers. Municipal Code Title 16 (Title 16) provides the standards and the legal authority for enforcement of the pretreatment program. Since the Agenda Item No. 3
Council Agenda Report
Introduction of an Ordinance to Amend Municipal Code Title 16 Liquid and Industrial Waste Disposal, and to Update Standard Condition and Pretreatment Program Administrative Documents [Ordinance Introduction]

last revision to Title 16, the City applied for Cross Media Electronic Reporting Rule (CROMERR) certification. CROMERR was put into effect in October 2005 and codified under 40 CFR Part 3. It sets standards for electronic reporting under EPA regulatory programs to include key elements such as identity proofing, electronic signatures, and maintaining the integrity of electronic documents. CROMERR certification allows publicly owned treatment works to receive electronic reports from its pretreatment program permittees (for example, industrial users).

Currently, the City’s pretreatment program must, by requirement, receive signed, certified hard copies. The proposed changes constitute a substantial modification of the City’s approved pretreatment program and require approval from the Regional Water Quality Control Board, and upon approval must be incorporated into the Municipal Code, Title 16.

The proposed changes to the pretreatment program documents includes updating text to reflect receipt of electronic reports as well as updating the Sections 16.02.040, 16.04.020,

16.08.010, 16.08.060 of the Ordinance, Enforcement Response Plan (Resolution No. 14-080), and Standard Conditions documents to achieve consistency with all pretreatment program administrative documents. Other proposed changes include updating these documents to reflect the creation of the Water Resources Department.

Budget and Financial Information
There is no fiscal impact from the proposed updates and changes.

Environmental Review
The proposed action amending Municipal Code Title 16 Liquid and Industrial Waste Disposal is not a “Project” under California Environmental Quality Act (CEQA) Guidelines § 15378 (b)(5) as administrative activities of governments that will not result in direct physical changes in the environment are not subject to environmental review.

Water Commission Recommendation
Staff presented this item to the City of Santa Barbara Water Commission at its July 16, 2026 meeting. The Commission voted 4-0-1 in support of staff’s recommendation.

Council Agenda Report
Introduction of an Ordinance to Amend Municipal Code Title 16 Liquid and Industrial Waste Disposal, and to Update Standard Condition and Pretreatment Program Administrative Documents [Ordinance Introduction]

Attachments:

1. Pretreatment Program Administrative Documents

2. Standard Condition Document
Prepared by: Dakota Corey, Water Supply and Services Manager /GF/MT/sjc Submitted by: Joshua Haggmark, P.E., Water Resources Director Approved by: Kelly McAdoo, City Administrator
1 TABLE OF CONTENTS
Preface Requirements for Pretreatment Program
Submission
1-5
Chapter 1 Organization and Multi- jurisdiction
Implementation
6-7
Chapter 2 Legal Authority 7-10
Chapter 3 Procedures for Identifying New 11-12
Industrial Users
Chapter 4 Local Limits 13
Chapter 5 Permitting 14-16
Chapter 6 Compliance Monitoring 17-22
Chapter 7 Enforcement 23-24
Chapter 8 Resources 25
Chapter 9 Public Participation and 26-27
Confidentiality
Appendices
Appendix A Santa Barba Municipal Code Title 16
Appendix B Lists of Users Surveyed to Determine Possible Significant Industrial Users Appendix C Technical Evaluation Supporting Local Limits Appendix D Forms
Appendix E Quality Assurance
Appendix F Enforcement Response Plan
ATTACHMENT 1

PRETREATMENT PROGRAM ADMINISTRATIVE PROCEDURES MANUAL

ORGANIZATION
This Administrative Procedures Manual is organized according to the following chapters.

Chapter 1: Organization and Multi-Jurisdiction Implementation This chapter contains the information required under Title 40 of the Code of Federal Regulations (40 CFR) Part 403.9(b)(3), which includes a brief description of how the City of Santa Barbara (City) will administer its Pretreatment Program, including organization charts.

Chapter 2: Legal Authority
This chapter contains the information required under 40 CFR Parts 403.8(f)(1)(i)-(vi) and 403.9(b)(1)-(2), which provides the City with the legal authority enforceable in federal, state, or local courts and authorizes or enables the City to apply and enforce the requirements for Sections 307(b) and (c), and 402(b)(8) of the Federal Water Pollution Control Act (Clean Water Act), as amended, (Title 33 of the United States Code Section 1251 et seq.) and any regulations implementing those sections. Such authority may be contained in a statute ordinance or series of contracts or joint powers agreements which the City is authorized to enact, enter into or implement, and which are authorized by State law.

Copies of ordinances, multi-jurisdiction agreements, and other legal authorities are included in Appendix A.

Chapter 3: Procedures for Identifying New Industrial Users This chapter identifies the procedures under 40 CFR Parts 403.8(f)(2)(i) and (ii) that the City will use to identify new non-domestic users that may be subject to pretreatment requirements. The procedures used to conduct the initial survey of existing non-domestic users subject to the pretreatment program are included in Appendix B. This chapter also contains a list of all Significant Industrial Users (SIUs) as that term is defined in Title 16 of the City of Santa Barbara Municipal Code (SBMC)
Chapter 4: Local Limits
This chapter identifies the local limits developed under 40 CFR Parts 403.5(c)(1) and (3).

The chapter identifies the sampling methods and analytical procedures that must be used to implement the local limits. The technical analyses supporting the local limits is provided as Appendix C of this document.

Chapter 5: Permitting
This chapter contains the information required under 40 CFR Parts 403.8(f)(1)(i)-(iv) and 40 CFR Part 403.8(f)(2)(iii). This chapter includes a copy of a standard blank wastewater discharge permit to be issued to SIUs and other industrial users. 5 Chapter 6: Compliance Monitoring
This chapter contains the information required under 40 CFR Parts 403.8(f)(1)(v) and 403.8(f)(2)(iv)-(vi). This chapter identifies the procedures that will be used to assess compliance with pretreatment requirements and wastewater discharge permit conditions.

This chapter includes a description of the filing system that the City will maintain to produce evidence admissible in enforcement proceedings or in judicial actions. This chapter also contains the frequencies for both discharger self-monitoring and monitoring by the City of each permitted user.

Chapter 7: Enforcement
This chapter contains the information required under 40 CFR Parts 403.8(f)(1)(vi) and 403.8(f)(2)(vi). This chapter includes an Enforcement Management System (EMS) which reflects the principles contained in Pretreatment Compliance Monitoring and Enforcement Guidance, U.S. Environmental Protection Agency, July, 1986.

Chapter 8: Resources
This chapter contains the information required under 40 CFR Part 403.8(f)(3) and 40 CFR Part 403.9(b)(4), which require that the City provide sufficient resources and qualified personnel to administer the Pretreatment Program.

Chapter 9: Public Participation and Confidentiality
This chapter contains the information required under 40 CFR Parts 403.8(f)(1)(vii) and 40 CFR 403.8(f)(2)(vii), which includes requirements for public participation and confidentiality of information gathered through the Pretreatment Program.

6 Chapter 1: Organization and Multi-Jurisdiction Implementation The City of Santa Barbara, which is governed by a seven member City Council, owns and operates the El Estero Water Resource Center . Under 40 CFR Part 403 and a National Pollutant Discharge Elimination System (NPDES) permit (CA0048143), issued by the Central Coast Regional Water Quality Control Board, that regulates the El Estero Water Resource Center Resource Center, the City is required to implement a Pretreatment Program to regulate discharges from non-domestic sources from its service area. The Pretreatment Program is administered under the general direction of the Water Resources Director and the supervision of the Water Resources Manager. The two organizational charts attached, show the organizational structure within the City.

Industrial dischargers outside the City limits, but discharging to a City sewer are subject to requirements of the SBMC. Because the City is solely responsible for the operation of the Pretreatment Program, no multi-jurisdictional agreements are required. SBMC Title 16 provides the City with the necessary legal authority to implement the Pretreatment Program. The administration of the program as follows:

1. Water Resources Director
The Water Resources Director has ultimate responsibility to carry out and enforce the Pretreatment Program and compliance with SBMC Title and federal requirements under 40 CFR Part 403.

2. Water Resources Manager
The Water Resources Manager has the responsibility to see that general provisions of SBMC Title are carried out.

3. El Estero Water Resource Center Superintendent
The El Estero Water Resource Center Superintendent provides information on daily flows and reports unusual influent and/or effluent characteristics or treatment upsets.

4. Laboratory Supervisor
The Laboratory Supervisor oversees laboratory staff at the El Estero Water Resource Center. The laboratory provides daily analyses and alerts the Pretreatment Program Coordinator to any unusual results. The laboratory performs special analyses for samples collected from permitted users to determine their compliance status. The laboratory analyzes unknown samples to determine constituents and information helpful for determining a possible source of the discharge.

5. Pretreatment Program Coordinator
Under direction of the Laboratory Supervisor, the Pretreatment Program Coordinator is responsible for preparing and issuing wastewater discharge permits, conducting sampling and inspections of permitted users, initiating enforcement for violations of wastewater discharge permits or SBMC Title 7 16, preparing all applicable reports, and ensuring that the Pretreatment Program is in compliance with all applicable state and federal regulations.

6. Collection Systems Superintendent
The Collections System Superintendent is responsible for overseeing maintenance on the wastewater collection system and provides the Pretreatment Program Coordinator with information about problem areas in the collection system.

7. Collection System Staff and Treatment Plant Operators These employees report unusual situations or areas of discharge which they notice during their unusual job performance to the Pretreatment Program Coordinator.

Chapter 2: Legal Authority
Publicly-owned treatment works (POTWs) must have legal authority which is enforceable in Federal, State, or local courts which authorizes or enables the POTW to apply and to enforce the requirements set forth in 40 CFR Part 403.8(f)(1)(i)-(vi). At a minimum this legal authority enables the POTW to:

1. Deny or condition new or increased contributions of pollutants, or changes in the nature of pollutants, to the POTW by dischargers where such contributions do not meet applicable pretreatment standards and requirements or where such contributions would cause the POTW to violate its NPDES permit (40 CFR Part 403.8(f)(1)(i));

2. Require compliance with applicable pretreatment standards and requirements by dischargers (40 CFR Part 403.8(f)(1)(ii));

3. Control through a wastewater discharge permit, order, or similar means, the contribution to the POTW by each discharger to ensure compliance with applicable pretreatment standards and requirements (40 CFR Part 403.8(f)(1)(iii));

4. Require: (a) the development of a compliance schedule by each discharger for the installation of technology required to meet applicable pretreatment standards and requirements; and (b) the submission of all notices and selfmonitoring reports from dischargers with pretreatment standards and requirements, including, but not limited to, the reports required in 40 CFR Part 403.12 (40 CFR Part 403.8(f)(1)(iv));

5. Conduct inspection, surveillance, and monitoring necessary to determine, independent of information supplied by dischargers, compliance or noncompliance with applicable pretreatment standards and requirements by dischargers. Representatives of the POTW shall be authorized to enter any premises of any discharger in which a discharge source or treatment system is located or in which records are required to be kept under 40 CFR Part 403.12(m) to verify compliance with pretreatment standards and requirements. Such authority shall be at least as extensive as the authority provided under section 308 of the Clean Water Act (40 CFR Part 403.8(f)(1)(v));

6. Obtain remedies for noncompliance by any discharger with any pretreatment standard and requirement. The POTW has the authority to seek injunctive relief and seek or assess civil or criminal penalties in at least the amount of $1,000 a day for each violation by dischargers with pretreatment standards and requirements. Pretreatment requirements, which will be enforced through the remedies discussed above, include, but not be limited to, the duty to allow or carry out inspections, entry, or monitoring activities; any rules, regulations, or orders issued by the POTW; or any reporting requirements imposed by the POTW has authority and 9 procedures (after informal notice to the discharger) immediately and effectively to halt or prevent any discharge or pollutants to the POTW which reasonably appears to present an imminent endangerment to the health or welfare of persons. The POTW has the authority and procedures (which includes notice to the affected dischargers and an opportunity to respond) to halt prevent any discharge to the POTW which presents or may present an endangerment to the environment or which threatens to interfere with operation of the POTW. The Approval Authority has authority to seek judicial relief for noncompliance by a discharger when the POTW has acted to seek such relief but has sought a penalty which the Approval Authority finds to be insufficient. The procedures for notice to dischargers where the POTW is seeking ex parte temporary judicial injunctive relief will be governed by applicable state or federal law and not by this provision (40 CFR Part 403.8(f)(1)(vi));

7. A statement from the City Attorney (Solicitor)or a city official acting in a comparable capacity (or the attorney for those POTWs which have independent legal counsel) that the POTW has authority adequate to carry out the programs described in 40 CFR Part 403.8. This statement (40 CFR Part 409.(b)(1)):
a. Identifies the provision of the legal authority under 40 CFR Part 403.8(f)(1), which provides the bases for each procedure under 40 CFR Part 403.8(f)(2);
b. Identifies the manner in which the POTW will implement the program requirements set forth in 40 CFR Part 403.8, including the means by which pretreatment standards will be applied to individual dischargers (e.g., by order permit, ordinance, etc.); and c. Identifies how the POTW intends to ensure compliance with pretreatment standards and requirements, and to enforce them in the event of noncompliance by dischargers; and

8. A copy of any statutes, ordinances regulations, agreements, or other authorities relied upon by the POTW for its administration of the Pretreatment Program. This document shall include a statement reflecting the endorsement or approval of the local boards or bodies responsible for supervising and/or funding the POTW Program if approved (40 CFR Part 403.9(b)(2)).

SBMC Title 16 provides the necessary legal authority for the City to implement the Pretreatment Program, and to meet the requirements of the federal pretreatment program. To address the basic requirements of the federal pretreatment program outlined above, the following section outlines the City's provisions for implementing the required controls:

1. Section 16.08.120 of the SBMC sets forth the legal authority for the City to deny or condition new or increased discharges of wastewater and pollutants, or changes in nature of a discharge, to the Community Sewer 10 and El Estero Water Resource Center Resource Center. Section 16.08.120 also defines the types of users that must acquire a wastewater discharge permit prior to discharging to the Community Sewer, required and optional provisions and conditions regulating discharge, and conditions for modifying and/or revoking wastewater discharge permits.

2. Chapter 16.04 of the SBMC outlines the regulations for discharges into the Community Sewer and El Estero Water Resource Center Resource Center in accordance with 40 CFR Part 403.8(f)(1)(ii).

3. Section 16.08.120 of the SBMC provides the City with the legal authority to issue and enforce wastewater discharge permits.

4. Sections 16.08.010(B)(7), 16.08.020, and 16.08.160 of the SBMC provide legal authority to the City to require the development of compliance schedules for the installation of technology required to meet applicable pretreatment standard requirements and reporting required to provide updates on the compliance schedule.

5. Sections 16.08.130 and 16.08.150 of the SBMC provide legal authority to the City to conduct inspections, surveillance, and monitoring necessary to assess compliance with applicable pretreatment standards and requirements.

6. Chapters 16.12 and 16.14 of the SBMC outlines the remedies that the City can implement for dischargers that have been found to be in noncompliance with pretreatment standards and requirements. All remedies for noncompliance will be implemented in accordance with the City’s Enforcement Response Plan.

7. The Santa Barbara City Council adopted SBMC Title 16 to provide the City with legal authority to implement the Pretreatment Program in accordance with the requirements in 40 CFR Part 403. The Santa Barbara City Council is responsible for funding for the Pretreatment Program. City staff prepares a two-year budget which is submitted to the Water Commission for review and recommendation then to the City Council for approval.

A copy of SBMC Title 16 is included in Appendix A of this document. 11 Chapter 3: Procedures for Identifying Permitted Users Under 40 CFR Part 403.8(f)(2)(i)-(ii), the City is required to identify all possible users which might be subject to the Pretreatment Program. The Pretreatment Program must identify the character and volume of pollutants contributed to the POTW by the identified users. Volume of discharge from the users is determined from the water bills. In cases where there is a known diversion of water for irrigation the estimated wastewater volume discharged to the sewer is adjusted accordingly. Because the Pretreatment Program has been in place for a number of years, the procedures used for the initial industrial waste study are not included in this update. The City currently uses the following methods to identify potential users that may need to be regulated under the Pretreatment Program:

1. All plans for remodels or proposed buildings are reviewed by the Pretreatment Program Coordinator as they undergo the City plan check process. Any proposed plans which do not meet City standards are identified and corrections required before a building permit is issued.

2. A list of new business licenses is reviewed monthly to determine whether any new businesses have begun in the City without building modifications requiring plan check.

3. The County list of hazardous waste generators is used as a source for identifying possible dischargers.

4. Dischargers in categories suspected or known to be possible SIUs are located via internet searches, industrial user surveys, or visiting the business.

5. An informal referral network between the Santa Barbara County Health Department and the Pretreatment Program staff has been developed. The Fire Department has also been alerted to report any possible dischargers to the attention of the pretreatment program staff.

6. The water bills are regularly reviewed to identify the largest users, and determine whether inclusion in the Pretreatment Program may be necessary.

7. Drive-by inspections through the service area.

The characteristics of discharges are determined in two ways: 1) users are sampled at the point of discharge to the community sewer for information on individual discharges; and 2) samples are taken at the influent to the treatment plant, and in the sewer system of residential areas to determine background levels of pollutants in domestic waste. In this manner we are able to determine pollutant contributions from domestic, industrial, and commercial sources.

A list of the dischargers that are currently permitted or in the process of being permitted is included in Appendix B. Categories of dischargers that the City is currently considering for regulation under the Pretreatment Program include dental offices, breweries, wineries, 12 tasting rooms, and cannabis operations (e.g., manufacturing facilities, growing facilities, dispensaries).

Restaurants are not regulated through the issuance of permits, but are notified of requirements for grease control and inspected for compliance. Restaurants which cause blockages of the wastewater collection system are required to increase maintenance of grease traps. If there is not existing grease trap, or if the trap is under-sized, the restaurant is required to install a new grease trap which meets the minimum flow and grease retention requirements of the most current Uniform Plumbing Code. The restaurant causing a blockage is also required to pay the costs incurred by the City for removing the blockage from the sewer line.

Inspections of industries include determining the location of all wastewater sources, inspection of floor drains and potential spills, and inspection of waste handling procedures to ensure that spilt wastes will not enter the sewer system. If there is a waste treatment system in existence the system is inspected, procedures for monitoring the performance of system, as well as equipment calibration and functioning are checked. Copies of inspection report sheets are included in this chapter.

Any compilation, index, or inventory of users made under this chapter is be made available to the USEPA Regional Administrator or Director upon request. 13 Chapter 4: Local Limits
Under 40 CFR Part 403.5(C)(1) and (3), the City is required to develop and implement local limits to regulate wastewater discharges to the community sewer and El Estero Water Resource Center Resource Center. The current local limits, which were technicallydeveloped using data from the treatment plant removal capabilities, NPDES permit limits, receiving water quality criteria, and biosolids criteria. Local limits for arsenic, cadmium, chromium, copper, lead, mercury, nickel, silver, zinc, selenium, cyanide, phenolics, chlorinated phenolics, endosulfan, endrin, hexachlorohexane (HCH), polychlorinated biphenyls (PCBs), and pH were developed and implemented to regulate the discharges from dischargers to the El Estero Water Resource Center Resource Center. The current local limits were adopted by the Santa Barbara City Council on July 7, 1992 following approval by the Central Coast Regional Water Quality Control Board and an opportunity for public participation. The technical analysis supporting the development of the current local limits is provided in Appendix C of this document.

In 2014, the City conducted a local limits evaluation to assess if the current local limits needed to be updated. Subsequent to the 2014 local limits evaluation, the City developed and implemented a local limits sampling plan in 2015 to collect data that were necessary to update the City’s local limits. The City developed draft local limits in 2017. However, the City did not implement the draft local limits because of upgrades to the El Estero Water Resource Center and the acceptance of brine waste from the Desalination Plant.

The City will revisit the local limits update after the operations at the El Estero Water Resource Center Resource Center have stabilized upon full implementation of the treatment processes modifications.

The City will provide the public an opportunity to review and provide comments on any proposed local limit modifications. All substantial modifications to the local limits (i.e., modifications either increasing an existing local limit or removal of an existing local limit) will submitted to the Central Coast Regional Water Quality Control Board for approval prior to adoption and implementation by the City.
14 Chapter 5: Wastewater Discharge Permitting
Wastewater Discharge Permits
The City has three types of wastewater discharge permits that it can issue to dischargers.

Users subject to these categories are required to obtain a wastewater discharge permit prior to discharging to the community sewer and/or El Estero Water Resource Center Resource Center, consistent with Section 16.06.120 of the SBMC. Compliance with the conditions of the permit is monitored through sampling and inspection. The three tiers are:
 Tier I- Significant Industrial Users
 Tier II Non-Significant Industrial User
 Tier III- Groundwater Dischargers
Tier I – Significant Industrial Users
A significant industrial user is defined as any user who discharges more than 25,000 gallons per day, is regulated under federal categorical standards, has the capability to affect deleteriously the community sewer or El Estero Water Resource Center Resource Center, or contributes greater than five percent of the El Estero Water Resource Center Resource Center’s average dry weather hydraulic or organic capacity. The City may also determine that a facility is a non-significant categorical industrial user (NSCIU) if it meets the NSCIU definition outlined in Title 16 of the SMBC.

Tier II – Non-Significant Industrial Users
Non-significant industrial users are users, as defined in Section 16.08.120 of the SBMC, are dischargers that may adversely affect the community sewer or El Estero Water Resource Center Resource Center or exceed local limits, pretreatment standards or requirements, are non-significant categorical industrial users and/or discharge waste with characteristics that exceed typical domestic wastewater.

Wastewater discharge permits may also be issued for non-significant industrial users that have, or are required to, implement mechanisms to reduce wastewater strength, have monitoring requirements, or for users that base the user fee or charge on estimates of wastewater flow.

Tier III – Groundwater Dischargers
Groundwater dischargers are any users who discharge groundwater to the community sewer or El Estero Water Resource Center Resource Center. Water from remediation of contaminated groundwater is accepted to the community sewer after suitable treatment and when disposal to a storm drain is infeasible. Groundwater discharge permits are issued for one year, and the user is required to submit monthly self-monitoring reports.

Users are required to apply for a wastewater discharge permit if it appears that they may be subject to regulation as a Tier I, II, or III discharger. The processes used to identify 15 potential significant industrial users are discussed in Chapter 3 of this document. Upon satisfactory completion of a wastewater discharge permit application, the City may issue users a wastewater discharge permit.

Users have a duty to reapply for wastewater discharge permits if they choose to continue an activity regulated by a wastewater discharge permit. The permitted user must submit an application to renew at least 90 days before the expiration of the existing wastewater discharge permit.

Example wastewater discharge permit application forms are included in Appendix D.

Wastewater Discharge Permit Administration
The Water Resources Director will evaluate the data and information furnished by a user.

After evaluation of the data and information furnished, the Water Resources Director may issue a wastewater discharge permit. The Water Resources Director may deny issuance of a wastewater discharge permit where the proposed discharge alone or in combination with other discharges has the potential to cause interference, pass through, or risk to health and safety or there is insufficiency capacity (either in the community sewer or El Estero Water Resource Center Resource Center) to accept the proposed discharge.

If the Water Resources Director issues a wastewater discharge permit, it shall contain, at a minimum: the name, address and Standard Industrial Classification (SIC) number of the discharger; a statement of permit duration, a statement of non-transferability volume of wastewater to be discharged, known or suspected wastewater constituents and characteristics to be regulated; any limitations on time and duration of discharges; and a requirement for notification of accidental spills, or changes in process; a requirement to notify the City of wastes which, if not discharged to the community sewer, would be classified as hazardous wastes; and the pollutant limits and the point at which pollutant limits apply. Wastewater discharge permits also specify the sampling frequency, the reporting requirements, and penalties for violations.

Wastewater discharge permits may also contain provision or conditions, including limitations on the discharge rate and/or time, flow equalization, requirements for installation of pretreatment technology or pollution control such as BMPs, development and implementation spill control plans or waste minimization plans, and other conditions deemed appropriate by the Water Resources Director to ensure compliance with Title 16 of the SMBC and federal, state, and local laws, rules, and regulations.

The City may issue a wastewater discharge permit for a period up to five years. New dischargers generally receive a wastewater discharge permit that lasts for one year such that the City can assess the discharge and modify wastewater discharge permits to reflect operations and discharge of wastewater. Users that have compliance issues typically receive shorter duration wastewater discharge permits. All Tier III wastewater discharge permits are issued for a period of one year. The City does not allow the transfer, reassignment, or selling of a wastewater discharge permit to a new or different owner, 16 operator, user, or premise. A wastewater discharge permit is void upon cessation of operations or transfer of the facility and/or operation to a different user.

The City may revoke a wastewater discharge permit for failure to comply with the SBMC Title 16, or the permit itself. Conditions that may result in the revocation of a wastewater discharge permit include, but are not limited to:

1. Failure to provide prior notification to the Water Resources Director of changed conditions pursuant to Section 16.08.070 of the SMBC;

2. Misrepresentation or failure to fully disclose all relevant facts in a wastewater discharge permit application;

3. Falsifying self-monitoring reports and certification statements;

4. Tampering with monitoring equipment;

5. Refusing to allow the Water Resources Director timely access to the facility and/or records;

6. Failure to meet effluent limitations, including local limits;

7. Failure to pay fines;

8. Failure to pay sewer charges and fees;

9. Failure to meet compliance schedules;

10. Information indicating that the discharge poses a threat to the community sewer, El Estero Water Resource Center Resource Center, or the receiving waters; or

11. Violation of any pretreatment standard or requirement or any terms of a wastewater discharge permit or SBMC Title 16.

Appeals to wastewater discharge permit revocation are discussed in Chapter 7 of this document.
17 Chapter 6: Compliance Monitoring, Inspections, Reporting and Notifications, and Recordkeeping
40 CFR Part 403.8(f)(1)(v) and Title 16 of the SMBC provides the City with legal authority to conduct inspection, surveillance and monitoring necessary to determine, independent of information supplied by users, compliance or noncompliance with applicable pretreatment standards and requirements by users. The following sections describe the City’s approach for carrying out compliance determinations.

Compliance Monitoring
Under 40 CFR Part 403.8(f)(2)(v), the City is required to randomly sample and analyze the effluent from dischargers in order to identify, independent of information supplied by users, occasional and continuing noncompliance with pretreatment standards. Under the City’s currently approved Pretreatment Program, permitted users are sampled by the City on a quarterly basis for the pollutants identified in an individual wastewater discharge permit. The City may sample a permitted user at a higher frequency as needed to assess compliance. Users are not required to conduct compliance sampling at this time. The City provides the results of the monitoring to the permitted users.

The City will modify this policy for compliance monitoring, and require that Tier I users conduct monitoring of its effluent twice per year as required by the federal regulations and the City will conduct monitoring of the effluent once per year to verify compliance. The City may require a higher frequency of monitoring to assess compliance. Monitoring frequencies are included in wastewater discharge permits. The City may still elect to conduct monitoring on behalf of the Tier I users on a case-by-case basis. For Tier II and Tier III users, the City will outline the monitoring requirements in the individual wastewater discharge permits.

Pollutants that are required to be sampled are determined by a comprehensive sampling program at the initial sampling. Samples are collected for total toxic organics, and all of the metals for which there are local limits. If any of the constituents analyzed are found they will be included in the required monitoring program as described in the individual wastewater discharge permits.

Effluent samples must be representative of the discharge from the facility. Ideally, samples are collected using 24-hour flow-proportional composite sampling techniques unless time-proportional composite sampling or grab sampling is authorized by the Water Resources Director. All sample collection, handling, and analyses must adhere to methods approved under 40 CFR Part 136. Samples for oil and grease, temperature, pH, cyanide, total phenols, sulfides, and volatile organic compounds must be obtained using grab sampling techniques. Multiple grab samples collected during a 24-hour period may be composited in the laboratory or in the field prior to analysis for cyanide, total phenols, and sulfides. Multiple grab samples collected during a 24-hour period may only be composited in the laboratory for volatile organics and oil and grease. If 40 CFR Part 136 does not contain sampling or analytical techniques for the pollutant in question, or where USEPA determines that 40 CFR Part 136 sampling and analytical techniques are 18 inappropriate for the pollutant in question, sampling and analyses must be performed by using validated analytical methods or any other applicable sampling and analytical procedures, including procedures suggested by the Water Resources Director or other parties approved by USEPA. A copy of the standard sampling protocol for the City’s Pretreatment Program is included in Appendix E.

All sample analyses must be conducted by certified analytical laboratories and accompanied by a chain-of-custody document. All sample collection and analysis must be completed such that it will produce evidence that is admissible in enforcement proceedings or in judicial actions. Quality control for the pretreatment program is performed independently of the quality control program for the individual laboratories used for analysis. Split, spiked, blank, or duplicate samples are taken approximately every tenth sample. Quality control is monitored, and unusual results are investigated. The quality of samples being taken by automatic sampler is checked for contamination through the use of sampler blanks and duplicate samples.

If effluent monitoring indicates an exceedance of an effluent discharge limitation, the permitted user is required to conduct re-sampling of its effluent and report the results of the analysis to the City within 30 days of determining that the initial sample was an exceedance.

Reporting requirements for compliance monitoring are discussed in the Compliance Reporting section below.

Results of all compliance monitoring shall be made available to the Regional Administrator or Director upon request.

Compliance Inspections
Under 40 CFR Parts 403.8(f)(2)(v)-(vi) and Section 16.08.150 of the SBMC, the City has the legal authority to conduct inspections of a user’s facilities, which a discharge source or treatment system is located or in which records are required to be kept under 40 CFR Part 403.12(m) to assess compliance with pretreatment standards and requirements.

Such authority shall be at least as extensive as the authority provided under section 308 of the Clean Water Act. Users are required to allow the Water Resources Director access to all parts of the premises for the purpose of inspection, sampling, records examination, and copying to verify the user’s compliance.

1. User Security. Where a user has security measures in force which require proper identification and clearance before entry into its premises, the user shall make necessary arrangements with its security guards so that, upon presentation of suitable identification, the Water Resources Director shall be permitted to enter without delay for the purposes of performing specific responsibilities.

2. Inspection Installations. The Water Resources Director shall have the right to install devices on the user’s premises, or require installation of devices, 19 as are necessary to conduct sampling and/or metering of the user’s operations.

3. Delay in Access. Unreasonable delays allowing the Water Resources Director access to the user’s premises shall be a violation.

4. Water Resources Director Search Warrant. If the Water Resources Director has been refused access to a building, structure, or property, or any part thereof, and holds reasonable suspicion that there may be a violation or that there is a need to inspect and/or sample as part of a routine inspection and sampling program of the City designed to verify compliance, or to protect overall public health, safety, and welfare of the City, the Water Resources Director may seek issuance of a search warrant from the City Attorney.

At a minimum, the City will conduct annual inspections of all Tier I users. The City may conduct more frequent inspections of Tier I users as needed. The City will conduct inspections of Tier II users on an as-needed basis, but at a minimum once per wastewater discharge permit term. The City will conduct inspections of Tier III users on an as-needed basis.

An example compliance inspection form is presented in Appendix D.

Compliance Reporting and Notifications
40 CFR Part 403.12 requires that permitted users submit periodic compliance reporting and notifications to the City. Under 40 CFR Part 403.8(f)(2)(iv), the City is required to receive and analyze these reports and notifications to evaluate and establish whether the permitted user is in compliance with pretreatment standards and requirements.

Reporting requirements include:

1. Baseline Monitoring Report
Permitted users subject to categorical pretreatment standards must submit a baseline monitoring report within 180 days of the categorical pretreatment standard becoming effective or within one 180 days the final administrative decision on a category determination submission, whichever is later. New sources, or sources that are newly subject to categorical standards are required to submit a baseline monitoring report at least 90 days before commencing discharge. New sources are required to identify the planned method of pretreatment. These reports must contain the information required in Section 16.08.010(B) of the SBMC.

2. Compliance Schedule Progress Report
All categorical industrial users for which a compliance schedule is required must submit compliance schedule progress reports. In accordance with Section 16.080.020 of the SBMC, compliance schedule progress reports are required within 14 days of each date in the schedule and the final compliance deadline. The maximum time between report submittals is nine 20 months. Reports must include whether the progress required in the increment was achieved, causes of any delays and corrective actions to return to schedule, if applicable.

3. Reports on Compliance with Categorical Pretreatment
Within 90 days of the final compliance date for applicable pretreatment standards, or for a new source following commencement of discharge, users subject to pretreatment standards must submit reports to the Water Resources Director containing the information required in Section

16.08.030 of the SBMC.

4. Compliance Reports
All Significant Industrial Users (Tier I) are required to submit semi-annual reports in June and December on July 15 and January 15, respectively. An example the semi-annual report form which industry is required to fill out and update is included in Appendix D. Other permitted users (Tier II and Tier III) are required to submit reports in accordance with their wastewater discharge permit requirements.

5. Hauled Waste Reporting
Waste haulers are required to provide a waste tracking form for each load.

These reports must include the information required in Section 16.08.050 of the SMBC.

6. The City may develop procedures for receipt of electronic reports through a CROMERR compliant system for any reporting requirements under SBMC Title 16 Such procedures shall comply with 40 CFR Part 3. These procedures shall be enforceable under SBMC Title 16.

Each User shall submit such CROMERR reports as authorized by the procedures adopted by the City pursuant to SBMC Title 16 or as identified in an individual or general Wastewater Discharge Permit to the User within the time frame set forth, which shall provide the User at least 90 calendar days to become CROMERR compliant. The User may request additional time for good cause, but sch request does not automatically extend the deadline for becoming CROMERR compliant.

Reports are required to be certified by an Authorized Representative of the User (defined in Section 16.02.040(C) of the SMBC) in accordance with Section 16.080.60 of the SBMC.

In addition to the applicable reporting requirements discussed above, permitted user are also required to provide notifications to the City under the following conditions:

1. Notification of Changed Discharge
Users are required to notify the Water Resources Director prior to any change in the volume or characteristics of discharge, or planned significant changes that might alter discharge volume, quality or characteristics. The 21 Water Resources Director may require that the user submit information as deemed necessary to evaluate the changed condition, including a wastewater discharge permit application. The Water Resources Director may condition or deny such changed discharge in accordance with Section

16.08.120 of the SBMC.

2. Notification of Violation
Users must notify the Water Resources Director within 24 hours after discovery of a violation. Sampling and analysis must be repeated and submitted to the City within 30 days of becoming aware of the violation. If the City samples the user monthly or conducts sampling for the user, the City will perform the repeat sampling and analysis unless otherwise specified. A written statement, detailing the cause of the violation and any response or preventative measures taken must be submitted to the Water Resources Director within 14 days following the discovery of the violation.

Violations may be subject to enforcement actions described in Chapter 7 of this document.

3. Notification of Potential Problems
In accordance with Section 16.08.100 of the SMBC, in the case of any discharge, including accidental or non-routine discharge, that could have adversely affect the community sewer or El Estero Water Resource Center Resource Center, the user is required to telephone the Water Resources Director immediately and indicate the location of discharge, volume, characteristics and any response taken by the user. In addition, the user must submit a written report to the City within five days following the discharge. The written report must include the cause of discharge and any preventative measures taken. Users are required to post the emergency notification protocol in a location visible to employees at the user’s facility.

If any changes at the user’s facility may affect potential for a slug discharge, the user must immediately notify the Water Resources Director.

Recordkeeping
Permitted users subject to the reporting requirements under the Pretreatment Program are required to retain and make available for inspection and copying all records of information obtained pursuant to any monitoring activities required by the City, any additional records of information obtained pursuant to monitoring activities undertaken by the user independent of such requirements, and documentation associated with BMPs established under Section 16.04.120(D) of the SBMC. Records shall include the date, exact place, method, and time of sampling, and the name of the person(s) taking the samples; the dates analyses were performed; who performed the analyses; the analytical techniques or methods used; and the results of such analyses. These records are required to be maintained and available for a period of at least three years. This period is automatically extended for the duration of any litigation concerning the user or the City, or where the user has been specifically notified of a longer retention period by the Water Resources Director.
22 The Pretreatment Program Coordinator maintains a paper file for each permitted user that includes all submitted, signed reports, wastewater discharge permit application, and correspondence. The paper file also includes a copy of the wastewater discharge permit, original laboratory reports from monitoring activities, a log of correspondence and submittals from the permitted users, inspection reports, and fact or information sheets providing background on the permitted user, decisions made by the City on user-specific issues, and other relevant information regarding the user.

The Pretreatment Program Coordinator also maintains a location on the El Estero Water Resource Center network with relevant information and copies of documents for each permitted user. At present, the City is Cross-Media Electronic Reporting Rule (CROMMER)-certified. As such, the City is legally authorized to accept electronically signed documents from permitted users.
23 Chapter 7: Enforcement
To meet the requirements of 40 CFR Part 403.8(f)(1)(vi), Chapters 16.12 and 16.14 of SBMC Title 16 provide the City with the legal authority to enforce against incidences of violations and obtain remedies for noncompliance by any permitted user with any pretreatment standard and requirement. All potential enforcement activities are outlined in the City’s Enforcement Response Plan (ERP), which is included in Appendix F of this document, and intended to ensure that all violations are met with consistent and uniform response that does not discriminate between permitted users. The main objectives of the ERP are as follows:

1. To establish procedures for the investigation of all instances of noncompliance;

2. To identify types of escalated enforcement available, and when they are appropriate;

3. To state the frequency of inspection and sampling of permitted users;

4. To set guidelines for documenting compliance;

5. To implement a system to track all monitoring reports; and

6. To identify criteria, responsible persons, and procedures to select and initiate enforcement response actions from among those provided for in the Title 16 of the SBMC.

The most common first step for noncompliance with pretreatment standards and requirements is for the City to send the permitted user a Notice of Violation (NOV) outlining the violation and requiring a response stating the reason for the violation and steps being taken to correct the violation. If the violation is an exceedance of a discharge limitation, the user is required to resample its discharge to confirm that the violation and submit the results of the analysis to the City within 30 days of becoming aware of the violation. (If the City conducts resampling, there may be a fee for the resampling and analysis.) If the violation has not been corrected, the user is issued a second notice of violation and required to submit a written explanation for the cause of the problem and detail steps taken to correct the problem.

Continued violation will result in escalating enforcement actions, including cease and desist orders (CDOs), administrative fines, compliance schedules, injunctions, publication of the facilities in significant noncompliance in in the newspaper, civil and/or criminal prosecution, suspension or termination of a wastewater discharge permit, and suspension or termination of sewer and/or water service to the user. Examples of a typical NOV and CDO are included in Appendix D.

The City is not required to conduct each enforcement action in sequence, and may implement higher levels of enforcement, as needed, depending on the nature of the violation. For example, if a discharge is imminently expected to cause damage or harm to the community sewer, El Estero Water Resource Center, environment, or public health and safety, the City may seek to terminate sewer service prior to implementing other 24 remedies. The ERP includes an Enforcement Response Guide (ERG) that is used to outline typical enforcement actions for various types of violations. As stated in Section

16.14.100 of the SMBC, typical conditions that may warrant termination of a wastewater discharge permit and/or sewer service include the following:

1. Violation of wastewater discharge permit conditions;

2. Failure to accurately report wastewater constituents and characteristics of its discharge;

3. Failure to report significant changes in operations or wastewater constituents and characteristics prior to discharge;

4. Refusal of reasonable access to the user’s premises for the purpose of inspection, monitoring, or sampling;

5. Violation of the pretreatment standards or requirements of Chapter 16.04 of the SBMC.

Users subject to any enforcement action from the City may appeal the action with the Water Resources Director. The user must submit a written request for reconsideration within 15 days of such decision, action, or determination that sets forth the facts in detail that support the user’s request for reconsideration. During the period in which the Water Resources Director is reconsidering the request from the user or during the period of any appeal or judicial review, the decision, action, or determination or of the Water Resources Director will remain in effect. Upon the decision, action, or determination of the Water Resources Director after reconsideration, the user may further appeal to the City Council. 25 Chapter 8: Resources
In accordance with 40 CFR Part 403.8(f)(3)-(4), the City currently receives and provides funding and qualified staff sufficient to adequately administer the Pretreatment Program.

The Pretreatment Program Coordinator (Laboratory Analyst Coordinator) is the only fulltime position staffing the Pretreatment Program. As discussed in Chapter 1 of this document, the Pretreatment Program Coordinator receives additional as needed support from the City legal staff, the City engineering staff, the City Laboratory staff, the Water Resources Manager, and the Wastewater Treatment Superintendent.

The City has significantly increased the level of resources available to the Pretreatment Program since 1989. The funds for the pretreatment program come from the wastewater collection and treatment fees. Additional fees are collected for wastewater discharge permits, this is a nominal amount which covers the sampling required to determine the facility’s compliance.

A general review of the Pretreatment Program budget is included in the annual report each year. The budget for the Pretreatment Program includes money for new equipment, replacement equipment, and sample analyses by a contract laboratory. The budget also includes money for training so that Pretreatment Program staff may attend at least one training conference each year. This is important to allow staff to keep abreast of the ever changing pretreatment regulations.

An itemized list of the equipment resources dedicated to the pretreatment program is included below. This information is updated annually in the annual report. 26 Chapter 9: Public Participation and Confidentiality
Public participation in the form of presentations to local special interest groups, public meetings (e.g., City Council meetings, Water Commission hearings) with the regulated community, and mailings in the sewer bills is undertaken to inform and educate the general public. El Estero Water Resource Center Water Resource Center tours also provide an opportunity to explain pretreatment to the general public.

The City is also required to meet public participation requirements, in accordance with 40 CFR Part 403.8(f)(2)(viii), by providing at least annually public notification, in the largest daily newspaper published in the service area of the El Estero Water Resource Center Resource Center, of permitted users which, during the previous 12 months were in significant noncompliance with pretreatment standards or requirements. Significant noncompliance is defined as one or more of the following:

1. Chronic violations of wastewater discharge limits, defined here as those in which 66 % or more of all of the measurements taken for the same pollutant during a six-month period exceed (by any magnitude) a numeric pretreatment standard or requirement, including instantaneous limits, as defined by 40 CFR Part 403.3(l);

2. Technical Review Criteria (TRC) violations, defined here as those in which 33% or more of all of the measurements taken for the same pollutant during a six-month period equal or exceed the product of the numeric pretreatment standard or requirement including instantaneous limits, as defined by 40 CFR Part 403.3(l) multiplied by the applicable TRC (TRC=1.4 for BOD, TSS, fats, oil, and grease, and 1.2 for all other pollutants except pH).

3. Any other violation of a pretreatment standard or requirement as defined by 40 CFR Part 403.3(l) (daily maximum, long-term average, instantaneous limit, or narrative standard) that the City determines has caused, alone or in combination with other discharges, interference, or pass through (including endangering the health and safety of City personnel or the general public).

4. Any discharge of a pollutant that has caused imminent endangerment to human health or welfare or to the environment or has resulted in the City’s exercise of its emergency authority to halt or prevent such a discharge.

5. Failure to meet, within 90 days after the schedule date, a compliance schedule milestone contained in a local control mechanism or enforcement order for starting construction, completing construction, or attaining final compliance;

6. Failure to provide, within 45 days after the due date, required reports such as baseline monitoring reports, 90-day compliance reports, periodic selfmonitoring reports, and reports on compliance with compliance schedules;

7. Failure to accurately report noncompliance; or
27 8. Any other violation or group of violations, which may include a violation of BMPs, which the City determines will adversely affect the operation or implementation of its Pretreatment Program.

The newspaper having the largest circulation in the El Estero Water Resource Center Resource Center service area is the. Upon submittal for publication of permitted users in significant noncompliance, the City receives a proof of publication from the newspaper, and maintains a record of that information.

In accordance with 40 CFR Part 403.8(f)(1)(vii), all permitted users are informed of their right to request confidentiality on information submitted to the City. Information and data regarding a user obtained from reports, surveys, wastewater discharge permit applications, wastewater discharge permits, monitoring programs, and the Water Resources Director’s inspection and sampling activities shall be made available to the public without restriction unless the user specifically requests in writing, and is able to demonstrate to the satisfaction of the Water Resources Director, that the release of such information would divulge information, processes, or methods of production entitled to protection as trade secrets under applicable state law. Any such request must be made at the time of submission of the information or data. When sufficiently demonstrated by the user furnishing a report that such information should be held confidential, the portions of a report which might disclose trade secrets or secret processes shall not be made available for inspection by the public, but shall be made available immediately upon request to governmental agencies for uses related to the NPDES program or Pretreatment Program, and in enforcement proceedings involving the user furnishing the report. Notwithstanding the above, wastewater constituents and characteristics and other effluent data as defined in 40 CFR Part 2.302 shall not be recognized as confidential information and shall be made available to the public without restriction.

ATTACHMENT 2

CITY OF SANTA BARBARA WATER RESOURCES DEPARTMENT

WASTEWATER DISCHARGE PERMIT STANDARD CONDITIONS
Section A. General Conditions and Definitions

1. Duty to Comply
The Permittee must comply with all conditions of this permit. Failure to comply with the requirements of this permit may be grounds for administrative action or enforcement proceedings including civil or criminal penalties, administrative penalties, injunctive relief, and/or termination of this permit.

2. General Discharge Prohibitions
The Permittee shall not introduce or cause to be introduced into the City of Santa Barbara Community Sewer or El Estero Water Resource Center (Plant) any waste or wastewater which causes pass through or interference. The Permittee shall comply with all the generally applicable discharge standards, under which the Permittee is prohibited from introducing into the Community Sewer or Plant any of the following:
a. Discharges, which cause or threaten to cause a fire or explosion hazard in the Community Sewer or Plant including but not limited to wastestreams with a closed cup flashpoint of less than 140°F (60°C) (using the test methods specified in 40 CFR Part 261.21). Closed-cup flashpoint values may be found in the National Institute of Occupational Safety and Health (NIOSH) Pocket Guide to Chemical Hazards. b. Discharges with a pH lower than 6.0 standard units or higher than 10.0 standard units, or any discharge, which causes corrosive structural damage to the Community Sewer or Plant or equipment. c. Discharges that contain solids or viscous substances in amounts that will cause obstruction of flow in the Community Sewer or Plant resulting in interference or damage. d. Discharges that include oxygen-demanding substances (BOD, etc.) which are released at a flow rate and/or pollutant concentration, which either singly or by interaction with other pollutants, will cause interference with the Plant.
e. Discharges that cause the temperature at the Plant to be greater than 104°F (40°C), impairment or inhibition of biological treatment processes, or temperatures greater than 140°F (40°C) at the point of discharge.
f. Discharges that include petroleum oil, nonbiodegradable cutting oil, or products of mineral oil origin in amounts that will cause interferences or pass through.
g. Discharges, which result in the release of toxic vapors or fumes in a quantity, which, alone or in conjunction with other discharges, may cause worker health and safety problems or create a public nuisance.
h. Discharges from any trucked or hauled pollutants, except at discharge points designated by the City.

City of Santa Barbara Wastewater Discharge Permit Standard Conditions Page 2 of 13 Revised August [Deleted] 2023 [End Deleted] [New Language] 2026 [End New Language] i. Discharges that are noxious or malodorous liquids, gases, solids, or other wastewater, which either singly or by interaction with other wastes, are sufficient to create a public nuisance or a hazard to life, or to prevent entry into the Community Sewer for maintenance and repair. j. Discharges, which cause Plant effluent residues, sludges, or scums to be unsuitable for reclamation and reuse, or which interfere with the reclamation process, or which increase the costs of disposal of Plant effluent or sludges.
k. Discharges that have a detrimental environmental impact, constitute a public nuisance in waters of the State, or create a condition unacceptable to any public agency having regulatory jurisdiction over the Community Sewer and/or Plant.
l. Discharges, which create conditions at or near the Plant, which violate any statute, rule, regulation, or ordinance of any public agency or State or Federal regulatory body, or which cause the City to violate its National Pollutant Discharge Elimination System (NPDES) Permit. m. Discharges at high quantities or rates of flow, which overload the City’s collection or treatment facilities, cause excessive collection or treatment costs, or use a disproportionate share of the Community Sewer or Plant facilities.
n. Discharges that cause a lower explosive limit (LEL) reading of greater than ten percent (10%) as hexane at any point within the Community Sewer or Plant. LEL values may be found in the NIOSH Pocket Guide to Chemical Hazards.
o. Discharges that cause obstruction or increased treatment costs due to the presence of any sand, grit, straw, metal, glass, rags, feathers, tar, plastic, wood, manure, dead animals, or offal that may in any way interfere with proper operation of the Community Sewer or Plant. p. Discharges that cause toxicity at the treatment plant or in the Community Sewer or Plant due to the presence of toxic or poisonous substances in sufficient quantities to constitute a hazard to humans or animals or to create a hazard at the treatment plant or injure or interfere with any sewage treatment processes.
q. Any other discharges prohibited or restricted by the Title 16 of the City of Santa Barbara Municipal Code.

3. Point of Effluent Limitation Application
Wastewater shall not exceed any local limitations for pollutants discharged to the Community Sewer or Plant. If the Permittee fails to provide a monitoring location, which characterizes the entire wastestream being discharged to the Community Sewer or Plant, local limitations shall apply at the monitoring point specified in the permit.

Federal Categorical Limits shall apply at the end of regulated processes, prior to dilution of the regulated wastestream by any non-regulated wastestream. If there is no available location to sample the regulated wastestream, the Combined Wastestream Formula (40 CFR Part 403.6(e)) shall be applied.

4. Dilution
The Permittee shall not increase the use of process waste, or in any way attempt to dilute a discharge, as a partial or complete substitute for adequate treatment to achieve compliance with a discharge limitation, unless expressly City of Santa Barbara Wastewater Discharge Permit Standard Conditions Page 3 of 13 Revised August [Deleted] 2023 [End Deleted] [New Language] 2026 [End New Language] authorized by an applicable Pretreatment Standard or Requirement. The City may impose mass limitations on Permittees who use dilution to meet applicable Pretreatment Standards or Requirements, or in cases when mass limitations are appropriate.

5. Permit Modification
The terms and conditions of this permit may be subject to modification and change by the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language] prior to the expiration of this permit. The Permittee must be notified of any modification to this permit at least [Deleted] thirty (30)[End Deleted] [New Language] 30 [End New Language] days prior to the effective date. Any modifications or new conditions in this permit must be issued in writing and include a reasonable time schedule for compliance.

This permit may be modified for good causes including, but not limited to the following:
a. To incorporate any new or revised Federal, State or local Pretreatment Standards or Requirements; b. To address significant alterations or additions to the Permittee’s operations, processes, or wastewater volume or character since the time of permit issuance;
c. A change in the Community Sewer or Plant that requires either a temporary or permanent reduction or elimination of the authorized discharge;
d. Information indicating that the permitted discharge poses a threat to the Community Sewer, Plant, City personnel, or receiving water;
e. Violation of any terms or conditions of this permit; f. Misrepresentation or failure to disclose fully all relevant facts in the Wastewater Discharge Permit Application or in any required reporting;
g. Revision of, or a grant of variance from, any Categorical Pretreatment Standard; or h. To correct typographical or other errors in the permit.

The filing of a request by the Permittee for a permit modification, revocation, reissuance, or termination shall not justify or excuse any failure to observe all permit conditions. Notifications of planned changes or anticipated noncompliance shall not justify or excuse any failure to observe all permit conditions.

6. Permit Termination
This permit may be terminated upon written notice from the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language] for any one or combination of the following reasons:
a. Failure to notify the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language] of significant changes to the wastewater prior to the changed discharge pursuant of Title 16 of the City of Santa Barbara Municipal Code;
b. Misrepresentation or failure to fully disclose all relevant facts in the Wastewater Discharge Permit Application; c. Falsifying self-monitoring reports and certification statements; d. Tampering with monitoring equipment;
City of Santa Barbara Wastewater Discharge Permit Standard Conditions Page 4 of 13 Revised August [Deleted] 2023 [End Deleted] [New Language] 2026 [End New Language] e. Refusing to allow the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language] timely access to the facility premises and/or records; f. Failure to meet effluent limitations;
g. Failure to pay fines;
h. Failure to pay sewer charges;
i. Failure to meet compliance schedules;
j. Failure to complete a wastewater survey or the Wastewater Discharge Permit Application; k. Violation of any Pretreatment Standard or Requirement, or any terms of the Wastewater Discharge Permit or Title 16 of the City of Santa Barbara Municipal Code; or l. Cessation of operations or transfer of business ownership.

7. Permit Appeals
Anyone affected by the issuance of this permit may appeal the terms and provisions of the permit within [Deleted] fifteen (15) [End Deleted] [New Language] 15 [End New Language] days of issuance by filing a written petition for appeal with the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language]. Such written petition for appeal shall indicate the specific permit conditions or provisions objected to, the particular reasons for objections, and the alternative condition or provision, if any, that is offered, instead of that objected to. Failure to submit a petition for appeal shall be a waiver of the right to appeal. Failure to provide timely objection to a provision or condition of a permit shall thereafter waive objection or challenge to such provision or condition.

The permit and conditions approved by the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language] shall remain effective pending any action on appeal. The [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language] may suspend the application of any provision or condition pending reissuance. The [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language] may approve any provision(s) or condition(s) appealed and reissue the permit.

A decision, action, or determination of the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language], after reconsideration is determined or denied, may be appealed to the City Council under provisions of Chapter 1.30 of the City of Santa Barbara Municipal Code.

8. Limitation on Permit Transfer
Wastewater Discharge Permits are issued to a specific Permittee for a specific operation. A Wastewater Discharge Permit shall not be reassigned, transferred, or sold to a new or different owner, Permittee, or premises or to a new or changed operation at or on any permitted or previously permitted premises.

City of Santa Barbara Wastewater Discharge Permit Standard Conditions Page 5 of 13 Revised August [Deleted] 2023 [End Deleted] [New Language] 2026 [End New Language]

9. Duty to Reapply
If the Permittee wishes to continue an activity regulated by this permit after the expiration date of this permit, the Permittee must submit an application for a new permit at least forty-five (45) days before the expiration date of this permit.

10. Continuation of Expired Permits
An expired permit will continue to be effective and enforceable until a new permit is reissued, if:
a. The Permittee has submitted a complete Wastewater Discharge Permit Application at least [Deleted] forty five (45) [End Deleted] [New Language] 45 [End New Language] days prior to the expiration date of the Permittee’s existing permit; and
b. The failure to reissue the permit, prior to the expiration of the existing permit, is not due to any act or failure on the part of the Permittee.

11. Property Rights
The issuance of this permit does not convey any property rights of any sort or any exclusive privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor any violation of Federal, State, or local laws or regulations.

12. Severability
The provisions of this permit are severable, and if any provision(s) of the permit, or the application of any provision of this permit circumstance, is held invalid, the application of such provision to other circumstances, and the remainder of this permit, shall not be affected thereby.

Section B. Operation and Maintenance of Pretreatment Controls

1. Proper Operation and Maintenance
The Permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the Permittee to achieve compliance with conditions of this permit. Proper operation and maintenance includes, but is not limited to, effective performance, adequate funding, adequate operator staffing and training, and adequate laboratory process controls, including appropriate quality assurance procedures. This provision requires that there are back-up or auxiliary facilities of similar systems that are operable only when necessary to achieve compliance with the conditions of the permit.

2. Duty of Halt or Reduce Activity
Upon reduction of efficiency of operation, or loss of all or part of the treatment facility, the Permittee shall, to the extent necessary to maintain compliance with its permit, control its discharges until operation of the treatment facility is restored or an alternative method of treatment is provided. This requirement applies for example, when the primary source of power of the treatment facility fails or is reduced. It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit.

City of Santa Barbara Wastewater Discharge Permit Standard Conditions Page 6 of 13 Revised August [Deleted] 2023 [End Deleted] [New Language] 2026 [End New Language]

3. Duty to Mitigate
The Permittee shall take all reasonable steps to minimize and/or correct any adverse impact to the public, Community Sewer or Plant, or the environment resulting from noncompliance with this permit, including accelerated or additional monitoring as necessary to determine the nature and impact of a non-complying discharge.

4. Bypass of Treatment Facilities
Bypass is prohibited, and the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language] may take an enforcement action against the permittee for a bypass unless:
a. Bypass is unavoidable to prevent loss of life, personal injury, or severe property damage; or b. There were no feasible alternatives to the bypass, such as the use of auxiliary treatment facilities, retention of untreated wastes, or maintenance during normal periods of equipment downtime. This condition is not satisfied if adequate back-up equipment should have been installed in the exercise of reasonable engineering judgment to prevent a bypass which occurred during normal periods of equipment downtime or preventative maintenance.

5. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control of wastewaters shall be disposed of in accordance with Section 405(c) and (d) of the Clean Water Act, the Resource Conservation and Recovery Act, and Title 22 of the California Code of Regulations.

6. Slug Discharges
The Permittee shall not discharge or caused to be discharged any slug load of materials, chemicals, products, or wastes into the Community Sewer and/or Plant. The City may require a Permittee to develop a plan to control slug discharges if it is determined by the City that such a plan is necessary. Any Permittee discharging a slug load of materials, chemicals, products, or wastes into the Community Sewer and/or Plant to avoid sewer service charges for the treatment violates Title 16 of the City of Santa Barbara Municipal Code, and may be subjected to enforcement actions. Any slug load that damages the Community Sewer and/or Plant is a major violation. Slug loads that do not damage the Community Sewer and/or Plant may be a minor violation.

Section C. Monitoring Requirements

1. Representative Sampling
Samples and measurements taken as required herein shall be representative of the volume and nature of the monitored discharge. All samples shall be taken at the monitoring points specified in this permit and, unless otherwise specified, before the effluent joins or is diluted by any other wastestream body of water or substance. All equipment used for sampling and analysis must be routinely calibrated, inspected, and maintained, according to the manufacturer’s specifications, to ensure their accuracy. Monitoring points shall not be changed without notification to and prior approval of the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language].

City of Santa Barbara Wastewater Discharge Permit Standard Conditions Page 7 of 13 Revised August [Deleted] 2023 [End Deleted] [New Language] 2026 [End New Language]

2. Analytical Methods to Demonstrate Continued Compliance All sampling and analysis required by this permit shall be performed in accordance with the techniques prescribed in 40 CFR Part 136 and amendments thereto, otherwise approved by USEPA, or as specified in this permit. Where 40 CFR Part 136 does not contain sampling or analytical techniques for the pollutant in question, or where the USEPA Administrator, or their designee, determines that the 40 CFR Part 136 sampling and analytical techniques are inappropriate for the pollutant in question, sampling and analysis shall be performed using validated analytical methods or any other applicable sampling and analysis procedures approved by the USEPA Administrator, or their designee, including procedures suggested by the City or other parties.

3. Additional Monitoring by the Permittee
If the Permittee monitors any pollutant more frequently than required by this permit, using test procedures describe in Section C.2, the results of this monitoring shall be included in the Permittee’s self-monitoring reports.

Section D. Reporting Requirements

1. Duty to Notify
a. The [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language] must be notified [Deleted] three (3) to five (5) [End Deleted] [New Language] 3 to 5 [End New Language] days prior to commencement of discharge to the Community Sewer or Plant. b. The Permittee shall give advance notice to the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language] of any planned changes in the permitted facility or activity, which may result in noncompliance with permit requirements. c. The Permittee shall promptly notify the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language] of any substantial change in the volume or character of pollutants in their discharge that may affect the potential for a slug discharge. d. The Permittee is required to notify the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language] immediately of any spills, slug loads, or any other discharge which may cause a potential problem to the Community Sewer or the Plant. e. Any Permittee that experiences an upset in operations that places the Permittee in a temporary state of noncompliance with the provisions of either this permit or with Title 16 of the City of Santa Barbara Municipal Code shall notify the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language].
f. The Permittee shall notify the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language] if it violates any discharge limits. g. The nature and quantity of any waste identified as hazardous waste under Title 22 of the California Code of Regulations, which is discharged into the Community Sewer, must be reported to the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language], and a permit received City of Santa Barbara Wastewater Discharge Permit Standard Conditions Page 8 of 13 Revised August [Deleted] 2023 [End Deleted] [New Language] 2026 [End New Language] for such discharge. If such discharge is otherwise exempt or the definition altered by reason of discharge into the Community Sewer, the Pretreatment staff shall be notified as well. h. In any of the cases noted above in paragraphs (b)-(g), the Permittee shall notify the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language] or City staff within [Deleted] twenty-four (24) [End Deleted] [New Language] 24 [End New Language] hours of becoming aware of a violation, upset, or other issues that may be a potential problem to the Community Sewer or Plant. Oral notification shall be followed, within [Deleted] five (5) [End Deleted] [New Language] 5 [End New Language] days, by a written report detailing the nature and circumstances of the violations. The report shall specify:
(i) Description of the violation, upset, or other issue that may be a potential problem to the Community Sewer or Plant, the cause(s) thereof, and the impact on the Permittee’s compliance status; (ii) Duration of noncompliance, including exact dates and times of the noncompliance, and if not corrected, the anticipated time the noncompliance is expected to continue; and (iii) All steps taken or to be taken to reduce, eliminate, or prevent recurrence of such a violation.

The report must also demonstrate that the treatment facility was being operated in a prudent and workman-like manner.

2. Notification of Bypass
a. Anticipated bypass. If the Permittee knows in advance of the need for a bypass, it shall submit prior written notice to the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language], at least ten (10) days before the date of the bypass, if possible. b. Unanticipated bypass. The Permittee shall immediately notify the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language] within [Deleted] twenty-four (24) [End Deleted] [New Language] 24 [End New Language] hours from the time it becomes aware of the bypass. A written notice shall be provided within [Deleted] five (5) [End Deleted] [New Language] 5 [End New Language] days [Deleted] of [End Deleted] [New Language] after [End New Language] the time the Permittee becomes aware of the bypass. This report shall specify:
(i) A description of the bypass, and its cause, including its duration, exact dates and times; (ii) Whether the bypass has been corrected;
(iii) If the bypass has not been corrected, the anticipated time it is expected to continue; and (iv) The steps being taken or to be taken to reduce, eliminate and prevent a reoccurrence of the bypass.

3. Monitoring Waivers
The City may authorize a User subject to a Pretreatment Standard to forego sampling of a pollutant regulated by a Pretreatment Standard if the User has demonstrated through sampling and other technical factors that the pollutant is not present nor expected to be present in the discharge, or is only present at background levels from intake water City of Santa Barbara Wastewater Discharge Permit Standard Conditions Page 9 of 13 Revised August [Deleted] 2023 [End Deleted] [New Language] 2026 [End New Language] and without any increase in the pollutant due to the activities of the User. This authorization is subject to the following conditions:
a. The waiver may be authorized where a pollutant is determined to be present solely due to sanitary wastewater discharged from the facility provided that the sanitary wastewater is not regulated by an applicable Pretreatment Standard and otherwise includes no process wastewater. b. The monitoring waiver is valid only for the duration of the effective period of the wastewater discharge permit, but in no case longer than [Deleted] five (5) [End Deleted] [New Language] 5 [End New Language] years. The User must submit a new request for the waiver before the waiver can be granted for each subsequent wastewater discharge permit.
c. In making a demonstration that a pollutant is not present, the User must provide data from at least one sampling of the facility’s process wastewater prior to any treatment present at the facility that is representative of all wastewater from all processes.
d. The request for a monitoring waiver must be signed in accordance with Section 16.02.040(C) and include the certification statement in Section 16.08.060 of this Title. e. Non-detectable sample results may be used only as a demonstration that a pollutant is not present if the USEPA-approved method from 40 CFR Part 136 with the lowest minimum detection level for that pollutant was used in the analysis.
f. Any grant of the monitoring waiver by the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language] must be included as a condition in the User’s wastewater discharge permit. The reasons supporting the waiver and any information submitted by the User in its request for the waiver must be maintained by the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language] for three [Deleted] (3) [End Deleted] years after expiration of the waiver.
g. Upon approval of the monitoring waiver and revision of the User’s wastewater discharge permit by the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language], the User must certify on each report with the statement in Section 16.08.060 of this Title that there has been no increase in the pollutant in its wastestream due to activities of the User. h. [Deleted] In the event that [End Deleted] [New Language] If [End New Language] a waived pollutant is found to be present or is expected to be present because of changes that occur in the User’s operations, the User must immediately: comply with the monitoring requirements imposed by the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language] and notify the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language]. i. This provision does not supersede certification processes and requirements established in categorical Pretreatment Standards, except as otherwise specified in the categorical Pretreatment Standard.

4. Signatory Requirements
All applications, reports or information submitted to the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language] must contain the following certification statement to be City of Santa Barbara Wastewater Discharge Permit Standard Conditions Page 10 of 13 Revised August [Deleted] 2023 [End Deleted] [New Language] 2026 [End New Language] signed by an authorized or duly authorized representative of the Permittee as required in Sections (a), (b), (c), or (d) below:
“I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.” a. If the Permittee is a corporation:
(i) The president, secretary, treasurer, or vice president of the corporation in charge of a principal business function, or any other person who performs similar policy- or decision-making functions for the corporation, or;
(ii) The manager of one or more manufacturing, production, or operating facilities, provided the manager is authorized to make management decisions that govern the operation of the regulated facility including having the explicit or implicit duty of making major capital investment recommendations, and initiate and direct other comprehensive measures to assure long-term environmental compliance with environmental laws and regulations; can ensure that the necessary systems are established or actions taken to gather complete and accurate information for Wastewater Discharge Permit requirements; and where authority to sign documents has been assigned or delegated to the manager in accordance with corporate procedures.
b. If the Permittee is a partnership or sole proprietorship: a general partner or proprietor, respectively. c. If the Permittee is a Federal, State or local government facility: a director or highest official appointed or designated to oversee the operation and performance of the activities of the government facility, or their designee.
[New Language] d. [End New Language] The individuals described in subdivisions (a) through (c) above, may designate a duly authorized representative, if the authorization is in writing. The authorization specifies the individual or position responsible for the overall operation of the facility from which the discharge originates or having overall responsibility for environmental matters for the facility. This authorization must be made in writing by the principal executive officer or ranking elected official, and submitted to the City prior to or together with any document being submitted.

5. Falsifying Information
Knowingly making any false statement on any report or other document required by this permit or knowingly rendering any monitoring device or method inaccurate, is a crime and may result in the imposition of criminal sanctions and/or civil penalties.

6. Retention of Records
a. The Permittee shall at all times keep and maintain accurate, current and legible records, which show the following:

City of Santa Barbara Wastewater Discharge Permit Standard Conditions Page 11 of 13 Revised August [Deleted] 2023 [End Deleted] [New Language] 2026 [End New Language] (i) Time, place, quantity, and constituents and characteristics of all discharges on or from any premises under the control of Permittee.
(ii) For any sampling required to be taken pursuant of this permit:
(a) Date and exact place, method, preservation techniques, and time of sampling; (b) Name(s) of the person(s) taking the samples;
(c) Date(s) that all analyses of the samples were performed; (d) Who performed the analyses;
(e) Results of the analyses; and
(f) Analytical techniques or methods used.
a. The Permittee shall retain records of all monitoring information, including all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation, copies of all reports required by this permit, and records of all data used to complete the application for this permit, for a period of at least three [Deleted] (3) [End Deleted] years from the date of the sample, measurement, report, or application.
b. This period may be extended by request of the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language] at any time. c. All records that pertain to matters that the subject of special orders or any other enforcement or litigation activities brought by the City shall be retained and preserved by the Permittee until all enforcement activities have concluded and all periods of limitations with respect to any and all appeals have expired. d. No SIU shall fail to transmit reports by electronic means by a designated electronic document receiving system that satisfies the requirements of CROMERR set forth in 40 CFR 3, including but not limited to the electronic signature agreement requirement, and verified with a valid electronic signature to develop a copy of record.
[New Language] e. The City has developed procedures for receipt of electronic reports through a CROMERR compliant system for any reporting requirements of Title 16 of the Santa Barbara Municipal Code in compliance with 40 CFR Part 3. These procedures are enforceable under Title 16 of the Santa Barbara Municipal Code. Each User shall submit such CROMERR reports as authorized by the procedures adopted by the City pursuant to Title 16 of the Santa Barbara Municipal Code or as identified in this Permit within the time frame set forth in this Permit, the User has 90 calendar days from the date of issuance of this Permit to become CROMERR compliant. The User may request additional time for good cause, but such request does not automatically extend the deadline for becoming CROMERR compliant. [End New Language] City of Santa Barbara Wastewater Discharge Permit Standard Conditions Page 12 of 13 Revised August [Deleted] 2023 [End Deleted] [New Language] 2026 [End New Language] Section E. Inspections and Enforcement

1. Duty to Provide Information
The Permittee shall furnish to the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language], within [Deleted] fifteen (15) [End Deleted] [New Language] 15 [End New Language] days any information which the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language] may request to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit, or to determine compliance with this permit. The Permittee shall also, upon request, furnish to the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language] copies of any records required to be kept by this permit.

2. Inspection and Entry
The [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language] or his designee shall have the right to enter and inspect the Permittee’s premises for the purpose of determining whether the Permittee is complying with all applicable regulations and the conditions of this permit and for the purpose of performing any duties provided in Title 16 of the City of Santa Barbara Municipal Code.

Failure to allow access to the [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language], at any time, to any building, structure, or property, or any part thereof, is a violation of this Wastewater Discharge Permit, and may result in issuance and execution of a search warrant and/or revocation of this Wastewater Discharge Permit.

3. Civil and Criminal Penalties for Violations of Permit Conditions The Permittee is subject to appropriate enforcement action, in accordance with Title 16 of the City of Santa Barbara Municipal Code, including civil and criminal penalties if it violates any condition of this Wastewater Discharge Permit, Title 16 of the City of Santa Barbara Municipal Code, or any other applicable local, State, or Federal regulation, law, statute, rule, and/or code.

Section 16.14.050 of the City of Santa Barbara Municipal Code provides that any Permittee who violates a permit condition is subject to a civil penalty of up to $5,000 per day of such violation. Section 16.14.060 of the City of Santa Barbara Municipal Code provides that any person who intentionally or negligently violates permit conditions is subject to criminal penalties of a fine of up to $25,000 per day of violation, or by imprisonment or both. Additionally, the Permittee may also be subject to sanctions under State and/or Federal law.

Nothing in this permit shall be construed to relieve the Permittee from civil and/or criminal penalties due to noncompliance under [Deleted] Chapter [End Deleted] [New Language] Title [End New Language] 16 [Deleted] .14 [End Deleted] of the City of Santa Barbara Municipal Code or State or Federal laws or regulations.

4. Annual Publication
The City, in the largest daily newspaper within its service area, annually publishes a list of all users, which were in significant noncompliance during the [Deleted] twelve- (12-) [End Deleted] [New Language] 12 [End New Language] previous months. Accordingly, the Permittee is apprised that noncompliance with this permit may lead to an City of Santa Barbara Wastewater Discharge Permit Standard Conditions Page 13 of 13 Revised August [Deleted] 2023 [End Deleted] [New Language] 2026 [End New Language] enforcement action and may result in publication of its name in an appropriate newspaper in accordance with Section 16.14.032 of the City of Santa Barbara Municipal Code.

5. Recovery of Costs Incurred
In addition to civil and criminal liability, a Permittee violating any of the provisions of this permit or Title 16 of the City of Santa Barbara Municipal Code or causing damage to or otherwise inhibiting the Community Sewer or Plant shall be liable to the City for any expense, loss, or damage caused by such violation or discharge. The [Deleted] Public Works Director [End Deleted] [New Language] Water Resources Director [End New Language] shall bill the Permittee for the costs incurred by the City for any cleaning repair or replacement work caused by the violation or discharge. Refusal to pay the assessed costs shall constitute a separate violation of Title 16 of the City of Santa Barbara Municipal Code. 1 [Council Introduction Draft Showing Changes From Current Code 8/25/2026] Ordinance No.

AN ORDINANCE OF THE COUNCIL OF THE CITY OF SANTA
BARBARA AMENDING TITLE 16 OF THE SANTA BARBARA

MUNICIPAL CODE RELATING TO LIQUID AND INDUSTRIAL WASTE

DISPOSAL BY THE AMENDMENT OF VARIOUS SECTIONS TO

AUTHORIZE THE WATER RESOURCES DIRECTOR TO ESTABLISH

AND IMPLEMENT AN ELECTRONIC DOCUMENT RECEIVING

SYSTEM CONSISTENT WITH THE FEDERAL CROSS-MEDIA

ELECTRONIC REPORTING RULE AND TO DESIGNATE THE WATER

RESOURCES DIRECTOR IN PLACE OF THE PUBLIC WORKS
DIRECTOR IN VARIOUS SECTIONS OR SUBSECTIONS OF TITLE 16 THE CITY COUNCIL OF THE CITY OF SANTA BARBARA DOES ORDAIN AS FOLLOWS:

Section 1
That Title 16, Chapter 16.02, Section 16.02.040 of the Santa Barbara Municipal Code is amended to read as follows:

16.02.040 Definitions.

Unless otherwise defined herein, terms shall be as adopted in the most recent edition of Standard Methods for the Examination of Water and Wastewater, published by the American Public Health Association, the American Water Works Association, and the Water Environment Federation. Waste constituents and characteristics shall be measured in accordance with the procedures established by the Administrator under Section 304(h) of the Federal Act, and as set forth in detail in methods promulgated or approved pursuant to 40 CFR Part 136, Test Procedures for the Analysis of Pollutants. Methods for sampling and analysis of wastewater may deviate from these regulations only when 40 CFR Part 136 fails to address sampling or analytical techniques for a particular pollutant or when alternative methods of analysis have been approved by the Administrator as equivalent procedures.

Unless the context requires a different meaning, the following words shall have the meaning indicated:

Administrator. The EPA Administrator or his or her designee.

Applicable Regulation(S). All City, State, and Federal regulations, rules, laws, ordinances, and codes as they apply to discharges by users to, on, or in the POTW and/or any community sewer.

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2 Authorized Representative of the User.

1. If the user is a corporation:
a. The president, secretary, treasurer, or a vice-president of the corporation in charge of a principal business function, or any other person who performs similar policy or decision-making functions for the corporation; or
b. The manager of one or more manufacturing, production, or operating facilities, provided the manager is authorized to make management decisions that govern the operation of the regulated facility, including having the explicit or implicit duty of making major capital investment recommendations, and initiate and direct other comprehensive measures to assure long-term environmental compliance with environmental laws and regulations; can ensure that the necessary systems are established or actions taken to gather complete and accurate information for Wastewater Discharge Permit requirements; and where authority to sign documents has been assigned or delegated to the manager in accordance with corporate procedures.

2. If the user is a partnership or sole proprietorship: A general partner or proprietor, respectively.

3. If the user is a Federal, State, or local government facility: A director or highest official appointed or designated to oversee the operation and performance of the activities of the government facility, or their designee.

4. The individuals described in paragraphs 1 through 3 above may designate a duly authorized representative if the authorization is in writing. The authorization specifies the individual or position responsible for the overall operation of the facility from which the discharge originates or having overall responsibility for environmental matters for the facility. This authorization must be made in writing by the principal executive officer or ranking elected official, and submitted to the City prior to or together with any document being submitted.

Batch Dump or Batch Discharge. The discharge of concentrated, non-compatible pollutants of a quality or in a manner or method which does not comply with this title or other applicable State or Federal laws and regulations.

Beneficial Uses. Any and all use of the Waters of the State that are protected against quality degradation, including, but not limited to, domestic, municipal, and agricultural use, use for Council Introduction Draft Showing Changes From
Current Code 8/25/2026
3 industrial supply, power generation, recreation, aesthetic enjoyment, or navigation, use for the preservation and enhancement of fish, wildlife and other aquatic resources or reserves, and other beneficial uses, tangible and intangible, as specified by Federal or State law or other applicable regulations.

Best Management Practices or BMPs. The schedules of activities, prohibitions of practices, maintenance procedures, and other management practices to implement the prohibitions listed in 40 CFR Part 403.5(a)(1) and (b). BMPs include treatment requirements, operating procedures, and practices to control plant site runoff, spillage or leaks, sludge or waste disposal, or drainage from raw materials storage.

Building Sewer. A sewer conveying wastewater from the premises of a user to a community sewer.

Biochemical Oxygen Demand or BOD. The quantity of oxygen required for the biochemical oxidation of organic matter under standard laboratory procedures for five days at 20 degrees centigrade, usually expressed as a concentration (e.g., mg/L).

Bypass. The intentional diversion of waste streams from any portion of a user’s treatment facility.

California Code of Regulations or CCR. The publication of the State of California government containing finalized State regulations.

Categorical Industrial User. Any user subject to a categorical pretreatment standard or categorical standard.

Categorical Pretreatment Standard or Categorical Standards. Any regulation containing pollutant discharge limits promulgated by EPA in accordance with Sections 307(b) and (c) of the Federal Act [Deleted] (33 U.S.C. 1317) [End Deleted] that apply to specific categories of users and that appear in 40 CFR Chapter I, Subchapter N, Parts 405-471.

City. City of Santa Barbara. When a provision of this title authorizes or requires a determination by the City, that determination may be made by the[Deleted] Public Works [End Deleted] [New Language] Water Resources [End New Language] Director.

Code of Federal Regulations or CFR. The publication of the United States government that contains finalized Federal regulations.

Commercial User. Any source of wastewater discharge originating from a commercial business.

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Current Code 8/25/2026
4 Commercial Wastewater. Liquid wastes originating from a commercial business, excluding domestic wastewater and industrial wastewater.

Community Sewer or Sewer. A sewer owned and operated by the City or other public agency and tributary to the POTW operated by the City.

Compatible Pollutant. Pollutants that include biochemical oxygen demand, suspended solids, pH and fecal coliform bacteria. Compatible pollutants are noncompatible when discharged in quantities that have an adverse effect on the City’s collection system, treatment plant or NPDES Permit.

Contamination. An impairment of the quality of the Waters of the State by waste to a degree that creates a hazard to the public health through poisoning or through the spread of disease, aquatic life, or beneficial uses. Contamination shall include any equivalent effect resulting from the disposal of wastewater, whether or not Waters of the State are affected. [New Language]Copy of Record. A true and correct copy of an electronic document received by an electronic document receiving system, which copy can be viewed in a human-readable format that clearly and accurately associates all of the information provided in the electronic documents with the descriptions and labeling of the information. A copy of record:

1. All electronic signatures contained in or associated with that document;

2. Information showing the time and date of receipt by the electronic document receiving system;

3. Any other information used to record the meaning of the document or the circumstances of its receipt.

Cross-media Electronic Reporting Rule or CROMERR. Federal Code of Regulations Title 40, Chapter 1, Subchapter A, Part 3, titled Cross-Media Electronic Reporting. A regulation adopted by the EPA designed to ensure that all documents for delegated programs that are submitted electronically are legally binding and usable in court. CROMERR provides the legal framework for electronic reporting under EPA’s regulatory programs. CROMERR establishes the criteria under which agencies operating delegated programs, such as the City, may establish systems for the use of electronic documents to satisfy reporting requirements under the Federal Law. [End New Language]
Daily Maximum. The arithmetic average of all effluent samples for a pollutant collected during a calendar day.

Daily Maximum Limit. The maximum allowable discharge limit of a pollutant during a calendar day. Where daily maximum limits are expressed in units of mass, the daily discharge Council Introduction Draft Showing Changes From
Current Code 8/25/2026
5 is the total mass discharged over the course of the day. Where daily maximum limits are expressed in terms of a concentration, the daily discharge is the arithmetic average measurement of the pollutant concentration derived from all measurements taken that day.

Discharge (including “discharged,” “discharging,” “discharges”). Any spilling, leaking, pumping, pouring, emitting, emptying, injecting, escaping, leaching, dumping, disposing or releasing of any waste or wastewater to, on or in the POTW or any community sewer.

Domestic Wastewater. Liquid wastes: (1) from the noncommercial preparation, cooking, and handling of food; or (2) containing human excrement and similar matter from the sanitary conveniences of dwellings, commercial buildings, industrial facilities and institutions and as are distinct from industrial wastewater. [New Language]Electronic Document. Any information in digital form that is conveyed to the City or third-party, where “Information” may include data, text, sounds, codes, computer programs, software, or databases. “Data,” in this context, refers to a delimited set of data elements, each of which consists of a content or value together with an understanding of what the content or value means; where the electronic document includes data, this understanding of what the data element content or value means must be explicitly included in the electronic document itself or else be readily available to the electronic document recipient.

Electronic Document Receiving System. Any set of apparatus, procedures, software, records, or documentation used to receive electronic documents.

Electronic Signature. Any information in digital form that is included in or logically associated with an electronic document for the purpose of expressing the same meaning and intention as would a handwritten signature if affixed to an equivalent paper document with the same reference to the same content. The electronic document bears or has on it an electronic signature where it includes or has logically associated with it such information.

Electronic Signature Agreement. An agreement signed by an individual with respect to an electronic signature device that the individual will use to create his or her electronic signatures requiring such individual to protect the electronic signature device from compromise; to promptly report to the City any evidence discovered that the device has been compromised; and to be held as legally bound, obligated, or responsible by the electronic signatures created as by a handwritten signature.

Electronic Signature Device. A code or other mechanism that is used to create electronic signatures. Where the device is used to create an individual's electronic signature, then the code or mechanism must be unique to that individual at the time the signature is created and Council Introduction Draft Showing Changes From
Current Code 8/25/2026
6 he or she must be uniquely entitled to use it. The device is compromised if the code or mechanism is available for use by any other person.[End New Language] Environmental Protection Agency or EPA. The United States Environmental Protection Agency or, where appropriate, the Regional Water Management Division Director, the Regional Administrator, or other duly authorized official of said agency.

Existing Source. Any source of discharge that is not a “new source.” Federal Act. The Federal Water Pollution Control Act, PL 92-500, also known as the Clean Water Act, codified as amended at 33 USC Section 1251 et seq., and any amendments thereto; as well as any guidelines, limitations and standards promulgated by EPA pursuant to the Federal Act.

Food Establishment. Any restaurant, kitchen or other similar facility, whether or not operated commercially or for profit, which is required by the County of Santa Barbara to have a permit for the preparation or provision of food for human consumption.

Grab Sample. A sample that is taken from the wastestream without regard to the flow in the wastestream and over a period of time not to exceed 15 minutes. [New Language]Handwritten Signature. The scripted name or legal mark of an individual, handwritten by that individual with a marking- or writing-instrument such as a pen or stylus and executed or adopted with the present intention to authenticate a writing in a permanent form, where "a writing" means any intentional recording of words in a visual form, whether in the form of handwriting, printing, typewriting, or any other tangible form. The physical instance of the scripted name or mark so created constitutes the handwritten signature. The scripted name or legal mark, while conventionally applied to paper, may also be applied to other media.[End New Language]
Holding Tank Waste. Any waste discharged from a holding tank, including, but not limited to, vessels, chemical toilets, recreational vehicles, septic tanks, and vacuum pump tank trucks.

Incompatible Pollutant or Noncompatible Pollutant. Any pollutant that which is not a compatible pollutant as defined in this section. Incompatible pollutants shall be regulated by applicable pretreatment standards, as set forth in this title.

Industrial User. Any source of industrial wastewater discharge.

Industrial Wastewater. All water-carried wastes, excluding domestic wastewater and commercial wastewater, resulting from the processing or manufacture of goods or products.

Council Introduction Draft Showing Changes From
Current Code 8/25/2026
7 Instantaneous Limit. The maximum concentration of a pollutant allowed to be discharged at any time, determined from the analysis of any discrete or composited sample collected, independent of the industrial flow rate and the duration of the sampling event.

Interference. A discharge that, alone or in conjunction with a discharge or discharges from other sources, inhibits or disrupts the POTW’s treatment processes or operations or the processing, use or disposal of sludge by the POTW; or which causes a violation of the City’s NPDES Permit or prevents lawful sludge disposal or use in compliance with any of the following statutory/regulatory provisions or permits issued thereunder, or any more stringent State or local regulations: Section 405 of the Federal Act; the Solid Waste Disposal Act, including Title II commonly referred to as the Resource Conservation and Recovery Act (RCRA); any State regulations contained in any State sludge management plan prepared to Subtitle D of the Solid Waste Disposal Act; the Clean Air Act; the Toxic Substances Control Act; and the Marine Protection, Research, and Sanctuaries Act.

Local Limit. Specific discharge limits developed and enforced by the City upon a permitted user to implement general and specific discharge prohibitions listed in 40 CFR Part 403.5(a)(1) and (b).

Lower Explosive Limit or LEL. The minimum concentration of a combustible gas or vapor (usually expressed in percent by volume at sea level) which will ignite if an ignition source (sufficient ignition energy) is present. These concentrations can be found in the National Institute of Occupational Safety and Health Pocket Guide to Chemical Hazards.

Mass Emission Rate. The weight of material discharged to the community sewer during a given time interval. Unless otherwise specified, the mass emission rate shall mean pounds per day of a particular constituent or combination of constituents.

Medical Waste. Isolation wastes, infectious agents, human blood and blood products, pathological wastes, sharps, body parts, contaminated bedding, surgical wastes, potentially contaminated laboratory wastes, and dialysis wastes.

Monthly Average. The sum of all “daily discharges” measured during a calendar month divided by the number of “daily discharges” measured during that month.

Monthly Average Limit. The highest allowable average of “daily discharges” over a calendar month, calculated as the sum of all “daily discharges” measured during a calendar month divided by the number of “daily discharges” measured during that month.

National Pretreatment Standard, Pretreatment Standard, or Standard. Any regulation containing pollutant discharge limits promulgated by the EPA in accordance with Sections Council Introduction Draft Showing Changes From
Current Code 8/25/2026
8 307 (b) and (c) of the Federal Act, which applies to industrial users. This term includes prohibitive discharge limits.

New Source.

1. Any building, structure, facility or installation from which there is (or may be) a discharge of pollutants, the construction of which commenced after the publication of proposed pretreatment standards under Section 307(c) of the Federal Act that will be applicable to such source if such standards are thereafter promulgated in accordance with that section, provided that:
a. The building, structure, facility, or installation is constructed at a site at which no other source is located; or
b. The building, structure, facility, or installation totally replaces the process or production equipment that causes the discharge of pollutants at an existing source; or
c. The production or wastewater generating processes of the building, structure, facility, or installation are substantially independent of an existing source at the same site. In determining whether these are substantially independent, factors such as the extent to which the new facility is integrated with the existing plant, and the extent to which the new facility is engaged in the same general type of activity as the existing source should be considered.

2. Construction on a site at which an existing source is located results in a modification rather than a new source if the construction does not create a new building, structure, facility, or installation meeting the criteria of paragraphs (1)(b) or (c) of this definition, but otherwise alters, replaces, or adds to existing process or production equipment.

3. Construction of a new source as defined in this definition has commenced if the owner or operator has:
a. Begun, or caused to begin, as part of a continuous onsite construction program:
i. Any placement, assembly, or installation of facilities or equipment; or
ii. Significant site preparation work including clearing, excavation, or removal of existing buildings, structures, or facilities which is Council Introduction Draft Showing Changes From
Current Code 8/25/2026
9 necessary for the placement, assembly, or installation of new source facilities or equipment; or
b. Entered into a binding contractual obligation for the purchase of facilities or equipment which are intended to be used in its operation within a reasonable time. Options to purchase or contracts which can be terminated or modified without substantial loss, and contracts for feasibility, engineering, and design studies do not constitute a contract under this paragraph.

National Pollutant Discharge Elimination System Permit or NPDES Permit. The permit issued to control discharges from the POTW to Waters of the United States.

Nuisance. Anything which is injurious to health or is indecent or offensive to the senses or an obstruction to the free use of property so as to interfere with the comfort or enjoyment of life or property, or which affects at the same time an entire community or neighborhood or any considerable number of persons, although the extent of the annoyance or damage inflicted upon individuals may be unequal.

Pass Through. A discharge that which exits the POTW into waters of the United States in quantities or concentrations, which alone or in conjunction with a discharge or discharges from other sources, is a cause of a violation of any requirement of the City’s NPDES Permit, including an increase in the magnitude or duration of a discharge.

Pattern of Noncompliance.

1. Six or more discharges during a 12-month period, at least 33% of which contain the same non-compatible pollutant in a concentration which exceeds the amount allowed by any applicable regulation; or

2. The failure of a user on three or more occasions within a 12-month period to file timely any report or other document required to be filed by the user pursuant to any applicable regulation.

Person. Any individual, partnership, co-partnership, firm, company, association, corporation, joint stock company, trust, estate, government entity, or any other legal entity, or their legal representatives, agents, or assigns. This definition includes all Federal, State, and local government entities.

Pollutant. Dredged spoil, solid waste, incinerator residue, filter backwash, sanitary sewage, garbage, sewage sludge, munitions, medical waste, chemical waste, biological materials, radioactive materials, heat, wrecked or discarded equipment, rock, sand, cellar dirt, Council Introduction Draft Showing Changes From
Current Code 8/25/2026
10 municipal, agricultural, and industrial waste, and certain characteristics of wastewater (e.g., pH, temperature, TSS, turbidity, color, BOD, COD, toxicity, or odor).

Pollution. An alteration of the quality of the Waters of the State by waste to a degree which unreasonably affects or impairs such waters for beneficial use or facilities which serve such beneficial uses. pollution may include contamination.

Premises. Any land, including any improvements or structures thereon, which is owned, used, occupied, leased or operated by a user and from or on which discharges occur or wastewater is created.

Pretreatment. The reduction of the amount of pollutants, the elimination of pollutants, or the alteration of the nature of pollutant properties in wastewater prior to, or in lieu of, introducing such pollutants into the POTW. This reduction or alteration can be obtained by physical, chemical, or biological processes; by process changes; or by other means, except by diluting the concentration of the pollutants, unless allowed by an applicable pretreatment standard.

Pretreatment Facility. Any wastewater treatment system consisting of one or more treatment devices designed to remove sufficient pollutants from waste streams to allow a user to comply with effluent limits.

Pretreatment Requirements. Any substantive or procedural requirement related to pretreatment, other than a national pretreatment standard, imposed on a user.

Pretreatment Standard or Standards. Prohibited discharge standards, categorical pretreatment standards, and local limits.

Process Wastewater. Any water, which during manufacturing or processing, comes into direct contact with or results from the production or use of any raw material, intermediate product, finished product, by-product, or waste product from any industrial, commercial, institutional, or agricultural source.

Prohibited Discharge Standards. Absolute prohibitions against discharge of certain substances, as specified in this title.

Publicly Owned Treatment Works or POTW. A treatment works, as defined by Section 212 of the Federal Act (33 USC Section 1292), which is owned by the City. This definition includes any devices or systems used in the collection, storage, treatment, recycling, and reclamation of sewage or industrial wastewater and any conveyances which convey wastewater to a treatment plant.

Council Introduction Draft Showing Changes From
Current Code 8/25/2026
11 [Deleted]Public Works Director. The Director of Public Works for the City of Santa Barbara or his or her designated representative.[End Deleted]
Sewage. [New Language]Sewage includes domestic wastewater and industrial wastewater.[End New Language] [Deleted]Human excrement and gray water (household showers, dishwashing operations, etc.).[End Deleted]
Standard Industrial Classification or SIC. The system of classifying industries as identified in the SIC Manual, 1972, Office of Management and Budget, and as may be amended.

Significant Industrial User or SIU.

1. Any user who has waste discharge subject to categorical pretreatment standards under 40 CFR Part 403.6 and 40 CFR chapter I, subchapter N; or

2. Any user who:
a. Discharges an average of 25,000 gallons per day or more of process wastewater to the POTW, excluding sanitary, non-contact cooling, and boiler blowdown wastewater; or
b. Contributes a process waste stream that makes up five percent or more of the average dry weather hydraulic or organic capacity of the POTW; or c. Is designated by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director the basis that the user:
i. Has a reasonable potential, either individually or in combination with other contributing industries, for adversely affecting the POTW operation or the quality of effluent from the POTW; or ii. May cause or threaten to cause the City to violate its NPDES Permit; or
iii. Has a reasonable potential to violate any pretreatment standard; or iv. Has in its waste discharge an incompatible pollutant.

3. Notwithstanding paragraph 1 of this definition, the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director may determine that an Industrial user is a non-significant categorical industrial user if the director finds there is substantial evidence that the industrial user never discharges more than 100 gallons per day (gpd) of total categorical wastewater, excluding sanitary, non-contact cooling and boiler blowdown wastewater, unless Council Introduction Draft Showing Changes From
Current Code 8/25/2026
12 specifically included in the pretreatment standard. The determination is subject to the following conditions:
a. The industrial user[Deleted], prior to the City’s finding,[End Deleted] has consistently complied with all applicable categorical pretreatment standards and requirements;
b. The industrial user annually submits the certification statement required in this title, together with any additional information necessary to support the certification statement; and
c. The industrial user never discharges untreated concentrated wastewater.

4. Notwithstanding paragraph 2 of this definition, the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] may determine that a user is not a Significant Industrial User if the director finds there is substantial evidence that there is no reasonable potential that the user’s discharges will adversely affect the community sewer or the POTW’s operation, or violate any Pretreatment Standard or Requirement. The determination must be made in accordance with the procedures stated in 40 CFR Part 403.8(f)(6) and may initiated by the director or request of a user.

Significant Noncompliance or SNC. Any action or conduct by a user [New Language]that [End New Language] [Deleted]which constitutes a violation of[End Deleted] [New Language] violates [End New Language] any applicable regulation and [Deleted]which[End Deleted] consists of one or more of the following:

1. Chronic violations of wastewater discharge limits, defined here as those in which 66% or more of all of the measurements taken for the same pollutant parameter during a six-month period exceed (by any magnitude) a numeric pretreatment standard or requirement, including instantaneous limits, as defined by 40 CFR Part 403.3(l);

2. Technical review criteria (TRC) violations, defined here as those in which 33% or more of all of the measurements taken for the same pollutant parameter during a six-month period equal or exceed the product of the numeric pretreatment standard or requirement including instantaneous limits, as defined by 40 CFR Part 403.3(l) multiplied by the applicable TRC (TRC=1.4 for BOD, TSS, fats, oil, and grease, and 1.2 for all other pollutants except pH);

3. Any other violation of a pretreatment standard or requirement as defined by 40 CFR Part 403.3(l) (daily maximum, long-term average, instantaneous limit, or Council Introduction Draft Showing Changes From
Current Code 8/25/2026
13 narrative standard) that the City determines has caused, alone or in combination with other discharges, interference, or pass through (including endangering the health and safety of City personnel or the general public);

4. Any discharge of a pollutant that has caused imminent endangerment to human health, welfare or to the environment, or has resulted in the City’s exercise of its emergency authority to halt or prevent such a discharge;

5. Failure to meet, within 90 days after the schedule date, a compliance schedule milestone contained in a local control mechanism or enforcement order for starting construction, completing construction, or attaining final compliance;

6. Failure to provide, within 45 days after the due date, required reports such as baseline monitoring reports, 90-day compliance reports, periodic self-monitoring reports, and reports on compliance with compliance schedules;

7. Failure to accurately report noncompliance; or

8. Any other violation or group of violations, which may include a violation of BMPs, which the City determines will adversely affect the operation or implementation of its pretreatment program.

Slug Load or Slug Discharge. [Deleted]Any discharge at a flow rate or concentration that which could cause a violation of the prohibited discharge standards in Chapter 16.04 of this title.[End Deleted] A slug discharge is any discharge of a non-routine, episodic nature, including, but not limited to, an accidental spill or a non-customary batch discharge, which has a reasonable potential to cause interference or pass through, or in any other way violate the City’s regulations, local limits or wastewater discharge permit conditions.

State. The State of California, including any department or agency thereof.

Storm Water. Any flow occurring during or following any form of natural precipitation, and resulting from such precipitation, including snowmelt.

Total Toxic Organics. The sum of all quantifiable values greater than 0.01 mg/L for the toxic organics listed below:

Acenaphthene
4-Chlorophenyl phenyl
ether
Benzo(ghi) perylene
Acrolein
4-Bromophenyl phenyl
ether
Fluorene
Acrylonitrile
Bis(2-chloroisopropyl)
ether
Phenanthrene
Benzene
Council Introduction Draft Showing Changes From
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14 Bis(2-chloroethoxy)
ether
Dibenzo(a,h) anthracene
Benzidine
Methylene chloride
Indeno(1,2,3-cd) pyrene
Carbon tetrachloride
Methyl chloride
Pyrene
Chlorobenzene
Methyl bromide
Tetrachloroethylene
1,2,4-Trichlorobenzene
Bromoform
Toluene
Hexachlorobenzene
Dichlorobromomethane
Trichloroethylene
1,2-Dichloroethane
Chlorodibromomethane
Vinyl chloride
1,1,1-Trichloroethane
Hexachlorobutadiene
Aldrin
Hexachloroethane
Hexachlorocyclopentadie
ne
Dieldrin
1,1-Dichloroethane
Isophorone
4,4’-DDT
1,1,2-Trichloroethane
Naphthalene
4,4’-DDE
1,1,2,2-
Tetrachloroethane
Nitrobenzene
4,4’-DDD
Chloroethane
2-Nitrophenol
alpha-Endosulfan
Bis(2-chloroethyl) ether
4-Nitrophenol
beta-Endosulfan
2-Chloroethyl vinyl ether
2,4-Dinitrophenol
Endosulfan sulfate
2-Chloronaphthalene
4,6-Dinitro-o-cresol
Endrin
p-Chloro-m-cresol
N-nitrosodimethylamine
Endrin aldehyde
Chloroform
N-nitrosodiphenylamine
Heptachlor
2-Chlorophenol
N-nitrosodi-npropylamine
Heptachlor epoxide
1,2-Dichlorobenzene
Pentachlorophenol
alpha-BHC
1,3-Dichlorobenzene
Phenol
beta-BHC
1,4-Dichlorobenzene
Bis(2-ethylhexyl)
phthalate
gamma-BHC
3,3’-Dichlorobenzidine
Butyl benzyl phthalate
delta-BHC
1,1-Dichloroethylene
Di-n-butyl phthalate
Arochlor 1242
1,2-transDichloroethylene
Di-n-octyl phthalate
Arochlor 1254
2,4-Dichlorophenol
Diethyl phthalate
Arochlor 1221
1,2-Dichloropropane
Dimethyl phthalate
Arochlor 1232
1,3-Dichloropropylene
Benzo(a)anthracene
Arochlor 1248
2,4-Dimethylphenol
Council Introduction Draft Showing Changes From
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15 Benzo(a)pyrene
Arochlor 1260
2,4-Dinitrotoluene
Benzo(b)fluoranthene
Arochlor 1016
2,6-Dinitrotoluene
Benzo(k)fluoranthene
Toxaphene
1,2-Diphenylhydrazine
Chrysene
Fluoranthene
Ethylbenzene
Acenaphthylene
Anthracene
Chlordane (tech and
metabolites)
Total Suspended Solids or Suspended Solids. The total suspended matter that floats on the surface of, or is suspended in, water, wastewater, or other liquid, and that is removable by laboratory filtering.
[New Language]Transmit. When used in the context of an Electronic Document Receiving System, “transmit” means to successfully and accurately convey an electronic document so that it is received by the intended recipient in a format that can be processed by the electronic document receiving system.[End New Language] Unpolluted Water. Water to which no constituent has been added, either intentionally or accidentally, [New Language]that[End New Language] [Deleted]which[End Deleted] would render such water unacceptable to the City [Deleted]having jurisdiction thereof[End Deleted] for [Deleted]disposal[End Deleted] [New Language]release[End New Language] to storm or natural drainages or directly to surface waters.

User. Any person who discharges from any premises used, in whole or in part, and whether intermittently or continuously, for any commercial, industrial, manufacturing, or institutional purpose.
[New Language]Valid Electronic Signature. An electronic signature on an electronic document that has been created with an electronic signature device that the identified signatory is uniquely entitled to use for signing that document, where this device has not been compromised, and where the signatory is an individual who is authorized to sign the document by virtue of an individual's legal status and/or an individual's relationship to the entity on whose behalf the signature is executed.[End New Language] Waste. Sewage and any and all other waste substances, liquid, solid, gaseous or radioactive, associated with human habitation, or of human or animal origin, or from any producing, manufacturing or processing operation of whatever nature, including such waste placed within containers of whatever nature prior to, and for purposes of, disposal.

Council Introduction Draft Showing Changes From
Current Code 8/25/2026
16 Wastewater. Liquid and water-carried industrial wastes and sewage from residential dwellings, commercial buildings, industrial and manufacturing facilities, and institutions, whether treated or untreated, which contribute to the POTW.

Wastewater Constituents and Characteristics. The individual chemical, physical, bacteriological and radiological parameters, including volume and flow rate and such other parameters, that serve to define, classify or measure the contents, quality, quantity and strength of wastewater.

Wastewater Discharge Permit. A permit issued to a user that allows it to discharge wastewater to the community sewer and POTW.
[New Language]Water Resources Director. The person holding the position of Water Resources Director under Chapter 2.35 of this Code. Unless the context of usage otherwise requires, the term Water Resources Director includes any member of the Water Resources Department exercising authority delegated by the Water Resources Director to enforce or administer the provisions of this Title.[End New Language] Waters of the State. Any water, surface or underground, including saline waters within the boundaries of the State as defined in 40 CFR Part 230.3(s).

SECTION 2.

That Title 16, Chapter 16.02, Section 16.04.030, Subsection E. of the Santa Barbara Municipal Code is amended to read:

E. Optimum use of City facilities may require scheduling of discharge of wastewater during periods of low flow in the sewerage system as established by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director.

SECTION 3.

That Title 16, Chapter 16.04 of the Santa Barbara Municipal Code is amended to designate the Water Resources Director in place of the Public Works Director in various Sections or Subsections as follows:
(i) Subsection R of Section 16.04.010: Hazardous waste, which meets the definition under CCR Title 22, Article 11, except as specifically authorized by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director in a Wastewater Discharge Permit.
(ii) Section 16.04.080 Requirement for Interceptors.

Council Introduction Draft Showing Changes From
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17 A. Sand and oil interceptors. Sand and oil interceptors shall be provided when, in the opinion of the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director, they are necessary for the removal of sand or oil.

All interceptor units shall be of a type and capacity approved by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director and shall be located to be easily accessible for cleaning and inspection. Such interceptors shall be installed, utilized and properly maintained in continuous and efficient operation at all times and at the expense of the user.

B. Food establishments. Grease and oil interceptors shall be provided at all food establishments, or when the Health Officer of the County or the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director determines that they are necessary for the proper handling of liquid waste containing excessive amounts of grease or oil. No such interceptor shall be required for private dwellings. Grease and oil interceptors shall be installed, utilized and properly maintained in continuous and efficient operation at all times and at the expense of the user. All interceptors shall be of a type, capacity and construction approved in writing by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director. Interceptors shall be located so as to be readily and easily accessible for cleaning and inspection and shall be accessible at all times to personnel from the City and the Health Officer of the County for inspection and sampling. Food establishments which do not have a dishwashing machine or garbage grinder and which show that the discharge does not contribute grease or oil in excess of the limitations of this title may apply for a variance from the requirement to install an interceptor.
(iii) Section 16.04.090 Requirement for Installation of Sampling Box.

When directed by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director, food establishments shall install a sampling box of a size and type to be specified by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director.
(iv) Subsection D of Section 16.04.120: BMPs. The [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director may establish BMPs, to implement this section and the requirements of Chapter 16.04. The BMPs may be established by administrative guidelines or as conditions of issuance of a Waste Discharge Permit.

SECTION 4.

Council Introduction Draft Showing Changes From
Current Code 8/25/2026
18 That Title 16, Chapter 16.08 of the Santa Barbara Municipal Code is amended by the addition of Section 16.08.210 as follows:
[New Language]
Section 16.08.210 Electronic Reporting.

A. The City may establish and adopt an electronic document receiving system consistent with the Cross-Media Electronic Reporting Rule for the receipt and retention of electronic documents. The electronic document receiving system shall include systems and procedures for retention of a copy of record for each electronic document filed through the system. The electronic documents receiving system shall include a requirement for use of the system for the submission reports required by this Chapter or by a permit issued under this Title. The electronic documents receiving system shall include a requirement that a person required to file a report under Chapter or pursuant to a permit issued under this Title must execute an electronic signature agreement in a form established by the City before submitting an electronic document. An electronic document will not be accepted unless it contains a valid electronic signature.

B. The City shall provide any user existing on the date the electronic document receiving system becomes operative at least 90 days before the user must file electronic documents.

City may grant additional time upon request of the user and upon a showing by the user of good cause for the time extension. Nothing in this section excuses the filing of timely reports under this Chapter or any permit issued under this Title.

C. The obligations of users established by the electronic document receiving system are enforceable according to the provisions of Chapter 16.14 of this Code. [End New Language]
SECTION 5.

That Title 16, Chapter 16.08 of the Santa Barbara Municipal Code is amended to designate the Water Resources Director in place of the Public Works Director in various Sections or Subsections as follows:
(i) Subsection D of Section 16.08.040:

D. Monitoring waivers. The [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director of the City may waive monitoring for a user subject to a pretreatment standard to forego sampling for regulated pollutant if the user demonstrates through sampling and other technical methods that the pollutant is not present nor expected to be present in the discharge, or is only present at background Council Introduction Draft Showing Changes From
Current Code 8/25/2026
19 levels from intake water and without any increase in the pollutant due to the activities of the user. A monitoring waiver also may be authorized where a pollutant is determined to be present solely due to sanitary wastewater discharged from the facility provided that the sanitary wastewater is not regulated by an applicable pretreatment standard and otherwise includes no process wastewater. A monitoring waiver does not supersede certification processes and requirements established in categorical pretreatment standards, unless specifically stated in the categorical pretreatment standard. Monitoring waivers are subject to the following limitations:

1. The monitoring waiver is valid only for the duration of the effective period of the wastewater discharge permit, but in no case longer than five years. The user must submit a new request for the waiver before the waiver can be granted for each subsequent wastewater discharge permit.

2. When user's discharge includes process wastewater from multiple process the data provided in support of a request for waiver must include at least one sampling of the process wastewater that is representative of the combined wastewater from all processes.

3. The request for a waiver must be signed by the user or an authorized representative of the user.

4. The request for a waiver must be signed by the user or an authorized representative of the user.

5. Non-detectable sample results may be used to demonstrate that a pollutant is not present if the USEPA-approved method from 40 CFR Part 136 with the lowest minimum detection level for that pollutant was used in the analysis.

6. Waivers must be included in the user's wastewater discharge permit. The request, reasons, tests, and other evidence supporting the waiver must be maintained by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director for three years after expiration of the waiver.

7. The user subject to a waiver must certify on each report required by this section that there has been no increase in the pollutant in its wastestream due to activities of the user. The certification must be in the form required by Section 16.08.060 of this chapter.

8. If a pollutant for which a waiver has been granted is found to be present or is expected to be present because of changes that occur in the user's operations, the user must immediately notify the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director and comply with monitoring requirements. The Council Introduction Draft Showing Changes From
Current Code 8/25/2026
20 [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director may revoke, modify, or continue a waiver following receipt of the written notification.
(iii) Subsection B of Section 16.08.060:

B. Annual certification for non-significant categorical industrial users. A facility determined by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director to be a non-significant categorical industrial user must annually submit the following certification statement signed by the user or the user's authorized representative. This certification must accompany an alternative report required by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director:
"Based on my inquiry of the person or persons directly responsible for managing compliance with the categorical Pretreatment Standards under 40 CFR _______ , I certify, to the best of my knowledge and belief, that during the period from ______ to ______ [month, days, year]:
(1) The facility described as _______[facility name] met the definition of a Non-Significant Categorical Industrial User as described in Section 16.02.040 of the Santa Barbara Municipal Code;
(2) The facility complied with all applicable Pretreatment Standards and requirements during this reporting period; and
(3) The facility never discharged more than 100 gallons of total categorical wastewater on any given day during this reporting period.

This compliance certification is based on the information stated in this report." (iv) Section 16.08.100:

16.08.100 Notification of Potential Problems.

A. Required notice of discharge. In case of any discharge, including, but not limited to, accidental discharges, discharges of a non-routine, episodic nature, a noncustomary batch discharge, a slug discharge or slug load, that might cause potential problems for the POTW, the user shall immediately telephone and notify the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director of the incident. This notification shall include the location of the discharge, type of waste, concentration, and volume, if known, and corrective actions taken by the user.

Council Introduction Draft Showing Changes From
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21 B. Report on discharge. Within five days following such discharge, the user shall, unless waived by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director, submit a detailed written report describing the cause(s) of the discharge and measures to be taken by the user to prevent similar future occurrences. Such notification shall not relieve the user of any expense, loss, damage, or other liability that might be incurred as the result of damage to the POTW, natural resources, or any other damage to person or property; nor shall such notification relieve the user of any fines, penalties, or other liability which may be imposed pursuant this title.

C. Notification protocol. A notice shall be permanently posted on the user's bulletin board or other prominent place advising employees who to call in the event of a discharge described in subsection A of this section. Employers shall ensure that all employees who cause such a discharge to occur are advised of the emergency notification procedure.

D. Notice of slug discharge. A user is required to notify the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director immediately of any changes at its facility affecting the potential for a slug discharge. (v) Section 16.08.120:

16.08.120 Wate Discharge Permits.
§ 16.08.120Wastewater Discharge Permits.

A. Permit administration. All permits under this title shall be administered by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director.

B. Mandatory permits. Users proposing to connect or to discharge into a community sewer must obtain a Wastewater Discharge Permit prior to discharge:

1. Tier I Significant Industrial User - Any user who meets any of the following conditions:
a. Has a waste discharge subject to categorical pretreatment standards;
b. Has an average discharge flow of 25,000 gallons per day or more of process wastewater to the POTW, excluding sanitary, non-contact cooling water, and boiler blowdown wastewater;
Council Introduction Draft Showing Changes From
Current Code 8/25/2026
22 c. Contributes a process waste stream that makes up five percent or more of the average dry weather hydraulic or organic capacity of the POTW; or d. Is designated by the City on the basis that the user:
i. Has a reasonable potential, either individually or in combination with other contributing industries, for adversely affecting the POTW operation or upon the quality of effluent from the POTW;
ii. May cause or threaten to cause the City to violate its NPDES permit;
iii. Has reasonable potential to violate any pretreatment standard; or
iv. Has in its waste discharge a toxic pollutant.

2. Tier II Non-Significant Industrial User - any user who meets any of the following criteria:
a. Is not required to obtain a Tier I Permit;
b. Is a non-significant categorical industrial user;
c. Has discharge characteristics greater than typical domestic wastewater;
d. Discharges industrial or commercial wastewater which may have potential effects on the City's POTW; or
e. Has a reasonable potential to violate any local limit, pretreatment standard, or pretreatment requirement.

3. Tier III Groundwater Dischargers - any user who discharges groundwater to the POTW.

C. Optional permits. The [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director may issue a Wastewater Discharge Permit upon application and in accordance with the terms of this title, for any of the following kinds of users:

1. A user who has elected that user charges and fees be based on an estimation of wastewater flow;
Council Introduction Draft Showing Changes From
Current Code 8/25/2026
23 2. A user who has installed or been required to install equipment designed or intended to reduce wastewater strength; or

3. A user for whom the Public Works Director has determined that monitoring is required to ensure that discharges comply with all applicable regulations.

D. Permit application. Prospective or existing users seeking a Wastewater Discharge Permit shall complete and file with the City an application in the form prescribed by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director, accompanied by the applicable fees. The applicant shall be required to submit, in units and terms appropriate for evaluation, the following information:

1. Identifying Information.
a. The name and address of the facility, including the name of the operator and owner.
b. Contact information, description of activities, facilities, and plant production processes on the premises.

2. Environmental Permits. A list of any environmental control permits held by or for the facility.

3. Description of operations, including all of the information listed below:
a. A brief description of the nature, average rate of production (including each product produced by type, amount, processes, and rate of production), and SIC number(s) of the operation(s) carried out by such user. This description should include a schematic process diagram which indicates the points of discharge to the POTW from regulated processes.
b. Types of wastes generated and a list of all raw materials and chemicals used or stored at the facility which are, or could accidentally or intentionally be, discharged to the POTW.
c. Number and type of employees, hours of operation, and proposed or actual hours of operation.
d. Type and amount of raw materials processed (average and maximum per day).
e. Site plans, floor plans, mechanical and plumbing plans, and details to show all sewers, floor drains, and appurtenances by size, location, and elevation, and all points of discharge.

Council Introduction Draft Showing Changes From
Current Code 8/25/2026
24 4. Time and duration of discharges.

5. The location of monitoring all wastes covered by the Wastewater Discharge Permit.

6. Flow Measurement. Information showing the measured average daily and maximum daily flow, in gallons per day, to the POTW from regulated process streams and other streams, as necessary, to allow use of the combined wastestream formula (40 CFR Part 403.6(e)). Flow rates should also include the 30-minute peak wastewater flow rate and monthly and seasonal variations if they exist.

7. Measurement of Pollutants.
a. The user shall identify the categorical pretreatment standards applicable to each regulated process and any new categorically-regulated processes for existing sources.
b. The user shall submit the results of sampling and analysis identifying the nature and concentration (or mass, where required by the City) of regulated pollutants in the discharge from each regulated process. c. Instantaneous, daily maximum, and long-term average
concentrations (or mass, where required) shall be reported. d. The sample shall be representative of daily operations. In cases where the standard requires compliance with a BMP or pollution prevention alternative, the user shall submit documentation as required by the City or the applicable Standards to determine compliance with the standard.

8. A request, if any, along with all supporting information, for a monitoring waiver (or renewal of an approved monitoring waiver) pursuant to Section

16.08.040 of this chapter.

9. Any other information deemed by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director to be necessary to evaluate the permit application.

10. Application Signatories and Certifications. All Wastewater Discharge Permit applications must be certified in accordance with Section 16.08.060 of this chapter and signed by an authorized representative of the user.

11. A facility determined to be a non-significant categorical industrial user by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Council Introduction Draft Showing Changes From
Current Code 8/25/2026
25 Language] Director must annually submit the certification statement specified in Section

16.08.060.B.

E. [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director permit review and determination. The [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director will evaluate the data furnished by the user. After evaluation and acceptance of the data furnished, the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director may issue a Wastewater Discharge Permit subject to terms and conditions provided herein. The [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director may deny issuance of a permit where the discharge alone, or in combination with other discharges, has the potential to cause:

1. Interference;

2. Pass through;

3. Insufficient capacity; or

4. Risk to health and safety.

F. Permit conditions. Wastewater Discharge Permits shall be subject to all applicable regulations, user charges and fees established by the City. The conditions of Wastewater Discharge Permits shall be enforced by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director in accordance with all applicable regulations. Wastewater Discharge Permits must contain the following:

1. A statement that indicates the Wastewater Discharge Permit issuance date, expiration date, and effective date.

2. A statement that the Wastewater Discharge Permit is nontransferable.

3. Effluent limits, including BMPs, based on applicable pretreatment standards.

4. Self-monitoring, sampling, reporting, notification, and recordkeeping requirements. These requirements shall include an identification of pollutants (or BMPs) to be monitored, sampling location, sampling frequency, and sample type based on Federal, State, and local law.

5. A statement of applicable civil and criminal penalties for violation of pretreatment standards and requirements, and any applicable compliance schedule. Such Council Introduction Draft Showing Changes From
Current Code 8/25/2026
26 schedule may not extend the time for compliance beyond that required by applicable Federal, State, or local law.

6. Requirements to control slug discharge, if determined by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director to be necessary.

7. Compliance with the Wastewater Discharge Permit does not relieve the user of responsibility for compliance with all applicable Federal and State pretreatment standards, including those which become effective during the term of the Wastewater Discharge Permit.

8. Wastewater Discharge Permits may include any of the following:
a. Limits on rate and time of discharge and/or requirements for flow regulations and equalization;
b. Requirements for the installation of pretreatment technology, pollution control, or construction of appropriate containment devices designed to reduce, eliminate, or prevent the introduction of pollutants into the POTW; c. Requirements for the development and implementation of spill control plans or other special conditions, including BMPs necessary to adequately prevent accidental, unanticipated, or non-routine discharges;
d. Development and implementation of waste minimization plans to reduce the amount of pollutants discharged to the POTW; e. Requirements for installation and maintenance of inspection and sampling facilities and equipment, including flow measurement devices; f. Statements of applicable administrative, civil, and criminal penalties for violation of pretreatment standards and requirements, and any applicable compliance schedule. Such schedule may not extend the time for compliance beyond that requirement by applicable Federal, State, or local law; and g. Other conditions as deemed appropriate by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director to ensure compliance with this title, and State and Federal laws, rules, and regulations.

G. Duration of permits. Permits shall be issued for a specified time period, not to exceed five consecutive years from the effective date of the permit. If the user wants to continue discharge after the expiration of the Wastewater Discharge Permit, a Wastewater Council Introduction Draft Showing Changes From
Current Code 8/25/2026
27 Discharge Permit application must be submitted a minimum of 45 days prior to the expiration date of the Wastewater Discharge Permit. If the user submits a completed Wastewater Discharge Permit application and, through no fault of the user, a new Wastewater Discharge Permit is not issued prior to the expiration of the existing Wastewater Discharge Permit, the existing Wastewater Discharge Permit will remain in effect until the City reissues or denies, as the case may be, a new Wastewater Discharge Permit. All Wastewater Discharge Permits issued to a user are void upon issuance of a new Wastewater Discharge Permit to that user.

H. Permit fees. Wastewater Discharge Permit fees shall be set by a resolution of the City Council and shall reflect all costs associated with administering the permit.

I. Permit modifications. The terms and conditions of the Wastewater Discharge Permit are subject to modification and change by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director prior to the expiration of the permit. The [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director shall attempt to inform the user of modifications to a Wastewater Discharge Permit at least 30 days prior to the modification effective date. Unless the circumstances require otherwise as determined by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director, modifications or new conditions to a Wastewater Discharge Permit shall be issued in writing and shall include a reasonable time schedule for compliance. A Wastewater Discharge Permit may be modified for any of the following reasons:

1. To incorporate any new or revised Federal, State, or local pretreatment standards or requirements.

2. To address significant alterations or additions to the user's operations, processes, or wastewater volume or character since the time of permit issuance.

3. A change in the POTW that requires either a temporary or permanent reduction or elimination of an authorized discharge.

4. Information indicating that the permitted user poses a threat to the City's POTW, personnel, or receiving waters.

5. Violation of any terms or conditions of the permit.

6. Misrepresentation or failure to fully disclose all relevant facts in the permit application or in any required reporting.

Council Introduction Draft Showing Changes From
Current Code 8/25/2026
28 7. Revision of, or a grant of variance from, any categorical pretreatment standard.

8. To correct typographical or other errors in the permit.

J. No permit transfer. Wastewater Discharge Permits are issued to a specific user for a specific operation. A Wastewater Discharge Permit shall not be reassigned, transferred or sold to a new or different owner, user, or premises, or to a new or changed operation at or on any permitted or previously permitted premises. Wastewater Discharge Permits shall be void upon cessation of operations or transfer to a different user.

K. Permit revocation. Any user who violates any of the following conditions of the Wastewater Discharge Permit or of this title, or applicable State and Federal regulations, is subject to having its permit revoked:

1. Failure to provide prior notification to the Public Works Director of changed conditions pursuant to Section 16.08.070 of this chapter;

2. Misrepresentation or failure to fully disclose all relevant facts in the Wastewater Discharge Permit application;

3. Falsifying self-monitoring reports and certification statements;

4. Tampering with monitoring equipment;

5. Refusing to allow the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director timely access to the facility premises and/or records;

6. Failure to meet effluent limitations;

7. Failure to pay fines;

8. Failure to pay sewer charges;

9. Failure to meet compliance schedules;

10. Information indicating that the permitted user poses a threat to the City's POTW, personnel, or receiving waters; or

11. Violation of any pretreatment standard or requirement, or any terms of the Wastewater Discharge Permit or this title.
(vi) Section 16.08.130:

16.08.130 Monitoring Facilities and Sampling Procedures.

Council Introduction Draft Showing Changes From
Current Code 8/25/2026
29 A. Installation of monitoring facilities. The [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director shall require the user to construct, at its own expense, monitoring facilities adequate to allow inspection and sampling of the sewer or internal drainage systems at, upon, or in the user's premises. The [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director may also require the construction of flow measurement facilities and sampling or metering equipment, and may specify which facilities and equipment shall be provided, installed, and operated at the user's expense. The monitoring facility should normally be situated on the user's premises, but the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director may, when such a location would be impractical or would cause undue hardship on the user, allow the facility to be constructed in the public street or sidewalk area and located so that it will not be obstructed by landscaping or parked vehicles; provided, however, that the user shall be required to comply with all applicable encroachment and other land use requirements.

B. Access to monitoring facilities. If the monitoring facility is inside or on the user's premises, User shall allow ready access for City personnel. Any change to the accessibility of the user's premises, such as a new lock or combination, must be provided to the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director within 24 hours following the change.

C. Obstruction to access. Any temporary or permanent obstruction to safe and easy access to the facility to be inspected and/or sampled shall be promptly removed by the user at the request of the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director and shall not be replaced. The costs of clearing such access shall be paid by the user. All costs of removing temporary or permanent obstructions shall be paid by the user.

D. Construction of monitoring facilities. Whether constructed on public or private property, the sampling and monitoring facilities shall be provided in accordance with the City's requirements and all applicable construction standards and specifications.

Construction shall be completed within 90 days following written notification by the City unless a time extension is otherwise granted by the City.

E. Sampling procedures.

1. Except as provided in subsections E.2 and 3 of this section, the user must collect wastewater samples using 24-hour flow-proportional composite sampling techniques, unless time-proportional composite sampling or grab sampling is authorized by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Council Introduction Draft Showing Changes From
Current Code 8/25/2026
30 Language] Director. Where time-proportional composite sampling or grab sampling is authorized by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director, the samples must be representative of the discharge. Using protocols (including appropriate preservation) specified in 40 CFR Part 136 and appropriate EPA guidance, multiple grab samples collected during a 24-hour period may be composited prior to the analysis as follows: for cyanide, total phenols, and sulfides, the samples may be composited in the laboratory or in the field; for volatile organics and oil and grease, the samples may be composited in the laboratory. Composite samples for other parameters unaffected by the compositing procedures as documented in approved EPA methodologies may be authorized by the City, as appropriate. In addition, grab samples may be required to show compliance with instantaneous limits.

2. Samples for oil and grease, temperature, pH, cyanide, total phenols, sulfides, and volatile organic compounds must be obtained using grab collection techniques.

Actual sample type requirements shall be included in the Wastewater Discharge Permit.

3. For sampling required in support of the reports required in Sections

16.08.010 and 16.08.030 of this chapter, a minimum of four grab samples must be used for pH, cyanide, total phenols, oil and grease, sulfide, and volatile organic compounds, for facilities for which historical sampling data do not exist; for facilities for which historical sampling data are available, the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director may authorize fewer grab samples.

4. For reports required by Section 16.08.040 of this title, the user is required to collect the number of grab samples necessary to assess and assure compliance with applicable pretreatment standards and requirements. (vii) Section 16.08.160:

16.08.160 Pretreatment.

Users shall meet limitations established herein before discharging to any community sewer.

Any facilities required to pretreat wastewater shall be provided and maintained and continuously operated at the user's expense. Prior to construction of any facility subject to regulation under the provisions of this title, detailed plans showing pretreatment facilities and operating procedures shall be submitted to the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director for review and approval , and shall be approved by the City before construction of the facility. The review of such plans and operating procedures will in no way relieve the user of responsibility for modifying the facility as necessary to produce a wastewater that meets the provisions of this title. Any subsequent changes in the pretreatment facilities or operation thereof shall be reported to Council Introduction Draft Showing Changes From
Current Code 8/25/2026
31 and approved by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director prior to implementation. (viii) Section 16.08.180:

16.08.180 Confidential Information.

Information and data regarding a user obtained from reports, surveys, Wastewater Discharge Permit applications, Wastewater Discharge Permits, monitoring programs, and from the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director's inspection and sampling activities shall be made available to the public without restriction unless the user specifically requests in writing, and is able to demonstrate to the satisfaction of the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director, that the release of such information would divulge information, processes, or methods of production entitled to protection as trade secrets under applicable State law. Any such request must be made at the time of submission of the information or data. When sufficiently demonstrated by the user furnishing a report that such information should be held confidential, the portions of a report which might disclose trade secrets or secret processes shall not be made available for inspection by the public, but shall be made available immediately upon request to governmental agencies for uses related to the NPDES program or pretreatment program and in enforcement proceedings involving the person furnishing the report. Notwithstanding the above, wastewater constituents and characteristics and other effluent data as defined in 40 CFR Part 2.302 shall not be recognized as confidential information and shall be made available to the public without restriction.
(ix) Section 16.08.200:

16.08.200 Special Agreements.

Special agreements and arrangements between the City and any person may be established when, in the opinion of the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director, unusual or extraordinary circumstances compel special terms and conditions. However, in no instance shall special agreements relieve a person from compliance with Categorical Pretreatment Limits or the National Pretreatment Regulations found in 40 CFR Part 403.

SECTION 6.

That Title 16, Chapter 16.10, Section 16.10.010 of the Santa Barbara Municipal Code is amended to read as follows:

Council Introduction Draft Showing Changes From
Current Code 8/25/2026
32 16.10.010 Determination of Components.

In order to ensure compliance with the local limitations on wastewater strength in Section

16.04.120 of this title, a determination of components contained in Sewage, liquid waste, and industrial waste discharges will be conducted by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director. Monitoring will be performed by means of a sampling device approved by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director. Sampling, resampling, and laboratory work performed by the City for monitoring will be performed at the expense of the user.

SECTION 5.

That Title 16, Chapter 16.12 of the Santa Barbara Municipal Code is amended to designate the Water Resources Director in place of the Public Works Director in various Sections or Subsections as follows
(i) Section 16.12.010:

16.12.010 Enforcement Response Plan.

The [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director shall investigate instances of noncompliance with any provision of this title, or with any pretreatment standards and requirements, as indicated in the reports and notices required under 40 CFR Part 403.12, or indicated by analysis, inspection, and surveillance activities performed by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director. The City shall conduct enforcement proceedings in accordance with its Enforcement Response Plan. The Enforcement Response Plan, adopted by resolution of the City Council, is incorporated herein by reference and may be amended from time to time to ensure consistent application of the provisions of this title and Federal and State regulations. (ii) Subdivision A of Section 16.12.020:

A. Notification of discharge. Any user who causes or permits a discharge which violates any applicable law, regulation, or the Wastewater Discharge Permit shall immediately notify the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director. Notification by the user as required in this section shall not, however, relieve the user of liability for any expense, loss or damage to any community sewer or the POTW which occurs, directly or indirectly, as a result of the Council Introduction Draft Showing Changes From
Current Code 8/25/2026
33 discharge, nor shall notification by the user relieve the user of liability for any expense, fee or fine incurred by the City as a result of the discharge. No later than 14 days after the discharge, the user shall deliver to the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director a detailed written statement describing the cause(s) of the discharge and the measures taken and/or to be taken to prevent similar discharges.
(iii) Section 16.12.030:

16.12.030 Notice of Violation.

When the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director finds that any user has violated, or continues to violate, a provision of this title, a Wastewater Discharge Permit, an order issued hereunder, a pretreatment standard or requirement, or any applicable local, State or Federal law, the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director may serve upon such user a written Notice of Violation. Within 14 calendar days of the date of the Notice of Violation, user shall submit to the City a written explanation of the violation and a plan for the satisfactory correction and prevention thereof, which shall include specific required actions to be taken. Submission of this plan in no way relieves the user of liability for any violations occurring before or after the date of the notice of violation. Nothing in this section limits the authority of the City to take emergency action, or any other enforcement action, without issuing a Notice of Violation.
(iv) Section 16.12.040:

16.12.040 Cease and Desist Orders.

When the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director finds that a user has violated, or continues to violate, any provision of this title, a Wastewater Discharge Permit, an order issued hereunder, or any other pretreatment standards or requirement, or that the user's past violations are likely to reoccur, the City may issue an order to the user directing it to cease and desist all violations and directing the user to immediately comply with all requirements of this title and applicable local, State and Federal law. Nothing in this section limits the authority of the City to take emergency action, or any other enforcement action, without issuing a Cease and Desist Order.
(v) Section 16.12.050:

16.12.050 Submission of Time Schedule.

Council Introduction Draft Showing Changes From
Current Code 8/25/2026
34 A. When the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director finds that a discharge of wastewater has been taking place in violation of prohibitions or limitations prescribed in this title, wastewater source control requirements, effluent limitations or pretreatment standards, or the provisions of a Wastewater Discharge Permit, the City may require the user to submit for approval, with such modifications as it deems necessary, a detailed time schedule of specific actions which the user shall take in order to prevent or correct a violation of any of these requirements.

B. If the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director determines that a discharge has occurred or is occurring, and that the discharge violates any applicable regulation or Wastewater Discharge Permit, the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director may require the person who caused or permitted the discharge to submit to the City a detailed time schedule of specific actions which the person shall take in order to prevent or correct any violation of any applicable regulation or Wastewater Discharge Permit.
(vi) Section 16.12.060 Appeals.

16.12.060 Appeals.

A. Request for reconsideration. Any user, permit applicant, permit holder, or person affected by any decision, action or determination, including the assessment of fines and civil penalties, Cease and Desist Orders, revocation of a permit, and other administrative remedies, made by the Public Work Water Resources Director, interpreting or implementing the provisions of this title or in any permit issued herein, may file with the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director a written request for reconsideration within 15 calendar days of such decision, action, or determination, setting forth in detail the facts supporting the user's or person's request for reconsideration.

B. [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director decision remains in effect pending appeal. The decision, action or determination of the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director shall remain in effect during such period of reconsideration and during the period of any appeal or judicial review under the provisions of this code.

C. Appeal to City Council. A decision, action or determination of the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director, after reconsideration is granted or denied, may be appealed to the City Council Council Introduction Draft Showing Changes From
Current Code 8/25/2026
35 under the provisions of Chapter 1.30 of this code, except that, as to decisions to assess administrative penalties in accordance with Chapter 16.12 herein, the time limit for judicial review that is to be found in California Code of Regulations Section 54740.6, as may be amended from time to time, shall control to the extent allowed by law. (vii) Subsection C of Section 16.12.070:

C. Bypass.

1. A user may allow a bypass to occur which does not cause pretreatment standards or requirements to be violated, but only if it also is essential for maintenance to assure efficient operation. A bypass meeting this limitation is not subject to the provisions of paragraphs 2 or 3 below.

2. Bypass Notifications.
a. If a user knows in advance of the need for a bypass, it shall submit prior notice to the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director at least 10 days before the date of the bypass, if possible.
b. A user shall submit oral notice to the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director of an unanticipated bypass that exceeds applicable pretreatment standards within 24 hours from the time it becomes aware of the bypass. A written submission shall also be provided within five calendar days of the time that the user becomes aware of the bypass. The written submission shall contain: a description of the bypass and its cause; the duration of the bypass, including exact dates and times, and, if the bypass has not been corrected, the anticipated time it is expected to continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence of the bypass. The [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director may waive the written report on a case-by-case basis if the oral report has been received within 24 hours.

3. Prohibited Bypass.
a. Bypass is prohibited and the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director may take an enforcement action against a user for a bypass, unless all of the following are met:
i. Bypass is unavoidable to prevent loss of life, personal injury or severe property damage, which means substantial physical damage to property, damage to the treatment facilities which causes them to be inoperable, or substantial and Council Introduction Draft Showing Changes From
Current Code 8/25/2026
36 permanent loss of natural resources which can reasonably be expected to occur in the absence of a bypass. Severe property damage does not mean economic loss caused by delays in production;
ii. There was no feasible alternative to the bypass, such as the use of auxiliary treatment facilities, retention of untreated wastes, or maintenance during normal periods of equipment downtime. This condition is not satisfied if adequate backup equipment should have been installed in the exercise of reasonable engineering judgment to prevent a bypass which occurred during normal periods of equipment downtime or preventative maintenance; and
iii. The user submitted notices as required by paragraph 2 of this subsection.
b. The [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director may approve an anticipated bypass after considering its adverse effects if the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director determines that the bypass will meet the three conditions listed in paragraphs (a)(i) through (iii) above.

SECTION 6.

That Title 16, Chapter 16.14 of the Santa Barbara Municipal Code is amended to designate the Water Resources Director in place of the Public Works Director in various Sections or Subsections as follows:
(i) Section 16.14.010:

16.14.010 Public Nuisance.

Discharges of wastewater which in any way violate this title or any permit or order issued by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director pursuant to this title are a public nuisance and shall be corrected or abated as directed by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director.
(ii) Section 16.14.020:

16.14.020 Injunction.

When the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director finds that a user has violated, or continues to violate, any provision of this title, a Wastewater Discharge Permit, an order issued hereunder, or any other Council Introduction Draft Showing Changes From
Current Code 8/25/2026
37 pretreatment standard or requirement, the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director may petition the Superior Court through the City Attorney for the issuance of a temporary or permanent injunction, as appropriate, which restrains or compels the specific performance of the Wastewater Discharge Permit, order, or other requirement imposed by this order on activities of the user.

The [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director may also seek such other action as appropriate for legal and/or equitable relief, including a requirement for the user to conduct environmental remediation. A petition for injunctive relief shall not be a bar against, or a prerequisite for, taking any other action against a user.
(iii) Section 16.14.050:

16.14.050 Administrative Civil Penalties.

Any provision of this title may be enforced by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director acting through use of administrative procedures and imposing administrative civil penalties for violations, as follows:

A. The [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director may determine violations of this title by administrative hearing and, based upon the results of that hearing, order administrative civil penalty(ies) to be assessed against the party responsible for the violation in accord with the provisions of this title and California Code of Regulations Section 54740.5, as may be amended from time to time.

B. In addition to general enforcement through administrative civil penalties as authorized herein, the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director is designated to be the hearing officer for administrative enforcement authorized pursuant to California Code of Regulations Sections 54740.5 and 54740.6.

C. Hearing, waiver of hearing, orders, reconsideration, appeal to the City Council, judicial review, delinquencies, lien, and confirmation regarding administrative remedies shall be as provided in accordance with California Code of Regulations Sections 54740.5 and 54740.6, as may be amended from time to time, and as provided in this title.

D. In determining the amount of civil liability, the hearing officer or board may take into account all relevant circumstances, including, but not limited to, the extent of harm caused by the violation, the nature and persistence of the violation, any economic benefit Council Introduction Draft Showing Changes From
Current Code 8/25/2026
38 gained through the user's violation, the length of time over which the violation occurs and corrective actions taken by the user.

E. Civil penalties may be imposed by the City as follows:

1. In an amount which shall not exceed $2,000.00 for each day for failing or refusing to furnish technical or monitoring reports.

2. In an amount which shall not exceed $3,000.00 for each day for failing or refusing to timely comply with any compliance schedule established by the City.

3. In an amount which shall not exceed $5,000.00 per violation for each day for discharges in violation of any waste discharge limitation, permit condition, or requirement issued, reissued, or adopted by the local agency.

4. In an amount which does not exceed $10.00 per gallon for discharges in violation of any suspension, cease and desist order or other orders, or prohibition issued, reissued, or adopted by a City.

5. The amount of any civil penalties imposed under this section which have remained delinquent for a period of 60 days shall constitute a lien against the real property of the discharger from which the discharge originated resulting in the imposition of the civil penalty. The lien provided herein shall have no force and effect until recorded with the county recorder and when recorded shall have the force and effect and priority of a judgment lien and continue for 10 years from the time of recording unless sooner released, and shall be renewable in accordance with the provisions of law.

6. All moneys collected under this section shall be deposited in a special account of the City and shall be made available for the monitoring, treatment, and control of discharges into the City's community sewer or POTW or for other mitigation measures.

7. Unless appealed, orders setting administrative civil penalties shall become effective and final upon issuance thereof, and payment shall be made within 30 days.

Copies of these orders shall be served by personal service or by registered mail upon the party served with the administrative complaint and upon other persons who appeared at the hearing and requested a copy.

8. The City may, at its option, elect to petition the Superior Court to confirm any order establishing civil penalties and enter judgment in conformity therewith in accordance with the provisions of law.

F. Except as provided in this section, remedies under this section are in addition to, and do not supersede or limit the use of, any and all other remedies, civil or criminal, Council Introduction Draft Showing Changes From
Current Code 8/25/2026
39 available under this title and under the statutes and regulations of the State of California and the United States of America. No penalties shall be recoverable under this section for any violation for which civil liability is recovered under Section 16.14.060 or California Code of Regulations Section 54740.

G. Administrative remedies, fines and other civil penalties imposed pursuant to the provisions of this title may, at the sole discretion of the Public Works Water Resouces Director, be added to and collected with the applicable user's sewer service charges.

H. Except as provided in this section, issuance of an administrative penalty shall not be a bar against, or a prerequisite for, taking any other action against the user. (iv) Section 16.14.090

16.14.090 Emergency Suspension.

The [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director may immediately suspend a user's discharge after informal notice to the user, whenever such suspension is necessary to stop an actual or threatened discharge which reasonably appears to present or cause an imminent or substantial endangerment to the health or welfare of persons. The [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director may also immediately suspend a user's discharge, after notice and opportunity to respond, that threatens to interfere with the operation of the community sewer or POTW, or which presents, or may present, an endangerment to the environment. Nothing in this section shall be interpreted as requiring a hearing prior to any emergency suspension under this title.

A. Notification of suspension. Any user notified of a suspension of its discharge shall immediately stop or eliminate its discharge. In the event of a user's failure to immediately voluntarily comply with the suspension order, the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director may take such steps as deemed necessary, including immediate severance of the sewer connection or turning off water supply, to prevent or minimize damage to the community sewer or POTW, its receiving stream, danger to any individuals, or to prevent continued violation of this title or Wastewater Discharge Permit. The [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director may allow the user to recommence its discharge when the user has demonstrated to the satisfaction of the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director that the violation has passed, unless termination proceedings in accordance with Section 16.14.100 of this chapter are initiated against the user.

Council Introduction Draft Showing Changes From
Current Code 8/25/2026
40 B. User responsibility. A user responsible, in whole or in part, for any discharge presenting imminent danger shall submit a detailed written statement describing the causes of the harmful contribution and the measures taken to prevent any future occurrence, to the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director prior to the date of any termination hearing under Section 16.14.100 of this chapter.

C. Cost to suspend or mitigate. The user is responsible for any costs incurred to suspend or mitigate the impact of the discharge. Such costs may be added to the user's sewer service charges.

SECTION 7.

That Title 16, Chapter 16.14, Section 16.14.040 of the Santa Barbara Municipal Code is amended to read:

16.14.040 Published Notices of Significant Violators.

The City will publish annually, in a newspaper of general circulation that provides meaningful public notice within the jurisdiction served by the City, a list of the users which, at any time during the previous 12 months, were in significant noncompliance with [Deleted]applicable[End Deleted] pretreatment standards and requirements [New Language]applicable to the user[End New Language]. [Deleted]The term "significant noncompliance," as defined in Section 16.02.040.EEE of this title, shall be applicable to all Tier I users. This term also shall apply to any other users that violate Sections

16.02.040.EEE.3, 4, or 8 of this title, and those users will also be included in this list.[End Deleted]
SECTION 8.

That Title 16, Chapter 16.14, Section 16.14.100 of the Santa Barbara Municipal Code is amended to read:

16.14.100 Termination of Discharge.
[New Language]A. [End New Language]Any user who violates any of the following conditions is subject to discharge termination:
[Deleted]1[End Deleted][New Language]A[End New Language].

Violation of Wastewater Discharge Permit conditions.
[Deleted]2[End Deleted][New Language]B[End New Language].

Failure to accurately report wastewater constituents and characteristics of its discharge.

Council Introduction Draft Showing Changes From
Current Code 8/25/2026
41 [Deleted]3[End Deleted][New Language]C[End New Language].

Failure to report significant changes in operations or wastewater constituents, and characteristics prior to discharge.
[Deleted]4[End Deleted][New Language]D[End New Language].

Refusal of reasonable access to the user's premises for the purpose of inspection, monitoring, or sampling.
[Deleted]5[End Deleted][New Language]E[End New Language].

Violation of the pretreatment standards in Chapter 16.04 of this title.

B. Such user shall be notified of the proposed termination of its discharge and be offered an opportunity to show why the proposed action should not be taken. Termination of the user's discharge by the [Deleted]Public Works[End Deleted] [New Language]Water Resources[End New Language] Director shall not be a bar, or a prerequisite for, taking any other action against the user.

CITY OF SANTA BARBARA
Council Agenda Report
Agenda Date: August 25, 2026
To: Mayor and Councilmembers
From: Finance Department
Subject: Amend Agreement with OpenGov, Inc., Extending Budget and Planning (On-Line Digital Budget Book) Services for Two Years [Agreement] Recommendation:

That Council approve an Amendment to Professional Services Contract 28,451 with OpenGov, Inc., for Budget and Planning (Online Digital Budget Book), extending services through July 31, 2028.

Discussion
In February 2022, staff recommended transitioning from the printed budget document to an interactive, digital budget book, to present the budget in a more understandable way, broaden citizen engagement, and strengthen public trust. The platform, Budget and Planning, is a product of OpenGov, Inc., whom the City contracts with for their transparency platform as well as Asset Management (formerly Cartegraph). The amendment will also align contract dates to coincide for better contract negotiation.

Implementation of this platform has allowed for more centralized processes with departments during the budget development process as well as quarterly reporting and Oversight Committee updates, as it integrates with the City’s current financial management system. The City also plans to replace other, outdated databases with the platform, such as the Capital Improvement Plan, replacing static reports with interactive, virtual reports that members of the public will have greater access to view and learn about various City functions.

Budget/Financial Information
The amendment is for a two-year extension of the current contract. The Fiscal Year 2027 Adopted Budget includes funding for the first year of this two-year extension. Funding for this agreement is currently available for the first year of the two-year contract; subject to the City Agenda Item No. 4
Council Agenda Report
Amend Agreement with OpenGov, Inc. Extending Budget and Planning (On-Line Digital Budget Book) Services for Two Years [Agreement]

Council’s approval of the annual budget, the City intends to request funding for the second year in Fiscal Year 2028. If funding is not available for the second year, the contract can be canceled.

Contract 28,451 Start Date End Date Annual Fee
First year extension
(included in adopted budget) 08/25/2026 07/31/2027 $174,967.60 Second year extension
(request with FY2028 budget) 08/01/2027 07/31/2028 $197,373.12 Total increase with amendment $372,340.72
Current not to exceed amount $594,654.03
Total new not to exceed amount
(5 year total) $966,944.75
A copy of the contract/agreement may be requested from the Finance Department for public review by emailing [email protected].

AB 339 Compliance: staff have completed all applicable employee organization notification requirements pursuant to Government Code Section 3504.1.

Sustainability Impact
Continuation of this project is in line with the greater sustainability and resilience goals of the City through leveraging technology to disseminate information to a broad audience and minimizing the use of papers and other materials.

Prepared by: Natalija Glusac, Budget Manager
Submitted by: Keith DeMartini, Finance Director
Approved by: Kelly McAdoo, City Administrator

CITY OF SANTA BARBARA
Council Agenda Report
Agenda Date: August 25, 2026
To: Mayor and Councilmembers
From: Police Department
Subject: Nonrenewal of Flock Contract
Recommendation
That Council receive a report regarding the nonrenewal of the Flock Camera system and the staff recommended alternative to this system consistent with Council direction earlier this year.

Discussion
Per Council direction earlier this year, staff took steps to evaluate nonrenewal of the Flock Camera system and to recommend alternatives to this system that better protect personal data and prevent sharing of information across police agencies. This report presents an overview of the Flock system and the staff recommended alternative, Verkada. In July, the City Administrator provided notice of contract nonrenewal to Flock and staff has since identified an alternative system consistent with Council direction.

The Santa Barbara Police Department has utilized twelve (12) Flock Safety Automated License Plate Recognition cameras since late 2023 as an investigative tool to assist in solving crimes, locating stolen vehicles, identifying suspect vehicles, and enhancing public safety. The Department's current agreement with Flock Safety is ending on August 23, 2026, providing an opportunity to move to a system that better meets the operational, security, privacy and community needs of the city.

The Santa Barbara Police Department will be switching to technology (Verkada’s License Plate Reader (LPR) platform) that improves investigative capabilities, and prioritizes public safety, while continuing to emphasize privacy. This purchase will deploy twelve fixed Verkada CB53 license plate recognition cameras at authorized locations within the city to assist in the investigation of crimes, identification of suspect vehicles, and timely notification of vehicles associated with serious criminal activity.

Agenda Item No. 5
Council Agenda Report
Nonrenewal of Flock Contract

Verkada’s LPR platform only captures license plate images and associated vehicle characteristics using purpose-built cameras. Authorized SBPD users may search for historical detections, create alerts for vehicles of interest, and review associated imagery within the Department’s Verkada Command environment, in accordance with established privacy safeguards. The system is intended as an investigative tool and is not used as the sole basis for enforcement action.

A central feature of the proposed Verkada system is that it operates as a closed, agencycontrolled system. License plate detections would be collected through City-owned cameras and maintained exclusively within the Department’s Verkada Command environment. The data would not be contributed to, or searchable through, a public, regional, or multi-agency license plate database. The Department would retain exclusive control over system configurations, user permissions, retention settings, alerts, and system administration.

Verkada’s License Plate Recognition system is fully compatible with the Santa Barbara Police Department's Automated License Plate Reader Policy (Policy 415 attached to this report) and will be operated in accordance with all applicable state laws and Department procedures. The system will be used solely for legitimate law enforcement purposes by authorized personnel who have completed Department-approved training. Access to LPR data will be controlled through role-based permissions already established by the Department, audit logging, and user authentication, consistent with the Department's accountability and security requirements.

As mentioned, Verkada is not a shared surveillance network; it is a city-owned, Departmentcontrolled system with no public or multi-agency search access. Therefore, the Department retains exclusive control over all system configurations, user permissions, retention settings, alerts, and system administration. Consistent with Department Policy 415, LPR data will be retained for a minimum of 30 days and will thereafter be purged unless it is reasonably believed to constitute evidence in a criminal or civil proceeding or is otherwise required to be retained by law. Any release of LPR data will occur only as authorized by Department policy and applicable California law.

Quotes for comparable systems from Axon and Motorola were considered; however, their higher costs and more limited privacy controls did not offer additional benefits that would make them preferable to Verkada.

Council Agenda Report
Nonrenewal of Flock Contract

Budget/Financial Information
The cost for removal of Flock camera equipment is five hundred dollars ($500) per camera, for a total removal cost of six thousand dollars ($6,000).

The total purchase cost of Verkada cameras and licenses for five years is $56,810.09, which can be covered using existing Police Department budget.
• 12 Verkada CB53 Outdoor LPR Cameras: $35,991.00
• 12 Five‑Year Camera Licenses: $9,891.00
• Shipping: $204.00
• Sales Tax: $4,244.09
• Labor: $6,480.00
Attachment:

1. SBPD Policy 415 Automated License Plate Reader Policy Prepared by: Bruno Peterson, Sergeant
Submitted by: Kelly Gordon, Chief of Police
Approved by: Kelly McAdoo, City Administrator
Attachment Santa Barbara Police Department
Santa Barbara PD Policy Manual
ALPR City Policy 2024 council approved update.pdf
Copyright Lexipol, LLC 2026/02/11, All Rights Reserved.

Published with permission by Santa Barbara Police
Department
ALPR City Policy 2024 council approved
update.pdf - 824

Policy
415
Santa Barbara Police Department
Santa Barbara PD Policy Manual
Automated License Plate Readers (ALPRs)
415.1 PURPOSE AND SCOPE
The purpose of this policy is to provide guidance for the capture, storage and use of digital data obtained through the use of Automated License Plate Reader (ALPR) technology. 415.2 POLICY
The policy of the Santa Barbara Police Department is to utilize ALPR technology to capture and store digital license plate data and images while recognizing the established privacy rights of the public.

All data and images gathered by the ALPR are for the official use of this department. Because such data may contain confidential information, it is not open to public review. 415.3 ADMINISTRATION
The Automatic License Plate Recognition (ALPR), allows for the automated detection of license plates. It is used by the Santa Barbara Police Department to convert data associated with vehicle license plates for official law enforcement purposes, including identifying stolen or wanted vehicles, stolen license plates and missing persons.

All installation and maintenance of ALPR equipment, as well as ALPR data retention and access, shall be managed by the vendors - in communications with the Public Safety Information Technology Manager, and in compliance with contracted policy and procedures. 415.3.1 ALPR ADMINISTRATOR
The Investigative Division Commandershall be responsible for developing guidelines and procedures to comply with the requirements of Civil Code § 1798.90.5 et seq. This includes, but is not limited to (Civil Code § 1798.90.51; Civil Code § 1798.90.53):
(a) A description of the job title or other designation of the members and independent contractors who are authorized to use or access the ALPR system or to collect ALPR information.
(b) Training requirements for authorized users.
(c) A description of how the ALPR system will be monitored to ensure the security of the information and compliance with applicable privacy laws. (d) Procedures for system operators to maintain records of access in compliance with Civil Code § 1798.90.52.
(e) The title and name of the current designee in overseeing the ALPR operation. (f) Working with the Custodian of Records on the retention and destruction of ALPR data. (g) Ensuring this policy and related procedures are conspicuously posted on the department's website.

Copyright Lexipol, LLC 2026/02/11, All Rights Reserved.

Published with permission by Santa Barbara Police
Department
Automated License Plate Readers (ALPRs) -
386
Attachment 2