UPDATED ERP (IN LEGISLATIVE FORMAT).DOCX

City of Tempe — Regular City Council Meeting (2026-01-22)

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Public Works Department
Water Utilities Division
Environmental Services Section
Enforcement Response Plan

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Table of Contents
I.
     PURPOSE ............................................................................................................................1
II.
DEFINITIONS .....................................................................................................................2
III.
GENERAL RESPONSIBILITIES........................................................................................5
IV.      AIR QUALITY:  ENFORCEMENT RESPONSE………………………………………...7
V.
CROSS CONNECTION CONTROL:  ENFORCEMENT RESPONSE.............................9
VI.
PRETREATMENT:  ENFORCEMENT RESPONSE .......................................................11
VII.
STORMWATER:  ENFORCEMENT RESPONSE...........................................................13
VIII. POINTS ASSESSMENT CRITERIA ................................................................................17
IX.       ADMINISTRATIVE FINE SCHEDULE (TABLE A)......................................................18
       HHEP VIOLATIONS (TABLE B) ....................................................................................19

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I.
PURPOSE
This Enforcement Response Plan (ERP) specifies how the City of Tempe (“City”) will 
investigate and respond to instances of noncompliance with the following Articles of the Tempe 
City Code (T.C.C.), collectively, the “Human Health and Environmental Protection Ordinances” 
or “HHEP Ordinances”:
CHAPTER 12, ARTICLE IVVI:
STORMWATER RETENTION
Chapter 12, Article VI:
Stormwater Pollution Control 
CHAPTER 13A, ARTICLE III:
DUST CONTROL
Chapter 27:
 
Sewers and Sewage Disposal
Chapter 33, Article V: 
Cross Connection Control
This ERP was developed in accordance with 40 C.F.R. Section 403.8(f)(5); T.C.C. SECTIONS 
12-99, 12-153, 13A-52, 13A-56, 27-95 and 33-111; T.C.C. Chapter 27, Divisions 10 – 12; and 
with the requirements of AZPDES Stormwater Permit No. AZS000005.  
The intent of the ERP is to enforce the HHEP Ordinances in an equitable and consistent manner 
to ensure compliance with these ordinances.  THESE ORDINANCES ARE ESSENTIAL FOR 
PROTECTING PUBLIC HEALTH AND SAFETY, PRESERVING THE CITY’S 
INVESTMENT IN CRITICAL INFRASTRUCTURE, AND SAFEGUARDING THE HEALTH 
AND SAFETY OF PERSONNEL WHO WORK IN OR AROUND THE POTABLE 
DRINKING WATER SYSTEM (“DW”), THE PUBLICLY OWNED TREATMENT WORKS 
(“POTW”), THE MUNICIPAL SEPARATE STORM SEWER SYSTEM (“MS4”), AND THE 
ENVIRONMENT. The HHEP Ordinances are important to protect public health and safety, the 
City’s investment in infrastructure, and the health and safety of personnel working in or on the 
potable drinking water system (“DW”), the publicly owned treatment works (“POTW”), the 
environment, and the municipal separate storm sewer system (“MS4”).

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II.
DEFINITIONS
In this ERP, the following words and phrases shall have the following meanings, unless the 
context otherwise requires:
ADMINISTRATIVE APPEAL: A FORMAL APPEAL TO THE PUBLIC WORKS 
DIRECTOR BY A RESPONSIBLE PARTY OR PERSON REQUESTING 
RECONSIDERATION OF ANY ENFORCEMENT ACTION INITIATED UNDER THIS ERP.
Administrative enforcement:  Legal, independently enforceable orders issued directly by Tempe 
officials that define the violation, provide evidence of the violation, impose administrative fines 
and/or require the RP to take corrective action within a specified time period.
Administrative fine:  Monetary penalty assessed through administrative enforcement 
(ADMINISTRATIVE ORDER, CONSENT ORDER, A COMPLIANCE ORDER, A CEASE 
AND DESIST ORDER AND/OR PRETREATMENT SETTLEMENT AGREEMENT) ISSUED 
BY THE CITY OF TEMPE.
AO:  ADMINISTRATIVE ORDER
ADEQ:  Arizona Department of Environmental Quality
A.R.S.:  Arizona Revised Statutes
AZPDES:  Arizona Pollutant Discharge Elimination System
BMP:  Best Management Practices
CFR:  Code of Federal Regulations.
DRAINAGE INFRASTRUCTURE: DEVICES, CONVEYANCES, RETENTION SYSTEMS, 
STRUCTURES THAT ARE USED TO MANAGE AND CONTROL STORM WATER 
RUNOFF INCLUDING, BUT NOT LIMITED TO: BUBBLER BOXES, CATCH BASINS, 
CHANNELS, CONDUITS, CULVERTS, DETENTION/RETENTION PONDS/BASINS, 
DRYWELLS, DITCHES, FLUMES, PIPES, PUMPS, SCUPPER, TREATMENT SYSTEMS, 
WETLANDS AND APPURTENANCES TO THOSE ITEMS, WHETHER NATURAL OR 
ARTIFICIAL, THAT ARE USED TO DRAW OFF SURFACE WATER FROM LAND, 
CARRY THE WATER AWAY, COLLECT, STORE, OR TREAT THE WATER, OR DIVERT 
THE WATER INTO NATURAL OR ARTIFICIAL WATERCOURSES.
Due date:  Date by which report or action is to be completed.  
DW: DRINKING WATER

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Harm caused:  POTW process upset/inhibition/disruption of normal operation and/or adverse 
change in POTW effluent, adverse change in POTW sludge (bio-solids) 
characteristics/concentrations; a discharge into the MS4 which results in a violation of the 
AZPDES Stormwater Permit; and/or adverse impact on the environment.  
HHEP OR HUMAN HEALTH AND ENVIRONMENTAL PROTECTION Ordinances:  
T.C.C. Chapter 12, Article IV (Stormwater Retention);Chapter 12, Article VI (Stormwater 
Pollution Control); Chapter 13A (Dust Control); Chapter 27 (Sewers and Sewage Disposal); and 
Chapter 33, Article V (Cross-Connection Control).
Judicial enforcement:   Enforcement, either civil or criminal, against a responsible party or 
organization through a court of law.
MS4: MUNICIPAL SEPARATE STORM SEWER SYSTEM
Nondomestic user:  An individual, corporation, or organization other than a single-family 
domicile which uses the potable water, wastewater, or public storm drain systems.
NOI:  Notice of Intent to Discharge to POTW
NOV:  Notice of Violation
Person:  An individual, corporation, entity, or organization.
POTW:  Publicly Owned Treatment Works
PSA:      PRETREATMENT SETTLEMENT AGREEMENT  
RP:  Responsible Person; the owner and/or operator of A property.  
SNC or significant noncompliance - Pretreatment:  (a) In order to comply with the public 
participation requirements of 40 CFR Part 25 in the enforcement of National Pretreatment 
Standards, for nondomestic users permitted to discharge wastewater, the definition of significant 
noncompliance shall have the same meaning as set forth by 40 CFR 403.8(f)(2)(viii) and Section 
27-82 of the T.C.C.;  (b) For violations of Chapter 12, Article IV, Stormwater Retention; Chapter 
12, Article VI, Stormwater Pollution Control; and Chapter 33, Article V, Cross-Connection 
Control, the RP shall be determined to be in SNC if the RP accumulates four or more points at 
any time during the previous six (6) months preceding the end of a quarter.  
T.C.C.:  Tempe City Code
TGC:  TEMPE GREASE COOPERATIVE
WL:  Warning Letter

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Violation:  Non-compliance with the HHEP Ordinances
III.
GENERAL RESPONSIBILITIES
PUBLIC WORKS DEPARTMENT 
Public Works Director
The Public Works Director is responsible for administration and enforcement of the HHEP 
Ordinances and the appropriate application of the ERP to suspected violations.  The Public 
Works Director may delegate authority to City staff as authorized by the T.C.C.
WATER UTILITIES DIVISION
Deputy PUBLIC WORKS Director - Water
If so delegated, the Deputy Public Works Director - Water is responsible for the appropriate 
application of the ERP to suspected violations.  The Deputy Public Works Director – Water will:

Conduct ADMINISTRATIVE APPEALS AND show cause hearings;

Issue administrative orders (AOs) as deemed appropriate by the Deputy PUBLIC WORKS 
DIRECTOR - WATER following a show cause hearing; 

Approve assessment of administrative fines;

Approve termination or emergency suspension of water or wastewater services; and

Implement enforcement responsibilities in the T.C.C. Sections 12-71, 12-116, 13A-52, 13A-
56, 27-95, and 33-101.
ENVIRONMENTAL SERVICES SECTION
Environmental Services SECTION Manager
The Environmental Services Manager is responsible for ensuring fair EQUITABLE and 
consistent implementation of the ordinance requirements and ensuring that enforcement activities 
are consistent withFOLLOW the ERP. The ENVIRONMENTAL SERVICES SECTION 
Manager will:

Review all suspected violations;

Promptly notify the Deputy Public Works Director – Water of significant noncompliance;

Sign Notices of Violation (NOVs);

Sign initial AOs;

Consult with the City Attorney regarding administrative enforcement; and

Make recommendations to the City Attorney regarding initiating judicial enforcement.
Environmental Services SECTION Supervisors

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The Environmental SERVICES SECTION SupervisorS are responsible for ensuring fair 
EQUITABLE and consistent implementation of the ordinance requirements and ensuring that 
enforcement activities are consistent withFOLLOW the ERP. The Supervisors will:

Supervise and manage the Environmental Compliance Inspectors;

Review all suspected violations;

Recommend appropriate enforcement for violations;

Initiate and conduct communication with the RP, including telephone contact, site inspections 
and meetings;

Develop and oversee compliance monitoring schedules;

Track enforcement response times;

Approve compliance sampling schedules;

Recommend AOs;

Recommend emergency suspension and termination of service;

Consult with the City Attorney on administrative enforcement;

Recommend initiation of judicial enforcement;

Collect administrative fines for violations upon approval by the Environmental Services 
SECTION Manager and/or Deputy Public Works director - WATER; AND

Participate in ADMINISTRATIVE APPEALS, show cause hearings and court proceedings as 
deemed necessary by the Public Works Director, Deputy Public Works Director - WATER, 
Environmental Services SECTION Manager, and/or City Attorney.
Environmental Compliance Inspectors
Environmental Compliance Inspectors (ECIs) are responsible for conducting compliance 
inspections.  ECIS will:

Conduct outreach and educational activities with regulated persons;

CONDUCT WASTEWATER SAMPLING;

Screen compliance monitoring data;

Determine compliance with permit conditions AND/or T.C.C. through on-site inspections and 
prepare inspection reports;

Identify instances of noncompliance;

Promptly notify the Environmental SERVICES SECTION Supervisor of noncompliance;

Draft warning letters (WLs);

Draft NOVs;

Assist in drafting AOs;

Develop compliance sampling schedules;

Provide compliance assistance as appropriate; AND

Participate in ADMINISTRATIVE APPEALS, show cause hearings and court proceedings as 
deemed necessary by the Public Works Director, Deputy Public Works Director - WATER, 
Environmental Services SECTION Manager, and/or City Attorney.
Water Quality Specialists
The Water Quality Specialists will be responsible for conducting compliance monitoring. The 
WATER QUALITY Specialists will:

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
Conduct compliance monitoring as required by permit AND/or T.C.C.;

Conduct field testing consistent with approved test methods;

Preserve samples as test methods require;

Initiate and maintain chain of custody of sample(s) until sample delivery to laboratory;

Prepare and maintain detailed notes of sampling activities, dates, times, and observations;

Provide sampling assistance to ECI(s); AND

Participate in ADMINISTRATIVE APPEALS, show cause hearings and court proceedings 
as deemed necessary by the Public Works Director, Deputy Public Works Director - 
WATER, Environmental Services SECTION Manager, and/or City Attorney.
 
CITY ATTORNEY
The City Attorney’s Office will:

Provide assistance and advice on legal/regulatory issues, developments, and changes;

Advise City staff during administrative enforcement matters as required;

Consult with Environmental Services SECTION Manager on administrative enforcement 
actions and review AOs issued by the ENVIRONMENTAL SERVICES SECTION Manager;

Manage and prosecute judicial enforcement on behalf of the City. 
MAILING ADDRESS & CONTACT INFORMATION   
P.O. Box 5002, Tempe, Arizona 85280
Phone: (480) 350-2678  
Fax: (480) 350-2615

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IV.
AIR QUALITY:  ENFORCEMENT RESPONSE
INVESTIGATION OF NONCOMPLIANCE WILL BE CONDUCTED BY  
ENVIRONMENTAL SERVICES SECTION STAFF. THE METHODS USED TO 
INVESTIGATE AND TO DETERMINE NONCOMPLIANCE MAY INCLUDE, BUT ARE 
NOT LIMITED TO: 
1. RESPOND TO COMPLAINTS RECEIVED FROM THE PUBLIC;
2. ON-SITE INSPECTIONS, INCLUDING SCHEDULED AND UNSCHEDULED 
VISITS; AND
3. CONDUCT SURVEILLANCE OF ACTIVITY TO VERIFY COMPLIANCE AND 
RECORD ACTIVITY THAT IS NON-COMPLIANT WITH THE T.C.C. 
THE CITY’S ENFORCEMENT RESPONSE TO ANY VIOLATION OF CHAPTER 13A MAY 
INCLUDE, BUT IS NOT LIMITED TO, THE FOLLOWING:
1. CONTACT BY INSPECTOR;
2. PROVIDE EDUCATIONAL MATERIAL OF BMP AND T.C.C. REQUIREMENTS 
AND/OR PROHIBITIONS;
3. WL (MAY INCLUDE CEASE AND DESIST);
4. NOV WITH OR WITHOUT AN ACCOMPANYING AO, WHICH MAY INCLUDE:
a.
AFFIRMATIVE OBLIGATIONS, 
b. PROHIBITED ACTIONS OR OBLIGATIONS TO CEASE AND DESIST,
c.
OTHER APPROPRIATE ORDERS;
5. ADMINISTRATIVE FINES;
6. HEARINGS TO SHOW CAUSE; 
7. JUDICIAL ENFORCEMENT ACTION, INCLUDING INJUNCTIVE RELIEF AND 
CRIMINAL PROSECUTION. 
ENFORCEMENT TIME FRAME
1. ENFORCEMENT RESPONSES TO INITIAL AIR QUALITY PROGRAM 
VIOLATIONS WILL BE INITIATED WITHIN THIRTY (30) DAYS OF DISCOVERY 
OR AT THE DISCRETION OF THE ENVIRONMENTAL SERVICES SECTION 
MANAGER.  WHENEVER USE OF AN NOV AS AN ENFORCEMENT RESPONSE 
IS SELECTED, IMMEDIATE ISSUANCE IS ALLOWED.
2. WHEN APPROPRIATE, FOLLOW-UP INSPECTIONS WILL OCCUR WITHIN TEN 
(10) DAYS OF A DUE DATE SPECIFIED IN A NOV.
3. FOLLOW-UP ESCALATED ACTION FOR REPEAT OR REOCCURRING 
OFFENSES WILL BE TAKEN WITHIN TEN (10) DAYS OF DISCOVERY OF THE 
REPEAT OR REOCCURRING OFFENSES AND MAY INCLUDE ADDITIONAL 
ADMINISTRATIVE ENFORCEMENT, INCLUDING AOS, ADMINISTRATIVE 
FINES, AND JUDICIAL ENFORCEMENT. 
4. IN EMERGENCY SITUATIONS CAUSED BY VIOLATIONS, INCLUDING 
IMMINENT DANGER TO THE PUBLIC HEALTH, SAFETY, OR WELFARE, AND

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ENDANGERMENT TO CITY PERSONNEL OR THE ENVIRONMENT, THE 
PUBLIC WORKS DIRECTOR OR THEIR DELEGATED REPRESENTATIVE MAY 
INITIATE ENFORCEMENT RESPONSES, INCLUDING WITHOUT LIMITATION 
ISSUANCE OF CEASE AND DESIST ORDERS;
5. A PERSON THAT HAS BEEN SUBJECT TO ENFORCEMENT ACTION UNDER 
THIS ERP MAY REQUEST AN ADMINISTRATIVE APPEAL. 
6. AN ADMINISTRATIVE APPEAL SHALL NOT BE A BAR AGAINST, OR 
PREREQUISITE FOR, TAKING ANY OTHER ACTION AGAINST THE PERSON.
7. THE PUBLIC WORKS DIRECTOR MAY ENTER INTO AN AGREEMENT WITH A 
RESPONSIBLE PARTY OR PERSON SUBJECT TO ENFORCEMENT UNDER THIS 
ERP.

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V.        CROSS CONNECTION CONTROL:  ENFORCEMENT RESPONSE
Investigation of noncompliance will be conducted by the ENVIRONMENTAL SERVICES 
SECTION STAFF.  The methods used to investigate and to determine noncompliance may 
include, but are not limited to: 
1. Respond to complaints received from the public;
2. On-site inspections, including scheduled and unscheduled visits; 
3. Scheduled and unscheduled testing of nondomestic users’ backflow assemblies THAT 
ARE NON-RESIDENTIAL CUSTOMERS;
4. Conduct surveillance of testers to verify test procedures are being followed; 
5. Review water purchase records and use of water of nondomestic users;
6. Review of reported backflow assembly test results.
The City’s Enforcement Response to any violation of Chapter 33, Article V, may include, but is 
not limited to, the following:
1. Contact by inspector;
2. Provide educational material of BMP and T.C.C. requirements and/or prohibitions;
3. WL;
4. NOV WITH OR WITHOUT AN ACCOMPANYING AO, WHICH MAY INCLUDE:
a.
AFFIRMATIVE OBLIGATIONS, 
b. PROHIBITED ACTIONS OR OBLIGATIONS TO CEASE AND DESIST,
c.
OTHER APPROPRIATE ORDERS;
5. Administrative fines;
6. Emergency suspension or termination of service;
7. Hearings to show cause;
8. Publication of significant violators and imposition of fines;
9.
Judicial enforcement action, including injunctive relief and criminal prosecution.
ENFORCEMENT TIME FRAME
1. Enforcement responses to initial Cross Connection Control Violations will be initiated 
within THIRTY (30) days of discovery or at the discretion of the Environmental Services 
SECTION Manager. Whenever use of an NOV as an enforcement response is selected, 
immediate issuance is allowed.
2. When appropriate, follow-up inspections will occur within ten (10) days of a due date 
specified in a NOV.
3. Follow-up escalated action for repeat or reoccurring offenses will be taken within ten 
(10) days of discovery of the repeat or REOCCURRING offenses and may include 
additional administrative enforcement, including AOs and administrative fines, and 
judicial enforcement. 
4. In emergency situations caused by violations, including imminent danger to the public 
health, safety, or welfare, and endangerment to City personnel or the environment, the

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Public Works Director or THEIR delegated representative may initiate enforcement 
responses, including without limitation:
a.
Issuance of cease and desist orders;
b. Water or wastewater service termination;
c.
Revocation or termination of any permits issued by the Public Works Department.
5. A PERSON THAT HAS BEEN SUBJECT TO ENFORCEMENT ACTION UNDER 
THIS ERP MAY REQUEST AN ADMINISTRATIVE APPEAL. 
6. AN ADMINISTRATIVE APPEAL SHALL NOT BE A BAR AGAINST, OR 
PREREQUISITE FOR, TAKING ANY OTHER ACTION AGAINST THE PERSON.
7. THE PUBLIC WORKS DIRECTOR MAY ENTER INTO AN AGREEMENT WITH A 
RESPONSIBLE PARTY OR PERSON SUBJECT ENFORCEMENT UNDER THIS 
ERP.

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VI.
PRETREATMENT:  ENFORCEMENT RESPONSE
INVESTIGATION OF NONCOMPLIANCE WILL BE CONDUCTED BY THE 
ENVIRONMENTAL SERVICES SECTION STAFF. THE METHODS USED TO 
INVESTIGATE AND TO DETERMINE NONCOMPLIANCE MAY INCLUDE, BUT ARE 
NOT LIMITED TO:
1. RESPOND TO COMPLAINTS RECEIVED FROM THE PUBLIC;
2. ON-SITE INSPECTIONS OF THE NONDOMESTIC USER, INCLUDING 
SCHEDULED AND UNSCHEDULED VISITS;
3. SCHEDULED AND UNSCHEDULED SAMPLING OF PROCESS AND OR 
DOMESTIC EFFLUENT;
4. CONDUCT SURVEILLANCE OF ACTIVITY TO VERIFY COMPLIANCE AND 
RECORD ACTIVITY THAT IS NON-COMPLIANT WITH T.C.C. AND/OR 
APPLICABLE PERMIT; 
5. REVIEW APPLICABLE DATA, RECORDS AND SAMPLING ANALYSIS 
RESULTS.
The City’s Enforcement Response to any violation of Chapter 27 may include, but is not limited 
to, the following:
      1.   Contact by inspector;
2. Provide educational material of BMP and T.C.C. requirements and/or prohibitions;
3. WL;
4. NOV WITH OR WITHOUT AN ACCOMPANYING AO, which may include:
a.
Modification of wastewater discharge permits,
b. Affirmative obligations, 
c.
Prohibited actions or obligations to cease and desist,
d. Other appropriate orders;
5. Administrative fines;
6. Emergency suspension or termination of service;
7. Hearings to show cause;
8. Publication of significant violators NONCOMPLIANCE;
9. Judicial enforcement action, including injunctive relief and criminal prosecution. 
ENFORCEMENT TIME FRAME
1. Enforcement responses to initial Pretreatment Program violations will be initiated within 
THIRTY (30) days of discovery or at the discretion of the Environmental Services 
SECTION Manager. Whenever use of an NOV as an enforcement response is selected, 
immediate issuance is allowed.
2. When appropriate, follow-up inspections will occur within ten (10) days of a due date 
specified in a NOV.

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3. Follow-up escalated action for repeat or REOCCURRING offenses will be taken 
INITIATED within ten (10) days of discovery of the repeat or REOCCURRING offenses 
and may include additional administrative enforcement, including AOs and 
administrative fines, and judicial enforcement. 
4. In emergency situations caused by violations, including imminent danger to the public 
health, safety, or welfare, and endangerment to City personnel or the environment, the 
Public Works Director or their delegated representative may initiate enforcement 
responses, including without limitation:
a.
Issuance of cease and desist orders;
b. Water or wastewater service termination;
c.
Revocation or termination of any permits issued by the PUBLIC WORKS 
Department;
d. At the recommendation of the PUBLIC WORKS Director to another Department 
Director, termination of permits issued by that respective Department.
5. PURSUANT TO CHAPTER 27-96, A PERSON THAT HAS BEEN SUBJECT TO 
ENFORCEMENT ACTION UNDER THIS ERP MAY REQUEST AN 
ADMINISTRATIVE APPEAL. 
6. AN ADMINISTRATIVE APPEAL SHALL NOT BE A BAR AGAINST, OR 
PREREQUISITE FOR, TAKING ANY OTHER ACTION AGAINST THE PERSON.
7. THE PUBLIC WORKS DIRECTOR MAY ENTER INTO AN AGREEMENT WITH A 
RESPONSIBLE PARTY OR PERSON SUBJECT TO ENFORCEMENT UNDER THIS 
ERP.

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VII.
STORMWATER:  ENFORCEMENT RESPONSE
ENFORCEMENT OF VIOLATIONS OF CHAPTER 12, ARTICLES IV AND VI, FROM 
DOMESTIC SOURCES MAY BE LIMITED TO ITEMS 1 THROUGH 3 UNLESS THE 
PUBLIC WORKS DIRECTOR DETERMINES THAT SPECIAL CIRCUMSTANCES 
WARRANT ADDITIONAL ENFORCEMENT MEASURES.  
STORMWATER POLLUTION
INVESTIGATION OF NONCOMPLIANCE WILL BE CONDUCTED BY THE 
ENVIRONMENTAL SERVICES SECTION STAFF. THE METHODS USED TO 
INVESTIGATE AND TO DETERMINE NONCOMPLIANCE MAY INCLUDE, BUT ARE 
NOT LIMITED TO:
1. RESPOND TO COMPLAINTS RECEIVED FROM THE PUBLIC;
2. ON-SITE INSPECTIONS OF USER, INCLUDING SCHEDULED AND 
UNSCHEDULED VISITS;
3. CONDUCT SURVEILLANCE OF ACTIVITY TO VERIFY COMPLIANCE AND 
RECORD ACTIVITY THAT IS NON-COMPLIANT WITH T.C.C.; 
4. SCHEDULED AND UNSCHEDULED SAMPLING OF PROCESS AND/OR 
DOMESTIC RUNOFF;
5. REVIEW APPLICABLE DATA, RECORDS AND SAMPLING ANALYSIS 
RESULTS.
The City’s Enforcement Response to any violation of Chapter 12, Article VI, may include, but is 
not limited to, the following:
1. Contact by Inspector;
2. Provide educational material of BMP and T.C.C. requirements and/or prohibitions;
3. WL;  
4. NOV WITH ACCOMPANYING AO, which may include:
a) Affirmative obligations; 
b) Prohibited actions or obligations to cease and desist,
c) Other appropriate orders;
5. Administrative fines;
6. Emergency suspension or termination of service;
7.
Hearing to show cause;
8.
Judicial enforcement action, including injunctive relief and criminal prosecution.
ENFORCEMENT TIME FRAME
1. Enforcement responses to initial Stormwater Violations will be initiated within THIRTY 
(30) days of discovery or at the discretion of the Environmental Services SECTION 
Manager. Whenever use of an NOV as an enforcement response is selected, immediate 
issuance is allowed.

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2. When appropriate, follow-up inspections will occur within ten (10) days of a due date 
specified in a NOV.
3. Follow-up escalated action for repeat or REOCCURRING offenses will be taken within 
THIRTY (30) days of discovery of the repeat or REOCCURRING offenses and may 
include additional administrative enforcement, including AOs and administrative fines, 
and judicial enforcement.
4. In emergency situations caused by violations, including imminent danger to the public 
health, safety, or welfare, and endangerment to City personnel or the environment, the 
PUBLIC WORKS Director or their delegated representative may initiate enforcement 
responses, including without limitation:
a.
Issuance of cease and desist orders;
b. Water or wastewater service termination;
c.
Revocation or termination of any permits issued by the PUBLIC WORKS 
Department;
d. At the recommendation of the PUBLIC WORKS Director to another Department 
Director, termination of permits issued by that respective Department.
5. A PERSON THAT HAS BEEN SUBJECT TO ENFORCEMENT ACTION UNDER 
THIS ERP MAY REQUEST AN ADMINISTRATIVE APPEAL. 
6. AN ADMINISTRATIVE APPEAL SHALL NOT BE A BAR AGAINST, OR 
PREREQUISITE FOR, TAKING ANY OTHER ACTION AGAINST THE PERSON.
7. THE PUBLIC WORKS DIRECTOR MAY ENTER INTO AN AGREEMENT WITH A 
RESPONSIBLE PARTY OR PERSON SUBJECT TO ENFORCEMENT UNDER THIS 
ERP. 
STORMWATER RETENTION
INVESTIGATION OF NONCOMPLIANCE WILL BE CONDUCTED BY THE 
ENVIRONMENTAL SERVICES SECTION STAFF. THE METHODS USED TO 
INVESTIGATE AND TO DETERMINE NONCOMPLIANCE MAY INCLUDE, BUT ARE 
NOT LIMITED TO:
1. RESPOND TO COMPLAINTS RECEIVED FROM THE PUBLIC;
2. ON-SITE INSPECTIONS OF USER, INCLUDING SCHEDULED AND 
UNSCHEDULED VISITS;
3. CONDUCT SURVEILLANCE OF ACTIVITY TO VERIFY COMPLIANCE AND 
RECORD ACTIVITY THAT IS NON-COMPLIANT WITH T.C.C.; 
4. SCHEDULED AND UNSCHEDULED SAMPLING OF PROCESS AND/OR 
DOMESTIC RUNOFF;
5. REVIEW APPLICABLE DATA, RECORDS AND SAMPLING ANALYSIS 
RESULTS.

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THE CITY’S ENFORCEMENT RESPONSE TO ANY VIOLATION OF CHAPTER 12, 
ARTICLE IV, MAY INCLUDE, BUT IS NOT LIMITED TO, THE FOLLOWING: 
 
1. CONTACT BY INSPECTOR; 
2. PROVIDE EDUCATIONAL MATERIAL OF BMP AND T.C.C. REQUIREMENTS 
AND/OR PROHIBITIONS; 
3. WL;   
4. NOV WITH ACCOMPANYING AO, WHICH MAY INCLUDE: 
a) AFFIRMATIVE OBLIGATIONS; 
b) OTHER APPROPRIATE ORDERS; 
5. ADMINISTRATIVE FINES; 
6. EMERGENCY SUSPENSION OR TERMINATION OF SERVICE; 
7. HEARING TO SHOW CAUSE; 
8. JUDICIAL ENFORCEMENT ACTION, INCLUDING INJUNCTIVE RELIEF AND 
CRIMINAL PROSECUTION. 
 
ENFORCEMENT TIME FRAME 
 
1. ENFORCEMENT RESPONSES TO INITIAL STORMWATER VIOLATIONS WILL 
BE INITIATED WITHIN THIRTY (30) DAYS OF DISCOVERY OR AT THE 
DISCRETION OF THE ENVIRONMENTAL SERVICES SECTION MANAGER.  
WHENEVER USE OF AN NOV AS AN ENFORCEMENT RESPONSE IS 
SELECTED, IMMEDIATE ISSUANCE IS ALLOWED. 
2. WHEN APPROPRIATE, FOLLOW-UP INSPECTIONS WILL OCCUR WITHIN 
SIXTY (60) DAYS OF A DUE DATE SPECIFIED IN A NOV.  
3. FOLLOW-UP ESCALATED ACTION FOR REPEAT OR REOCCURRING 
OFFENSES WILL BE TAKEN WITHIN THIRTY (30) DAYS OF DISCOVERY OF 
THE REPEAT OR REOCCURRING OFFENSES AND MAY INCLUDE 
ADDITIONAL ADMINISTRATIVE ENFORCEMENT, INCLUDING AOS AND 
ADMINISTRATIVE FINES, AND JUDICIAL ENFORCEMENT. 
4. IN EMERGENCY SITUATIONS CAUSED BY VIOLATIONS, INCLUDING 
IMMINENT DANGER TO THE PUBLIC HEALTH, SAFETY, OR WELFARE, AND 
ENDANGERMENT TO CITY PERSONNEL OR THE ENVIRONMENT, THE 
PUBLIC WORKS DIRECTOR ORDELEGATED REPRESENTATIVE MAY 
INITIATE ENFORCEMENT RESPONSES, INCLUDING WITHOUT LIMITATION: 
a.
ISSUANCE OF CEASE-AND-DESIST ORDERS; 
b. WATER OR WASTEWATER SERVICE TERMINATION; 
c.
REVOCATION OR TERMINATION OF ANY PERMITS ISSUED BY THE;
d. AT THE RECOMMENDATION OF THE TO ANOTHER DEPARTMENT 
DIRECTOR, TERMINATION OF PERMITS ISSUED BY THAT RESPECTIVE 
DEPARTMENT.

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5. PURSUANT TO CHAPTER 12-72, A PERSON THAT HAS BEEN SUBJECT TO 
ENFORCEMENT ACTION UNDER THIS ERP MAY REQUEST AN 
ADMINISTRATIVE APPEAL.
6. AN ADMINISTRATIVE APPEAL SHALL NOT BE A BAR AGAINST, OR 
PREREQUISITE FOR, TAKING ANY OTHER ACTION AGAINST THE PERSON.
7. THE PUBLIC WORKS DIRECTOR MAY ENTER INTO AN AGREEMENT WITH A 
RESPONSIBLE PARTY OR PERSON SUBJECT TO ENFORCEMENT UNDER THIS 
ERP.

17
VIII.
POINTS ASSESSMENT CRITERIA
INTRODUCTION
In order to apply enforcement in an equitable and consistent manner, violation points have been 
developed for each classification of violation (See Table B). Points for violations have been assigned 
depending upon the severity of the violation; the potential for environmental, public, or employee harm; 
facility damage that may result from a violation; and/or the cost of the violation to the City and its 
operations. Each violation by an RP shall result in points being assigned to that RP.  
When an RP’s total points in any two consecutive quarters equals or exceeds 4.0 points, administrative 
fines will be assessed against the RP. The fines will be assessed in the amounts specified on Table A. 
ASSESSMENT OF POINTS
A. IF A VIOLATION IS DISCOVERED, THE CITY MAY ISSUE THE RP, AN NOV AND 
SET FORTH POINTS ASSESSED AND THE POTENTIAL ENFORCEMENT PENALTIES 
UNDER THIS ERP.  
B. Significant noncompliance (SNC) is calculated at the end of every quarter for the six (6) 
months preceding the end of the quarter:
Compliance Review Date(s)
Period of Review
April 
October 1 of previous year through March 31 of current year
July 
January 1 through June 30 of current year 
October 
April 1 through September 30 of current year
January 
July 1 through December 31 of previous year
C. When the total number of points equals or exceeds four (4) points during any two consecutive 
quarters, the PUBLIC WORKS Director or their delegated representative shall assess 
administrative fines consistent with this ERP and determine other appropriate enforcement 
actions which may include revocation of the permit, if applicable; publication of those in SNC; 
and/or termination of service or cease and desist orders.
D. If a permit or property is conveyed, points associated with that permit or property do not 
convey to the new permit holder or owner unless the new holder/owner is related to the 
previous holder/owner or unless it appears that the conveyance is an attempt to avoid 
enforcement. Determinations pursuant to this Section D shall be at the sole discretion of the 
PUBLIC WORKS Director. 
E. A single operational upset or activity, which leads to simultaneous violations of more than one 
pollutant parameter, may be treated as a single violation for point assessment, provided there is 
no harm caused.

18
IX.
ADMINISTRATIVE FINE SCHEDULE
ADMINISTRATIVE FINES FOR POINTS ASSESSED
As a result of SNC, when an RP is assigned four (4) points or more during any consecutive two-quarter 
period, the PUBLIC WORKS Director or their delegated representative will assess an administrative 
fine with a base value of $2,500.00. 
In addition to the base administrative fine, each quarter (0.25) point assessed in excess of FOUR (4) 
points shall be assigned a dollar value of $156.25. For each quarter point, the following values will be 
applied: 
TABLE A – ADMINISTRATIVE FINE SCHEDULE
POINTS
0.25
0.50
0.75
1.0
1.25
1.50
1.75
2.0
FINE
$156.25
$312.50
$468.75
$625.00
$781.25
$937.50
$1,093.75
$1,250.00
POINTS
2.25
2.50
2.75
3.0
3.25
3.50
3.75
4.0
FINE
$1,406.25
$1,562.50
$1,718.75
$1,875.00
$2,031.25
$2,187.50
$2,343.75
$2,500.00
Following an SNC and the imposition of the base fine, each subsequent violation during the same 
consecutive two-quarter period shall be assessed a fine based on the quarter-point increment schedule.  
For subsequent violations, all points assessed during the two-quarter period are used to determine 
whether a penalty will be assessed, but the amount of the penalties are only assessed on points for which 
penalties were not previously assigned; i.e., no double billing for points assessed. At any time, the 
accumulated points total less than four points for any consecutive two-quarter period, fines will not be 
assessed for that period.
Data used to determine compliance shall be maintained in accordance with the City’s record retention 
policy and applicable state or federal regulations.  
RECONSIDERATION OF THE FINEAPPEAL OF ADMINISTRATIVE FINES
If the RP desires to dispute an assessed administrative fine, the RP must file a written request for the 
PUBLIC WORKS Director to reconsider the administrative fine along with full payment of the 
administrative fine within FIFTEEN (15) days of being notified of the fine.  
PUBLICATION OF RP IN SIGNIFICANT NONCOMPLIANCE
The PUBLIC WORKS Director shall publish at least annually in a newspaper of general circulation a list 
of RPs which, at any time since the list was last published, were in SNCTHAT HAVE BEEN IN SNC AT 
ANY TIME SINCE THE LAST PUBLICATION. 
Industrial Users found to be in SNC shall be published in accordance with 40 CFR 403.8(f)(2)(viii)(A-H).

19
TABLE B – HHEP VIOLATIONS
Any violation of ordinance not specified in Table B may be awarded points at the discretion of the PUBLIC 
WORKS Director.
The description of the violation is for ease of reference only.  For the specific violation, consult the corresponding 
ordinance section cited.
Table B, Part 1:  Cross Connection Control Violations
Code   
Violation
Points    Enforcement 
Response
Code Reference
CC-1
Incorrect installation of assembly 
1.0
WL, NOV, AO
§ 33-104(a)
CC-2
Incorrect size of assembly installed
1.0
WL, NOV, AO
§ 33-104(b)
CC-3
Installation of by-pass around assembly 
4.0
WL, NOV, AO
§ 33-104(c)
CC-4
Incorrect type of assembly and/or valves installed
1.0
WL, NOV, AO
§ 33-104(d-f)
CC-5
Installation of a non-approved assembly
1.0
WL, NOV, AO
§ 33-106 
CC-6
Failure to install assembly after notification issued – 
1st occurrence
2.0
WL, NOV, AO
§ 33-110(b)
CC-7
Failure to install assembly after notification issued – 
2nd occurrence
2.0
WL, NOV, AO
§ 33-110(b)
CC-8
Failure to install assembly after notification issued – 
3rd occurrence, discontinuance of service
4.0
NOV, AO, 
Termination of 
Services 
§ 33-110(b)
§ 33-109
CC-9
Failure to maintain records of tests and/or repair
1.0
WL, NOV, AO
§ 33-107(a)
CC-10
Failure to conduct annual testing  - 1st occurrence 
2.0
WL, NOV, AO
§ 33-107(b)
CC-11
Failure to conduct annual testing  - 2nd occurrence
2.0
WL, NOV, AO
§ 33-107(b)
CC-12
Failure to conduct annual testing – 3rd occurrence
4.0
NOV, AO, 
Termination of 
Services
§ 33-107(b)
CC-13
Failure to notify of testing
1.0
WL, NOV, AO
§ 33-107(c)
CC-14
Failure to conduct initial test 
1.0
WL, NOV, AO
§ 33-107(b)
CC-15
Failure to conduct test by certified tester
1.0
WL, NOV, AO
§ 33-107(d)
CC-16
Failure to re-test after repair, etc., of assembly
2.0
WL, NOV, AO
§ 33-107(e)
CC-17
Failure to maintain system open for inspection
2.0
WL, NOV, AO
§ 33-108

20
Table B, Part 2:  Pretreatment Violations
Code   
Violation
Points    Enforcement 
Response
Code Reference
P-1
Allow a prohibited discharge into the POTW which 
causes pass through or interference – 1st occurrence.  
2.0
WL, NOV, AO
§ 27-10(a)
P-2
Allow a prohibited discharge into the POTW which 
causes pass through or interference – 2nd occurrence 
within any two consecutive quarters. 
4.0
WL, NOV, AO
§ 27-10(a)
P-3
Allow a prohibited discharge into the POTW – 1st 
occurrence.
2.0
WL, NOV, AO
§ 27-10(b)(1-19)
P-4
Allow a prohibited discharge into the POTW – 2nd 
occurrence within any two consecutive quarters.
4.0
NOV, AO
§ 27-10(b)(1-19)
P-5
Discharge from nondomestic source without a 
permit.
2.0
WL, NOV, AO
§ 27-10(c)
P-6
Discharge from nondomestic source without a 
permit – 2nd occurrence within any two consecutive 
quarters. 
4.0
WL, NOV, AO
§ 27-10(c)
P-7
Processing or storage of a prohibited pollutant, 
substance, or wastewater prohibited by Article I 
which could be discharged into POTW. 
2.0
WL, NOV, AO
§ 27-10(c)(2)
P-8
Violation of Local or Categorical limit - 1st 
occurrence. 
2.0
WL, NOV, AO
§ 27-11
§ 27-12
P-9
Violation of Local or Categorical limit - 2nd 
occurrence within any two consecutive quarters. 
2.0
WL, NOV, AO
§ 27-11
§ 27-12
P-10
Violation of Local or Categorical limit - 3rd 
occurrence within any two consecutive quarters. 
4.0
NOV, AO
§ 27-11
§ 27-12
P-11
Use of process water to dilute discharge as a partial 
or complete substitute to adequate treatment – 1st 
occurrence. 
2.0
WL, NOV, AO
§ 27-14
P-12
Use of process water to dilute discharge as a partial 
or complete substitute to adequate treatment – 2nd 
occurrence within any two consecutive quarters. 
4.0
NOV, AO
§ 27-14
P-13
Tamper, damage, or destroy monitoring equipment. 
4.0
NOV, AO 
Revocation of permit
§ 27-15(a)
§ 27-46(5)
P-14
Tamper with manhole or unauthorized entry into 
POTW.
2.0
NOV, AO, CEASE 
and DESIST
§ 27-15(b)
P-15
Tamper with manhole or unauthorized entry into 
POTW – 2nd occurrence within any two consecutive 
quarters.
4.0
NOV, AO, CEASE 
and DESIST
§ 27-15(b)
P-16
Tamper with pretreatment device – 1st occurrence.
2.0
NOV, AO, CEASE 
and DESIST
§ 27-15(c)
P-17
Tamper with pretreatment device – 2nd occurrence 
within any two consecutive quarters. 
4.0
NOV, AO, CEASE 
and DESIST
§ 27-15(c)
P-18
Failure to provide pretreatment facilities. 
1.0
WL, NOV, AO
§ 27-21 or §27-22
P-19
Failure to restrict discharge during peak flow period.
1.0
WL, NOV, AO
§27-22(a)
P-20
Failure to install suitable storage and flow control 
equipment as directed by the PUBLIC WORKS 
Director.
1.0
WL, NOV, AO
§ 27-22(B)

21
P-21
Failure to properly maintain pretreatment equipment 
– 1st occurrence. 
1.0
WL, NOV, AO
§ 27-22(c)
P-22
Failure to properly maintain pretreatment equipment 
– 2nd occurrence in any two consecutive quarters. 
2.0
WL, NOV, AO
§ 27-22(c)
P-23
Failure to properly maintain pretreatment equipment 
– 3rd occurrence in any two consecutive quarters.
4.0
WL, NOV, AO
§ 27-22(c)
P-24
Failure to maintain cleaning and maintenance 
records – 1st occurrence. 
1.0
WL, NOV, AO
§ 27-22(c)
P-25
Failure to maintain cleaning and maintenance 
records – 2nd occurrence within any two consecutive 
quarters.
2.0
WL, NOV, AO
§ 27-22(c)
P-26
Failure to maintain cleaning and maintenance 
records – 3rd occurrence within any two consecutive 
quarters.
4.0
WL, NOV, AO
§ 27-22(c)
P-27
Failure to develop and/or implement accidental 
discharge/slug control plan – 1st occurrence. 
1.0
WL, NOV, AO
§ 27-23
P-28
Failure to develop and/or implement accidental 
discharge/slug control plan – 2nd occurrence within 
any two consecutive quarters.
2.0
WL, NOV, AO
§ 27-23
P-29
Failure to develop and/or implement accidental 
discharge/slug control plan – 3rd occurrence within 
any two consecutive quarters.
4.0
WL, NOV, AO
§ 27-23
P-30
Discharge of hauled waste into POTW without 
discharge permit – 1st occurrence. 
4.0
NOV, AO, CEASE 
and DESIST
§ 27-24
P-31
Illegal disposal of pretreatment sludge and other 
material.
4.0
NOV, AO, CEASE 
and DESIST
§ 27-25
P-32
Failure to submit wastewater analysis within forty-
five (45) days of request – 1st occurrence. 
1.0
WL, NOV, AO
§ 27-31
P-33
Failure to submit wastewater analysis within forty-
five (45) days of request – 2nd occurrence within any 
two consecutive quarters.
2.0
WL, NOV, AO
§ 27-31
P-34
Failure to submit wastewater analysis within forty-
five (45) days of request – 3rd occurrence within any 
two consecutive quarters.
4.0
WL, NOV, AO
§ 27-31
P-35
Failure to submit information required by T.C.C. 
Section 27-32(B).
1.0
WL, NOV, AO
§ 27-32
P-36
Failure to obtain wastewater discharge permit - 
discharge occurring.
2.0
WL, NOV, AO
§ 27-33 or § 27-
34
P-37
Failure to notify PUBLIC WORKS Director of 
significant changes to wastewater prior to changed 
discharge.
4.0
WL, NOV, AO, 
REVOCATION OF 
PERMIT
§ 27-46(1)
P-38
Failure to provide prior notification to the PUBLIC 
WORKS Director of changed conditions.
4.0
WL, NOV, AO, 
REVOCATION OF 
PERMIT
§ 27-46(2)
P-39
Misrepresentation or failure to fully disclose all 
relevant facts in wastewater discharge permit 
application.
4.0
WL, NOV, AO, 
REVOCATION OF 
PERMIT
§ 27-46(3)
P-40
Falsifying self-monitoring reports.  
4.0
WL, NOV, AO, 
REVOCATION OF 
PERMIT
§ 27-46(4)

22
P-41
Refusing to allow the PUBLIC WORKS Director 
timely access to the facility premises and records.
4.0
WL, NOV, AO, 
REVOCATION OF 
PERMIT
§ 27-46(6)
§ 27-71
P-42
Failure to meet effluent limitations.
4.0
WL, NOV, AO, 
REVOCATION OF 
PERMIT
§ 27-46(7)
P-43
Failure to pay fines.
4.0
WL, NOV, AO, 
REVOCATION OF 
PERMIT
§ 27-46(8)
P-44
Failure to pay sewer charges.
4.0
WL, NOV, AO, 
REVOCATION OF 
PERMIT
§ 27-46(9)
P-45
Failure to meet compliance schedules.
4.0
WL, NOV, AO, 
REVOCATION OF 
PERMIT
§ 27-46(10)
P-46
Failure to complete a wastewater survey or the 
wastewater discharge permit application.
4.0
WL, NOV, AO, 
REVOCATION OF 
PERMIT
§ 27-46(11)
P-47
Failure to provide advance notice of the transfer of 
business ownership of a permitted facility.
4.0
WL, NOV, AO, 
REVOCATION OF 
PERMIT
§ 27-46(12)
P-48
Violation 
of 
any 
pretreatment 
standard 
or 
requirement, or any terms of the wastewater 
discharge permit or this article.
4.0
WL, NOV, AO, 
REVOCATION OF 
PERMIT
§ 27-46(13)
P-49
Failure to immediately notify of potential problems.
1.0
WL, NOV, AO
§ 27-56(a)
P-50
Failure to submit detailed written report within 5 days 
following discharge Violation.
1.0
WL, NOV, AO
§ 27-56(b)
P-51
Failure to post notification information of POTW in 
the event of an accidental discharge, non-routine 
discharge, or slug load which may impact the POTW.
2.0
WL, NOV, AO
§ 27-56(c)
P-52
Failure to notify PUBLIC WORKS DIRECTOR 
within 24 hours of becoming aware of Violation – 1st 
occurrence. 
1.0
WL, NOV, AO
§ 27-58
P-53
Failure to notify PUBLIC WORKS Director within 
24 hours of becoming aware of Violation – 2nd 
occurrence within any two consecutive quarters. 
2.0
WL, NOV, AO
§ 27-58
P-54
Failure to notify PUBLIC WORKS Director within 
24 hours of becoming aware of Violation – 3rd 
occurrence within any two consecutive quarters. 
4.0
WL, NOV, AO
§ 27-58
P-55
Failure to notify of discharge of hazardous waste.
2.0
WL, NOV, AO
§ 27-59
P-56
Improper test method conducted – 1st occurrence. 
1.0
WL, NOV, AO
§ 27-60
P-57
Improper test method conducted – 2nd occurrence 
within any two consecutive quarters.
2.0
WL, NOV, AO
§ 27-60
P-58
Improper test method conducted – 3rd occurrence 
within any two consecutive quarters.
4.0
WL, NOV, AO
§ 27-60
P-59
Failure to apply for renewal of discharge permit 
within 30 days of permit expiration. 
2.0
WL, NOV, AO
§ 27-47
P-60
Failure to apply for renewal of discharge permit 
within 30 days of permit expiration – 2nd notice.
4.0
WL. NOV, AO
§ 27-47

23
P-61
VIOLATION OF UTILIZING A GARBAGE 
DISPOSAL/GRINDER 
TO 
INTRODUCE 
LIQUIFIED SOLID WASTE CAUSING PASS 
THROUGH OR INTERFERENCE TO THE POTW 
– 1ST OCCURRENCE
1.0
WL, NOV, AO
§ 27-22(d)
P-62
VIOLATION OF UTILIZING A GARBAGE 
DISPOSAL/GRINDER 
TO 
INTRODUCE 
LIQUIFIED SOLID WASTE CAUSING PASS 
THROUGH OR INTERFERENCE TO THE POTW 
–  2ND OCCURRENCE
2.0
WL, NOV, AO
§ 27-22(d)
P-63
VIOLATION OF UTILIZING A GARBAGE 
DISPOSAL/GRINDER 
TO 
INTRODUCE 
LIQUIFIED SOLID WASTE CAUSING PASS 
THROUGH OR INTERFERENCE TO THE POTW 
– 3RD OCCURRENCE
4.0
WL, NOV, AO
§ 27-22(d)
P-64
VIOLATION OF UTILIZING A DISHWASHER 
WITHOUT PROPER PRETREATMENT DEVICE 
CAUSING 
PASS 
THROUGH 
OR 
INTERFERENCE 
TO 
THE 
POTW 
– 
1ST 
OCCURRENCE
1.0
WL, NOV, AO
§ 27-22(c)
P-65
VIOLATION OF UTILIZING A DISHWASHER 
WITHOUT PROPER PRETREATMENT DEVICE 
CAUSING 
PASS 
THROUGH 
OR 
INTERFERENCE 
TO 
THE 
POTW 
– 
2ND 
OCCURRENCE
2.0
WL, NOV, AO
§ 27-22(c)
P-66
VIOLATION OF UTILIZING A DISHWASHER 
WITHOUT PROPER PRETREATMENT DEVICE 
CAUSING 
PASS 
THROUGH 
OR 
INTERFERENCE 
TO 
THE 
POTW 
– 
3RD 
OCCURRENCE
4.0
NOV, AO
§ 27-22(c)
P-67
FAILURE 
TO 
SUBMIT 
A 
BASELINE 
MONITORING REPORT.
4.0
NOV, AO
§ 27-51 (b)
P-68
FAILURE 
TO 
SUBMIT 
A 
REQUESTED 
PROGRESS REPORT ON A COMPLIANCE 
SCHEDULE.
4.0
NOV, AO
§ 27-52
P-69
FAILURE 
TO 
SUBMIT 
A 
ONE-TIME 
COMPLIANCE REPORT UNDER THE DENTAL 
AMALGAM RULE.
4.0
NOV, AO
§ 27-22(g) 
P-70
FAILURE TO PAY TGC INVOICE – 1ST 
OCCURRENCE
1.0
WL, NOV, AO
§ 27-21(C)
RULES AND 
PROCEDURES 
P-71
FAILURE TO PAY TGC INVOICE – 2ND 
OCCURRENCE
2.0
NOV, AO, 
SUSPENSION OF 
TGC SERVICES
§ 27-21(C)
RULES AND 
PROCEDURES
P-72
FAILURE TO PAY TGC INVOICE – 3RD 
OCCURRENCE
4.0
NOV, AO, SENT TO 
COLLECTIONS, 
REMOVED FROM 
TGC FOR ONE 
YEAR
§ 27-21(C)
RULES AND 
PROCEDURES

24
Table B, Part 3:  Stormwater Violations
Code   
Violation
Points    Enforcement 
Response
Code Reference
SW-1
Discharging any substance to the public right-of-
way and/or the public storm drain system that is not 
composed entirely of storm water – 1st occurrence.
2.0
Provide BMP 
pamphlet, WL, NOV, 
AO
§ 12-125(a)
SW-2
Discharging any substance to the public right-of-
way and/or the public storm drain system that is not 
composed entirely of storm water – 2nd or greater 
occurrence.
4.0
WL, NOV, AO
§ 12-125(a)
SW-3
Improper use, storage, spill, dump of material in a 
manner which could cause or contribute to the 
addition of pollutants to the storm system – 1st 
occurrence.
2.0
WL, NOV, AO
§ 12-125(b)
SW-4
Improper use, storage, spill, dump of material from 
a commercial/industrial activity in a manner which 
could cause or contribute to the addition of 
pollutants to the storm system – 2nd or greater 
occurrence within any two consecutive quarters.
4.0
NOV, AO
§ 12-125(b)
SW-5
Establishment, use, maintenance, or continuance of 
any connection to the public storm sewer system 
which has caused or will likely cause a violation.
2.0
WL, NOV, AO
§ 12-125(f)
SW-6
Failure to remove any connection to the public 
storm drain system after written notification has 
been issued as required by §12-125(f).
2.0
WL, NOV, AO
§ 12-125(f)
SW-7
Failure to clean up any release or discharge which 
may result in pollutant(s) entering the public storm 
drain system.
2.0
WL, NOV, AO
§ 12-126(a)
SW-8
Failure to notify the City of discharge or release of 
pollutant into the public storm drain system.
2.0
WL, NOV, AO
§ 12-126(b)
SW-9
Failure to implement BMP(s) (non-construction).
1.0
WL, NOV, AO
§ 12-127 
SW-10
Failure to implement BMP(s) (construction).
2.0
WL, NOV, AO
§ 12-128
SW-11
Discharge of exempt discharges that are determined 
to be a significant source of pollutants or could 
place the City in violation with its AZPDES Permit. 
2.0
WL, NOV, AO
§ 12-125(c)
SW-12 
FAILURE TO MAINTAIN DRAINAGE 
INFRASTRUCTURE TO MEET DESIGN 
CAPACITY.  
4.0 
WL, NOV, 
PROVIDE 3RD 
PARTY CERTIFIED 
INSPECTION 
§ 12-86(E)
OR § 12-89(C)  
SW-13
FAILURE TO INSPECT AND/OR MAINTAIN 
RECORDS OF INSPECTIONS – 1ST 
OCCURRENCE
1.0 
WL, NOV 
§ 12-86(E)
§ 12-89(C)(1)
CITY OF 
TEMPE 
ENGINERING 
DESIGN 
CRITERIA
DECLARATION 
OF 
MAINTENANCE

25
FOR 
INSPECTION 
AND 
MAINTENANCE 
OF DRAINAGE
SW-14
FAILURE TO INSPECT AND/OR MAINTAIN 
RECORDS OF INSPECTIONS – 2ND 
OCCURRENCE WITHIN ANY TWO 
CONSECUTIVE QUARTERS.
2.0 
WL, NOV 
§ 12-86(E)
§ 12-89(C)(1)
CITY OF 
TEMPE 
ENGINERING 
DESIGN 
CRITERIA
DECLARATION 
OF 
MAINTENANCE  
FOR 
INSPECTION 
AND 
MAINTENANCE 
OF DRAINAGE
SW-15
FAILURE TO MEET NOV PLAN FOR 
CORRECTION
4.0
NOV, AO
§ 12-92

26
TABLE B, PART 4:  AIR QUALITY VIOLATIONS
CODE   VIOLATION
POINTS  ENFORCEMENT 
RESPONSE
CODE 
REFERENCE
AQ-1
USE A LEAF BLOWER TO BLOW LEAVES, 
GRASS CUTTINGS, OTHER LANDSCAPE 
DEBRIS, TRASH, SOIL OR DUST INTO A 
PUBLIC ROADWAY - 1ST OCCURRENCE.
2.0
WL, NOV, AO
§ 13A-52(A)
AQ-2
USE A LEAF BLOWER TO BLOW LEAVES, 
GRASS CUTTINGS, OTHER LANDSCAPE 
DEBRIS, TRASH, SOIL OR DUST INTO A 
PUBLIC ROADWAY - 2ND OCCURRENCE.
4.0
WL, NOV, AO
§ 13A-52(A)
AQ-3
OPERATE A LEAF BLOWER EXCEPT ON 
SURFACES THAT HAVE BEEN 
STABILIZED - 1ST OCCURRENCE.
2.0
WL, NOV, AO
§ 13A-52(B)
AQ-4
OPERATE A LEAF BLOWER EXCEPT ON 
SURFACES THAT HAVE BEEN 
STABILIZED. 2ND OCCURRENCE.
4.0
WL, NOV, AO
§ 13A-52(B)
AQ-5
 OPERATE A LEAF BLOWER DURING 
ANY HIGH POLLUTION ADVISORY DAY 
FORECAST FOR PARTICULATE MATTER 
- 1ST OCCURRENCE.
2.0
WL, NOV, AO
§ 13A-52(C)
AQ-6
 OPERATE A LEAF BLOWER DURING 
ANY HIGH POLLUTION ADVISORY DAY 
FORECAST FOR PARTICULATE MATTER 
2ND OCCURRENCE.
4.0 
WL, NOV, AO
§ 13A-52(C)