Title
Adoption of a Resolution Approving the City of Alameda Sewer System Management Plan, July 1, 2025.
In accordance with the California Environmental Quality Act (CEQA), this action is categorically exempt from further environmental review pursuant to CEQA Guidelines Section 15301 (Existing Facilities), 15302 (Replacement or Reconstruction), and 15308 (Actions by Regulatory Agencies for Protection of the Environment). (Public Works 501)
Body
To: Honorable Mayor and Members of the City Council
From: Jennifer Ott, City Manager
EXECUTIVE SUMMARY
The Statewide Sanitary Sewer Systems General Order WQ 2022-0103-DWQ (2006 General Order) effective June 5, 2023, requires sanitary sewer agencies, such as the City of Alameda (City), to submit an updated Sewer System Management Plan (SSMP) every six years to comply with the State Water Resources Control Board’s (SWRCB) waste discharge requirements. The 2022 General Order requires the governing entity of the sewer system to approve the updated SSMP. Staff prepared the Sewer System Management Plan update (Exhibit 1) for City Council’s review and approval. The SSMP update will be finalized after Council’s consideration and submitted to the SWRCB prior to the first due date of August 2, 2025.
BACKGROUND
On May 2, 2006, the SWRCB adopted Statewide General Waste Discharge Requirements for the 2006 General Order. This order required all public agencies in California that own or operate a sanitary sewer system to develop and implement an SSMP. The 2006 General Order also required the SSMP to be updated and adopted by the agencies’ governing board every five years. The regulation was established in response to the frequency and impact of unintentional discharges of untreated or partially treated sewage-known as sewer spills - into the environment, including streets, basements, rivers, and other water bodies. These spills pose significant risks to public health, water quality, and property.
The goal of the SSMP is to provide a plan and schedule to: (1) properly manage, operate, and maintain all parts of the sanitary sewer system(s), (2) reduce and prevent spills, and (3) contain and mitigate spills that do occur.
The City Council adopted Resolution No. 14634 on July 21, 2009, approving the City’s first SSMP. On October 21, 2014, City Council adopted Resolution No. 14976 approving an updated SSMP. Although the SSMP was not brought to City Council in 2019, the required five-year interval per the 2006 General Order, the SSMP was kept up to date.
The SWRCB adopted Order WQ 2022-0103-DWQ on December 6, 2022, which became effective on June 5, 2023 (2022 General Order). This order supersedes the previous 2006 General Order.
DISCUSSION
The City owns and operates a sanitary sewer system consisting of 138 miles of sewer mainlines, 46 sewage pump stations, 6 miles of force mains, and approximately 3,129 manholes and other sewer structures. The City is subject to the requirements of the new 2022 General Order and must maintain regulatory coverage by complying with the new provisions. Key updates to the SSMP requirement under the 2022 General Order include:
• Broader Scope of Regulation - Extends the scope of protection from “waters of the United States” to include “waters of the State” covering a broader range of water bodies such as groundwater and non-federal waters.
• Climate Change Resilience - Incorporates adaptation strategies into sewer system planning.
• Revised Spill Reporting Protocols - Includes shorter response timeframes and increased coordination requirements.
• Modified SSMP Audits and Updates - three-year audit period with an updated SSMP brought to Council every six years.
• Revised Lateral and Spill Threshold Reporting - Aligns reporting thresholds with environmental risk.
• Enhanced Public Communication Requirements - Ensures transparency and community engagement.
City staff reviewed and revised the SSMP to reflect the required changes in the 2022 General Order. The updated SSMP (Exhibit 1) outlines the City’s proactive strategies for system maintenance, capacity assurance, emergency response, and long-term system resilience. In addition, the updated SSMP is consistent with and supportive of the City’s work requirements in the Final Consent Decree for Consolidated Case Nos. C 09-00186-RS and C 09-05684-RS.
ALTERNATIVES
• Adopt the proposed resolution with no modifications to the SSMP.
• Adopt the proposed resolution with direction for specific modifications to the SSMP.
• Do not adopt the proposed resolution and provide staff a different direction. This will impact the City’s ability to meet the regulatory deadline of submitting an updated SSMP by August 2, 2025.
FINANCIAL IMPACT
Activities in the SSMP are budgeted in the Capital Improvement Program and the Sewer Maintenance operating budget with available funds from the Sewer Enterprise Fund. The City recently conducted a sewer rate study and adopted sewer service charges to ensure adequate revenue is available to meet the capital and operational demands of the SSMP. There is no impact to the General Fund.
MUNICIPAL CODE/POLICY DOCUMENT CROSS REFERENCE
The updated SSMP addresses a Strategic Plan Priority by advancing the City’s goal to invest in infrastructure. More specifically, Strategic Plan project TIE21 is to rehabilitate 8 miles of sewer pipes.
ENVIRONMENTAL REVIEW
In accordance with CEQA, this action is categorically exempt from further environmental review pursuant to CEQA Guidelines Section 15301 (Existing Facilities), 15302 (Replacement or Reconstruction), and 15308 (Actions by Regulatory Agencies for Protection of the Environment).
CLIMATE IMPACT
There are no identifiable climate impacts from adopting the proposed resolution approving the Sewer System Management Plan, July 1, 2025
RECOMMENDATION
Adopt a resolution approving the City’s SSMP, July 1, 2025
Respectfully submitted,
Erin Smith, Public Works Director
Financial Impact section reviewed,
Ross McCarthy, Finance Director
Exhibit:
1. Sewer System Management Plan, July 1, 2025