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LEGAL AUTHORITY © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for San Leandro use only. Page 20 of 57 3. Legal Authority WDR REQUIREMENTS Att. D-3 (pg. D-4) “The Plan must include copies or an electronic link to the Enrollee’s current sewer system use ordinances, service agreements and/or other legally binding procedures to demonstrate the Enrollee possesses the necessary legal authority to: • Prevent illicit discharges into its sanitary sewer system from inflow and infiltration (I&I); unauthorized stormwater; chemical dumping; unauthorized debris; roots; fats, oils, and grease; and trash, including rags and other debris that may cause blockages; • Collaborate with storm sewer agencies to coordinate emergency spill responses, ensure access to storm sewer systems during spill events, and prevent unintentional cross connections of sanitary sewer infrastructure to storm sewer infrastructure; • Require that sewer system components and connections be properly designed and constructed; • Ensure access for maintenance, inspection, and/or repairs for portions of the service lateral owned and/or operated by the Enrollee; • Enforce any violation of its sewer ordinances, service agreements, or other legally binding procedures; and • Obtain easement accessibility agreements for locations requiring sewer system operations and maintenance, as applicable. COMPLIANCE The above items are addressed in order below: Authority to prevent illicit discharges into the City’s wastewater collection system. The City’s Municipal Code, Section 3-15-200 to Section 3-15-215, prohibits the discharge of non- stormwater to the sewer system (with exceptions for such activities as water line flushing, landscape irrigation, and dechlorinated swimming pool water), prohibits any discharge that would result in a violation of the WPCP’s NPDES permit, prohibits illicit drainage connections, and prohibits the discharge of trash and other debris, The City’s Municipal Code, Section 3-14-300 through Section 3-14-370 include general discharge prohibitions, limitations on wastewater strength, prohibitions of specific discharges such as fats, oils, grease, and toxics, prohibits the discharge of stormwater, groundwater, and yard drainage into the sanitary sewer, prohibits dilution as a substitute for treatment, limits the use of garbage grinders, and prohibits the discharge of certain types of hospital waste. The City’s pre-planned collaboration and coordination with storm drain agencies. The City owns and operates most of the storm drains within its boundaries and has a de facto legal authority to ensure access to these storm drains in the event of a wastewater spill. The Sewer Collections staff maintain both the sewers and the storm drains. Having the same personnel operate both systems allows for streamlined spill response. In addition, both Alameda County Flood Control and Conservation District (ACFCCD) and Caltrans own and operate storm drains within the City limits. The City has historically had good communications with ACFCCD, and the City is permitted to do work with in their drains as necessary. If a spill were to occur within a ACFCCD storm drain, the City would cleanup the spill. To comply with the WDR requirement, the City will contact