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ELEMENT 4 – OPERATIONS AND MAINTENANCE PROGRAM <br /> <br />Sewer System Management Plan Audit (8/2/21 to 8/2/24) Page 20 of 47 <br />FINDINGS (Element 3: Analysis) <br />SSMP Element - AT. D-3 <br />COMPLIANCE <br />q The Agency should ensure its available legal authority addresses illicit discharge <br />prohibi[ons, enforcement authority, ability for adequate stormwater collabora[on and <br />access to easement areas for spill response and required maintenance; relevant codes, <br />ordinances, and/or standards should be updated to ensure proper legal authority as <br />required to comply with the Reissued WDR. <br />q The City should periodically review its illicit discharge prohibi[ons/enforcement authority <br />for satellite sewers and update as necessary. <br />q Assess element narra[ve and improve as necessary for 2025 SSMP Update. <br />IMPLEMENTATION <br />q None <br />EFFECTIVENESS <br />WDR RECOMMENDATION <br />To measure effec[veness and ensure alignment with available industry standard guidance, the City <br />should check/verify the following data for inclusion in its next required SSMP update: <br />q Annually review City codes and ordinances to ensure they are adequate in fulfilling all <br />required legal requirements. <br />q Check for instances when the code/ordinance did not address a specific <br />need/circumstance. <br />RESILIENCE <br />WDR RECOMMENDATION <br />To provide resilience and align with available industry standard guidance, the City should check/verify <br />the following data, make adjustments as necessary, and include any changes in the next required <br />SSMP update: <br />q Monitor performance of ordinances, codes, and agreements for deficiencies and omissions. <br />q Perform periodic review of ordinances, codes, and service agreements. <br />q Stay abreast of industry trends and local ordinances that may affect opera[ons. <br /> <br />ATTY/RESO.0077/CC RESO SEWER SYSTEM MANAGEMENT PLAN - EXHIBIT A <br />REV: 07-14-25 LF <br /> <br />Page 190 of 317