Item A: City of Coburg Request for Connection to Regional Wastewater Facilities

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? Increased ongoing regional wastewater program staffing and other costs associated with maintaining MWMC’s responsibilities to an additional partner, the costs of which would be significantly disproportionate to the customer base served in Coburg. Unlike Scenario One, this Scenario could not be accommodated by minor modifications to the MWMC IGA. It is assumed that significant amounts of time and resources would be spent negotiating the conditions of the partnership, drafting IGA amendment language supporting the negotiations, and processing the agreement through all four Governing Bodies. Like Scenario One, Additional IGAs would be needed depending on the level of ongoing support services Coburg would seek to contract with Eugene and/or Springfield to provide. ESTABLISHMENT OF REGULATORY REQUIREMENTS, REPORTING AND COMPLIANCE ASSURANCE The MWMC-owned regional wastewater facilities and the locally-owned collection systems in the metropolitan area are operated under a single National Pollutant Discharge Elimination System (NPDES) permit, which is issued by the DEQ to the Cities of Eugene and Springfield and to MWMC. This permit, which enables MWMC to discharge treated wastewater to the Willamette River, carries numerous requirements the Cities and MWMC must meet to maintain compliance with the Federal Clean Water Act and the State’s water quality statutes and administrative rules. This section addresses the regulatory programs/requirements that are mandatory for Eugene and Springfield, and would need to be adopted and implemented in Coburg if Coburg were to become connected to the MWMC system. It also addresses obligations Coburg would be expected to meet through ordinances and agreements. The activities and tasks staff has identified as needed are described below. An estimated time and cost for Eugene-Springfield wastewater program staff to support wastewater services to Coburg is provided in Attachment A. Industrial Pretreatment Program and Pollution Management The Industrial Pretreatment Program is a federally mandated program that is intended, among other things, 1) to prevent discharge of pollutants to the sewerage system that may interfere with the operation of the system or contaminate the resulting sludge, or pass through the system, inadequately treated, into receiving waters; 2) to protect the health of employees working in and around the sewerage system; and 3) to improve the opportunity to recycle and reclaim wastewater and sludge otherwise entering the sewerage system. In the Eugene-Springfield area, MWMC is delegated the authority to develop and enact the “model” pretreatment ordinance and corresponding pollutant limits. MWMC also enacts regulatory Pollution Management Practices for certain businesses and industries that are not regulated by permit, because they generate significant pollutants of concern. Eugene and Springfield are obligated to adopt local ordinances, enact rules, and implement programs that are identical to the MWMC-adopted models. If wastewater services are extended to Coburg, the Eugene-Springfield staff would need to plan and conduct the following work activities: ? Provide background information and technical assistance to Coburg staff and Council; ? Assist Coburg with development, legal review, and adoption of ordinances that implement the MWMC model pretreatment program, local limits, and that provide for Page 16