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

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program implementation and enforcement, including adoption of the Enforcement Response Guide; ? Assist Coburg with development of a program and implementation plan, or develop the program for implementation through a service contract with Coburg; ? Conduct a formal review of Eugene-Springfield regulatory “local (pollutant) limits” in accordance with DEQ and EPA guidelines to determine adequacy, whether they will need to be adjusted to accommodate Coburg’s industrial pollutant load, and how reserve capacities will be established and apportioned to enable industrial growth in Eugene, Springfield and Coburg; and ? Work with Coburg to develop enforcement authority, responsibility, and program compliance assurance within Coburg’s city limits, including the ability to assess and collect fees and charges, and to implement any and all regulations and Pollution Management Practices as adopted by MWMC. The scope, timing and costs of the Eugene-Springfield efforts/resources that would be needed is difficult to assess, and would depend on the amount of assistance needed by Coburg to enact, implement, and enforce a program that is identical to Eugene’s and Springfield’s under the governance of MWMC. A rough estimate is provided in Attachment A. Collection System Construction, Maintenance, and Rehabilitation Requirements If Coburg were to connect to the MWMC system, collection system design, operation, maintenance, and long-term rehabilitation would be another set of program parameters where regulatory conformity with Eugene, Springfield and MWMC, along with ongoing resource allocation, would be required. MWMC, Eugene, and Springfield (as co-signators to the NPDES permit and co-operators of the overall system) are obliged to meet system performance standards under peak wet weather flow conditions. These standards, which prohibit sanitary sewer overflows (SSOs) except under extreme storms or catastrophic events, are met in the Eugene- Springfield area through several regulatory vehicles. The NPDES permit incorporates the Wet Weather Flow Management Plan, adopted by MWMC and the two Cities in 2001, including policies for system performance and level of treatment, as well as ongoing system hydraulic modeling, and targets for infiltration and inflow reduction through system rehabilitation and regulatory enforcement. Although Coburg would connect to the MWMC system with a newly constructed collection system, it would need to be built to standards approved by MWMC, and the City would need to ensure conformance with standards established in the Eugene-Springfield area for ensuring compliance with the NPDES permit, as well as State and Federal rules prohibiting SSOs. The Governing Bodies and/or MWMC would need to address whether sanctions would need to be determined in the event that Coburg failed to comply, resulting in greater amounts of peak flows that planned. If wastewater services are extended to Coburg, the Eugene-Springfield staff would need to plan and conduct the following work activities: ? Review and process for approval, Coburg’s collection system design specifications; ? Ensure that Coburg maintains a duly authorized and certified System Operator or that Eugene-Springfield personnel are contracted and authorized in that capacity; and ? Provide assistance to Coburg to establish ongoing system maintenance, management and rehabilitation programs, including system monitoring and reporting (this program will Page 17