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Home My WebLink About4/21/2026 Item 7b, Oasis Associates Carol Florence <cmf@oasisassoc.com> Sent:Wednesday, April To:E-mail Council Website Cc:Floyd, Aaron; Scott, Shawna; Lehman, Chris; Emily Ewer Subject:CC Meeting_21 April 2026_Item 7b Attachments:2026-04-15.OAI Comments to CC Item 7b_Sewer Capacity Program Amendments.pdf Dear Council Members & Staff, Thank you, in advance, for accepting the attached comments on the noted City Council item. We appreciate the opportunity to provide our thoughts and look forward to hearing your response and the other public input. Yours respectfully, C.M. Florence, AICP Principal Planner OASIS ASSOCIATES, INC. 3427 Miguelito Court San Luis Obispo, CA 93401 P: 805.541.4509 I D: 805.548.1561 I M: 805.459.9972 www.oasisassoc.com thth I will be OOO from Friday, April 24 – Tuesday, April 28 attending the American Planning Association annual conference. I will be reading and responding to emails, albeit not at my usual pace. Please contact me should your projects need attention prior to my travels! 1 3427 Miguelito Court San Luis Obispo, CA 93401 805.541.4509 p 805.546.0525 f www.oasisassoc.com CP 018415 ● RLA 2248 ● CLARB 907 15 April 2026 Honorable City Council Members CITY OF SAN LUIS OBIPSO 990 Palm Street San Luis Obispo, CA 93401 via email - emailcouncil@slocity.org RE: 21 April 2026 Council Agenda Item 7b – Proposed Revisions to Title 13, Chapter 13.08 §13.08.395 (Private Sewer Laterals/Systems) & §13.08.396 (Wastewater Flow Offset) Dear Council Members, Oasis Associates, Inc. has reviewed the proposed amendments to Title 13, including modifications to Sections 13.08.395 (Private Sewer Laterals/Systems) and 13.08.396 (Wastewater Flow Offset). We appreciate the City’s efforts to modernize the program and improve system performance through a more data-driven approach. Based on our review of the staff report and proposed ordinance, we offer the following comments and recommendations for Council and staff consideration: 1. Clarification of Wastewater Flow Engineering Analysis Requirements The proposed framework relies on project-specific wastewater flow modeling and engineering analysis to determine potential impacts and any required mitigation. However, the scope, methodology, and required documentation for such analyses are not clearly defined. We recommend that the City: • Establish clear guidelines outlining the required scope of analysis, assumptions, and data inputs; • Define who is qualified to prepare such analyses (e.g., licensed civil engineers versus other professionals); and • Provide general cost expectations or ranges associated with preparing these studies. Providing this clarity will ensure consistency in application, reduce uncertainty for applicants, and streamlines staff review. 2. Ministerial Projects and Potential Impacts to Capacity-Constrained Areas While the staff report indicates that most ministerial projects will not be subject to offset requirements, recent State housing laws allow for larger-scale residential developments to be processed ministerially. As a result, projects that may generate substantial wastewater flows could proceed without discretionary review or project-specific mitigation requirements. This creates a potential gap in addressing cumulative impacts to the wastewater system, particularly within capacity-constrained areas. We recommend the City consider: • Whether additional objective criteria or safeguards are needed to address larger ministerial projects; and • How public health and system capacity concerns will be evaluated and mitigated in these cases. 3. Development Review Thresholds and Equity Between Land Use Types The current development review thresholds create a significant disparity between residential and non- residential projects. For example: • Commercial projects exceeding 10,000 square feet are subject to Major Development Review; while • Residential projects require 50 or more units to reach a similar threshold. OASIS ASSOCIATES, INC. 15 April 2026 Wastewater Flow Offset Program Ordinance Amendments Page 2 of 3 3427 Miguelito Court San Luis Obispo, CA 93401 805.541.4509 p 805.546.0525 f www.oasisassoc.com CP 018415 ● RLA 2248 ● CLARB 907 Applying wastewater flow analysis requirements based on these thresholds may disproportionately burden commercial development, despite potentially lower wastewater generation. We recommend that the City: • Reevaluate the nexus between development review thresholds and wastewater generation; and • Consider whether wastewater analysis triggers should be based on projected flow rather than project size alone. 4. Lack of Nexus Between Project Size and Wastewater Generation Relatedly, development review thresholds are primarily based on architectural and planning considerations, not infrastructure demand. For example, a large industrial or storage building with minimal plumbing fixtures may trigger extensive review and analysis, while a high-density residential project with significantly greater wastewater generation may not, depending on processing pathway. We recommend that the City: • Incorporate wastewater generation metrics (e.g., fixture units, estimated discharge) into the determination of when engineering analysis is required; and • Ensure that regulatory triggers are aligned with actual system impacts. 5. Changes of Use Within Existing Structures The proposed framework appears to focus primarily on new development and intensification through discretionary review. However, increases in wastewater discharge can also occur through changes of use within existing buildings. We recommend that the City clarify: • How changes of use that increase wastewater demand will be evaluated; and • Whether additional analysis or mitigation may be required in such cases, particularly in constrained areas. 6. Predictability and Transparency of Case-by-Case Mitigation Requirements The staff report indicates that future offset or mitigation requirements will be determined on a case-by- case basis using engineering analysis and system modeling. While this approach may improve proportionality, it may also introduce uncertainty for applicants if there are no established benchmarks, metrics, or cost expectations. To improve transparency and predictability, we recommend that the City: • Develop general guidelines (or) example scenarios illustrating potential mitigation requirements; • Provide case studies or representative cost ranges for different project types; and • Consider establishing standardized methodologies or thresholds to guide determinations. This will help applicants better understand potential obligations early in the development process and reduce variability in outcomes. Oasis Associates, Inc. supports the City’s goal of improving wastewater system performance and addressing inflow and infiltration through targeted infrastructure improvements. The proposed shift toward data- driven decision-making and lateral replacement is a meaningful step forward. However, as the City transitions away from a prescriptive offset program toward a discretionary, analysis- based framework, it is critical to ensure that the new system is: OASIS ASSOCIATES, INC. 15 April 2026 Wastewater Flow Offset Program Ordinance Amendments Page 3 of 3 3427 Miguelito Court San Luis Obispo, CA 93401 805.541.4509 p 805.546.0525 f www.oasisassoc.com CP 018415 ● RLA 2248 ● CLARB 907 • Clearly defined, • Equitably applied across project types, and • Predictable for property owners and the development community. We appreciate the opportunity to provide these comments and look forward to continued collaboration with City staff. Yours respectfully, OASIS ASSOCIATES, INC. C.M. Florence, AICP Emily Ewer, AICP Principal Planner Senior Planner cc: A. Floyd, Public Works & Utilities Director C. Lehman, Deputy Director – Wastewater S. Scott, Asst. Director of Utilities \\oasis-2023\oasis-data\city san luis obispo\2026-04-21.city council hearing_sewer capacity program amendments\2026-04-14.oai comments to the sewer capacity program amendments cmf.docx