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PART 1 – EXECUTIVE SUMMARY Sewer System Management Plan Audit (8/2/21 to 8/2/24) Page 10 of 47 AUDIT CONCLUSIONS The SSMP Audit completed by Fischer Compliance LLC in collabora[on with agency management and field opera[ons staff shed light on many exis[ng successful work programs in place. When comparing the City spill data/metrics performance with other collec[on systems in the region, the City performs well. Detailed audi[ng procedures incorpora[ng review of ques[onnaires, the agency’s exis[ng SSMP, interviews and other data were relied on for genera[ng the detailed Audit findings for documen[ng the agency’s SSMP compliance, implementa[on, and effec[veness. To facilitate the project and improve effec[veness of the Audit process, the City dedicated an internal staff person for managing the project, responding to ques[ons/data requests, and providing regular communica[ons to auditors in every phase of the project. Several specific technical recommenda[ons along with an implementa[on plan/schedule were generated for helping the agency get a jump start on upda[ng its SSMP, many months ahead of schedule before its due date on 8/2/2026. The Audit also revealed several areas to provide an advantage to help prepare the agency for regulatory compliance inspec[ons and improve SSMP effec[veness. This includes providing insights for the City to reflect on addi[onal ways for further improving exis[ng work programs and spill reduc[on measures. Appendix 1 serves as the heart of the Audit containing detailed Compliance Evalua[on Inspec[on (CEI) reports for suppor[ng findings and conclusions. Appendix 2 allows agency and regulators to evaluate spill performance and other data to help compare the agency’s performance against other collec[on systems in the region. Appendix 3 includes a checklist to help the agency outline and track progress to address the Audit findings, refine upda[ng of the City’s SSMP (due by 8/2/2025), and provide an overall roadmap for focusing priori[es and aIen[on with the system over the next several years. Appendices 4-5 are provided for addi[onal technical support for assis[ng the City with more tools for evalua[ng system effec[veness, tracking performance, and reviewing compliance differences between the 2006 and 2022 WDRs. POST-AUDIT RECOMMENDATIONS The City should complete Appendix 3 (SSMP Implementa[on Plan/Schedule) as soon as prac[cal to commit to ongoing/future improvements to reduce the City’s enforcement liability exposure. This exercise also provides valuable informa[on for management to help expedite comple[on of the City’s required 2025 SSMP Update due by 8/2/2025. ATTY/RESO.0077/CC RESO SEWER SYSTEM MANAGEMENT PLAN - EXHIBIT A REV: 07-14-25 LF Page 180 of 317