Sewer Use and Stormwater Ordinance Updates

Wastewater discharged to the Palo Alto Regional Water Quality Control Plant–the City’s wastewater treatment plant– is governed by the City’s Sewer Use Ordinance (SUO–Palo Alto Municipal Code Chapter 16.09). This Chapter sets requirements that protect both public health and wastewater collection and treatment infrastructure. Proposed ordinance revisions would:

• remove requirements for stormwater, fats, oil, and grease, and hauled liquid waste and establish these provisions as separate ordinance chapters;
• incorporate requirements and recommendations of the 2007 EPA Model Pretreatment Ordinance into the City’s new SUO;
• incorporate required changes identified during the 2022 RWQCP Pretreatment Program Audit. 

Currently the discharge of hauled liquid waste is governed by Palo Alto Municipal Code Chapter 16.09 as a subsection of the larger Sewer Use Ordinance. The City proposes removing hauled liquid waste requirements from the larger Sewer Use Ordinance, and moving those requirements into a new proposed Chapter 16.66 of the Palo Alto Municipal Code. No other major changes to current hauled liquid waste requirements are proposed. 

Food facilities (including restaurants, hotels, convenience stores, and religious institutions) are a significant source of Fats, Oils, and Grease (FOG) that enter the sanitary sewer treatment system. FOG can clog pipes and result in sanitary sewer overflows that negatively impact public health, creeks, the City’s storm drain system, and the San Francisco Bay. In addition, clogged sanitary pipes result in costly maintenance for both businesses and the City. The California Plumbing Code addresses how FOG should be managed in food facilities, while the State Water Resources Control Board’s Sanitary Sewer Systems General Order regulates how the City must manage its wastewater collection (or sanitary sewer) system and prevent the introduction of FOG to the system.

The City proposes establishing a new ordinance Chapter 16.13 of the City’s Municipal Code to regulate how FOG shall be managed by food facilities to also include FOG provisions from the current Sewer Use ordinance (see description of that draft update above). This will consolidate all FOG requirements into one ordinance.

Water quality impacts of stormwater runoff are regulated by the San Francisco Bay Regional Water Quality Control Board (Water Board). The Water Board’s requirements are detailed in the Municipal Regional Stormwater NPDES Permit (MRP), which states that the City of Palo Alto (and 76 other local agencies in the Bay Area) shall not allow anything other than rain into the City’s storm drain system, creeks, and the San Francisco Bay. The MRP establishes how the City must comply to ensure pollutants do not discharge from businesses, construction sites, residences, and other potential sources.

The City’s stormwater requirements in the existing sewer use ordinance establish the City’s authority to enforce MRP requirements and formalize compliance processes. The City will update municipal code Chapter 16.11 as the stand-alone Stormwater Ordinance separating out MRP requirements from the current sewer use ordinance. See the link to the table below, which describes the major sections of the new draft Stormwater Ordinance.