8.
City Council Work Session
- Meeting Date:
- 09/09/2025
- From:
- Jolene Montoya, Water Services Section Director - Regulatory Compliance
- Department:
- Water Services
Co-Submitter:
TITLE:
Updates to the Flagstaff Water Services Enforcement Response Plan (ERP)
DESIRED OUTCOME:
Presentation and Discussion on ERP Changes.
Executive Summary:
- Update narrative to have the stormwater section match pretreatment and cross-connection in language.
- Update Watershed Specialist to Stormwater Project Manager.
- Add in Floodplain language from City Code.
- Update Stormwater and Regulatory Compliance Managers to Water Services Manager/Section Director.
- List Scavenger Waste violations for staff direction.
Information:
In 2018, the City Council adopted by reference the Enforcement Response Plan (ERP) that is required for the Pretreatment and MS4 programs to protect City wastewater treatment infrastructure and facilities which was slightly revised by Council in 2022. In the period since, Water Services has followed this plan for various enforcement actions that include from warning letters to an administrative order. These proposed changes would reflect position title changes within Water Services as well as give authority for escalating enforcement to proper staff. There is also an addition to the Pretreatment section for scavenger waste enforcement. Although there has already been enforcement related to scavenger waste permits, we felt it was necessary to list specific issues with this program for direction to City personnel. Lastly, there are clerical changes to ensure the document is in the same format throughout. None of these changes will adjust any monetary fines or types of enforcement actions.