ENV TASK FORCE FINAL REPORT TO BOS_10.20.25_DRAFT.DOCX

Environmental Services Department
301 W. Jefferson St., Suite 170 
Phoenix, Arizona 85003
P: 602.506.6616
Maricopa.gov/Enviro
ENVIRONMENTAL SERVICES DEPARTMENT AD HOC STAKEHOLDER TASK FORCE FINAL REPORT
With the direction of the Board, an ad hoc task force committee was formed to review the service level and processes of the 
Environmental Services Department (ESD). At the invitation of Chairman Galvin, key stakeholders, comprised of a diverse 
group of professionals who are interested and involved in the services provided by ESD's Water & Wastewater Treatment and 
Subdivision Programs, participated in a kickoff meeting on June 17, 2025. There was an active, open discussion of the 
department’s strengths and identification of areas for review and improvement.
Based on the discussion items from the initial meeting, two (2) subcommittees were formed to develop improvement 
recommendations: Process/Permit Center and Standards/Scope. The subcommittee members met biweekly starting on June 
26, 2025. During the first meeting, each subcommittee selected a chairperson to lead and focus the group’s efforts. As the 
subcommittees worked through the areas of interest, key staff provided support by preparing notes and providing information 
on current processes, reference material, and organizational history.
Once each subcommittee had formalized its recommendations, the task force reconvened on August 21, 2025. At this time, the 
chairpersons from each subcommittee presented their respective recommendations to gain consensus from all the members. 
As a result of their commitment to the process and intense efforts, 40 recommendations were developed.
Due to the nature and scope of the recommendations, staff have been proactive in working to implement many of the
recommendations. For those recommendations that require additional time, resources, and further stakeholder input, a phased 
implementation schedule has been proposed.
Below is a high-level summary of those recommended actions being submitted to the Maricopa County Board of Supervisors 
for review and consideration.

Environmental Services Department
301 W. Jefferson St., Suite 170 
Phoenix, Arizona 85003
P: 602.506.6616
Maricopa.gov/Enviro
Process/Permit Center Recommendations
Issues Reviewed:
Recommendation(s) & Supporting Information:
Status:
1.  Lack of communication regarding new 
requirements and procedures for Subdivision 
Program submittals can cause delays.
A)
Provide advanced notification of proposed 
process changes before they are implemented 
via the WaterWorks bulletin. The notifications 
will provide an opportunity for stakeholder input 
prior to implementation. The bulletin will be 
distributed via email, text, and the website at 
least quarterly, or as often as needed to ensure 
timely communication of changes.
B)
Communicate process and regulatory changes 
within Permit Center (i.e., on the landing page 
after logging in).
C) Create guidance documents for each of the 
permit types (water ATC/AOC, sewer 
ATC/AOC, reclaimed water ATC/AOC). These 
guidance documents will include:

References to the relevant codes and 
standards,

Description of the required submittal 
documents,
A)  In Progress – Creation of the 
WaterWorks bulletin template has 
started, and initial topics have been 
identified. Feedback from 
stakeholders will be solicited in 
advance for any topics that include 
a change or update to processes 
that will affect stakeholders. The 
first Waterworks bulletin is expected 
to be distributed by October 31, 
2025.
B)   In Progress – A link to the 
WaterWorks bulletin will be placed 
on the permit application pages 
within Permit Center to direct 
stakeholders to potential past and 
current process and regulatory 
changes. Anticipated completion 
date of December 31, 2025.
C)   In Progress – Guidance documents 
will be created and published on our 
website for each of the permit types. 
Anticipated completion date of 
December 31, 2025.

Environmental Services Department
301 W. Jefferson St., Suite 170 
Phoenix, Arizona 85003
P: 602.506.6616
Maricopa.gov/Enviro

Plan and report requirements not explicitly 
mentioned in code, and

Common deficiencies.

A link to this document will be provided on 
the first screen of every permit type.
D)
Hold annual stakeholder meeting to review 
updates, introduce staff, and discuss 
stakeholder topics of interest.
D)  In Progress – An annual stakeholder 
meeting will be scheduled by 
10/31/25. The first meeting will take 
place in the fourth quarter of 2026.
2.  Clarify or simplify when there is a 
jurisdictional issue with a project crossing 
multiple jurisdictional boundaries (e.g., a 
project in the City of Phoenix that passes 
through MCDOT ROW).
A)   Create a process whereby all environmental 
reviews for any water/wastewater infrastructure 
projects serving projects within the City of 
Phoenix are deferred to the City of Phoenix 
health delegate, even when that infrastructure 
crosses through or runs within right-of-way 
owned by Maricopa County.
A)   In Progress – A meeting will be set 
up with the City of Phoenix (COP) to 
solidify a process for COP to have 
full jurisdiction of environmental 
reviews that are majority located 
within COP but cross into County 
land. Anticipated completion date of 
December 31, 2025.
3.   When preparing for the AOC, there is no 
documentation of allowable 
design/construction tolerances. 
A) Work with MAG to compile a list of allowable 
tolerances from the MAG Uniform Standard 
Specifications and Standard Details for Public 
Works Construction. Solicit stakeholder 
feedback during the development and 
finalization of this list.
B) Publish the list of allowable tolerances on 
MCESD’s website.
A)    In Progress – MCESD will begin 
coordination efforts with MAG by 
November 21, 2025, with the goal 
of creating a final list of allowable 
tolerances by June 30, 2026.
B)    In Progress – List of allowable 
tolerances anticipated to be 
published on MCESD’s website by 
June 30, 2026.
4. Enhance human support for Permit Center 
and permitting inquiries.
 
A)   Create a “help needed” link on the first page of 
each permit type in Permit Center. This link will 
provide customers with the email and phone 
number of administrative support staff who can 
provide assistance specific to the permit type.
A)    In Progress – A directory will be 
created for staff assistance and 
published on the MCESD website. 
A link to the directory will be 
created on the Permit Center

Environmental Services Department
301 W. Jefferson St., Suite 170 
Phoenix, Arizona 85003
P: 602.506.6616
Maricopa.gov/Enviro
B) Add a general department email address to the 
auto-generated notifications from Permit 
Center.
C) Rename the Permitting Services Coordinator 
position so that customers better understand 
this person’s role. 
D) Include the Permitting Services Coordinator 
contact information in each WaterWorks 
bulletin, along with a brief explanation of this 
person’s role and backup contact. 
E)
Develop a procedure that outlines when staff 
should initiate and/or offer assistance to 
customers from the Permitting Services 
Coordinator. 
application pages. Anticipated 
completion date of December 31, 
2025.
B)    In Progress – The program-specific 
email address or link to the overall 
directory will be added to Permit 
Center email notifications. 
Anticipated completion date of 
December 31, 2025.
C)    Completed – The Permitting 
Services Coordinator was renamed 
to Business & Community Liaison 
in October of 2025.
D)    In Progress - The Permitting 
Services Coordinator's contact 
information, in addition to a 
description of their role, will be 
included in the WaterWorks 
bulletin, anticipated to go out by 
October 31, 2025.
E)    In Progress - An SOP will be 
created and distributed to staff 
outlining when staff should get the 
Permitting Services Coordinator 
involved to offer customer 
assistance. Anticipated completion 
date of November 30, 2025.
5.   Customers are experiencing challenges 
setting up global access to projects in Permit 
Center
A)   Create customer training materials (i.e., 
guidance documents, videos) on how to set up 
contacts to allow multiple parties to access 
projects in Permit Center. Publish links to the 
materials in the Permit Center.
A)    In Progress – A guidance document 
for company contacts has been 
created and published online. 
Links to these materials will be 
added to all permit types within 
Permit Center by December 31, 
2025.

Environmental Services Department
301 W. Jefferson St., Suite 170 
Phoenix, Arizona 85003
P: 602.506.6616
Maricopa.gov/Enviro
B)   Develop and advertise online training sessions 
for Permit Center users in the WaterWorks 
bulletin.
C)   Explore options with Tyler Technologies to 
allow customers to update contacts for billing 
after invoicing.
D)   Develop a feature or report that allows 
customers to see which contacts pertain to 
various applications from the same entity.
B)    In Progress – Permit Center training 
sessions will be developed and 
published in the WaterWorks 
bulletin. Anticipated completion by 
December 31, 2025.
C)    In Progress – MCESD will explore 
options with Tyler Technologies to 
allow customers to update contacts 
for billing after invoicing.  
Anticipated completion by 
December 31, 2025.
D)    In Progress – It has been stated 
that Gilbert has this feature. 
MCESD will reach out to Gilbert for 
assistance on implementing this 
feature by December 31, 2025.
6.   Utilities have received requests for an 
updated Capacity Assurance (CA) letter at the 
Approval of Construction (AOC) stage, which is 
unnecessary.
A)   Modify the application in Permit Center to not 
require a Capacity Assurance letter at the 
Approval of Construction (AOC) stage.
A)    In Progress – The manual process 
of removing this requirement from 
all converted permit records has 
begun.  Anticipated completion by 
February 28, 2026.
7.   The Approval of Proposed Plan (AOPP) is 
used as a catch-all for projects without a 
defined permit. The AOPP process needs more 
clarity.
A)
Create a guidance document for internal and 
external use that explains the AOPP process 
and distinguishes when an AOPP is required as 
opposed to an ATC/AOC. Solicit stakeholder 
feedback prior to implementation. 
B)
Limit the requirement to submit an AOPP to 
only requirements explicitly outlined in the 
Arizona Administrative Code and the Maricopa 
County Environmental Health Code.
A)    In Progress – MCESD will create 
this AOPP guidance document and 
provide it to the stakeholder group 
for feedback. Anticipated 
completion date of February 28, 
2026.
B)    In Progress – The requirement to 
submit an AOPP will be limited to 
Arizona Administrative Code and 
Maricopa County Environmental 
Health Code requirements. This

Environmental Services Department
301 W. Jefferson St., Suite 170 
Phoenix, Arizona 85003
P: 602.506.6616
Maricopa.gov/Enviro
C) Develop a procedure for drafting Approval of 
Construction letters that allows for parts and 
equipment to be replaced with equivalent parts 
or equipment of the same specifications.
will be included in the AOPP 
guidance document created by 
February 28, 2026.
C)    In Progress – AOCs will be drafted 
to allow for flexibility in equipment 
and parts. An internal guidance 
document is being created to train 
staff. Anticipated completion date 
of October 31, 2025.
8.   Organizations undergo an extensive 
process to develop a treatment technique, only 
to be told that MCESD doesn’t like the 
technology selected.
A)   Advertise the pre-application meeting process 
on the County website, including instructions 
on how to request a pre-application meeting in 
Permit Center. Include specific objectives of a 
pre-application meeting for novel treatment 
techniques (i.e., discuss validation methods, 
research data, and pilot testing).
A)      In Progress – A pre-application 
meeting instructional document 
will be created and published on 
the MCESD website. Anticipated 
completion date of March 31, 
2026.
9.  Minor changes to a project come up during 
an inspection and trigger a Notice of 
Violation(NOV). It is not a major change, but 
then it's highlighted in the inspection.
A)   Establish a Treatment Technique or Process 
Failure Notification procedure. This would be 
an online procedure for the utility 
owner/operator to report to MCESD of a 
treatment or process failure that temporarily 
impacts the normal operation of a facility. 
Solicit stakeholder feedback prior to finalizing 
the procedure.
A)      In Progress – An SOP and 
Emergency Failure Form have 
been drafted. This will be 
distributed to stakeholders by 
October 31, 2025, with an 
anticipated implementation date 
by December 31, 2025.
10.  There has not been a comprehensive cost 
recovery evaluation and/or adjustment to align 
increased workloads with available resources.
A)   Start the EROP process to incorporate updated 
fees into the Maricopa County Environmental 
Health Code.
A)      Completed – The EROP process 
to update fees has been started 
with the next step of stakeholder 
workshops taking place starting 
on October 14, 2025.

Environmental Services Department
301 W. Jefferson St., Suite 170 
Phoenix, Arizona 85003
P: 602.506.6616
Maricopa.gov/Enviro
B)  Develop a procedure that outlines how the 
department will brief the Board of Supervisors 
on an updated cost-recovery study every four 
years.
B)     In Progress – Procedure will be 
developed and implemented by 
December 31, 2025.

Environmental Services Department
301 W. Jefferson St., Suite 170 
Phoenix, Arizona 85003
P: 602.506.6616
Maricopa.gov/Enviro
Standards/Scope Recommendations
Issues Reviewed:
Recommendation(s) & Supporting Information:
Status:
1.   Treatment Program often goes beyond 
the scope of Safe Drinking Water Act and 
Clean Water Act. There are duplicative 
regulatory activities for wastewater treatment 
plants between MCESD and ADEQ.
A)    Discontinue requiring ATC/AOC for wastewater 
treatment plant repairs, rehabilitation, and 
maintenance that do not impact capacity or the 
point of discharge. 
A)    In Progress – MCESD will initiate 
the EROP process to exclude 
wastewater treatment plant 
repairs, rehabilitation, and 
maintenance plan review from 
the Environmental Health Code. 
Anticipated initiation date of 
December 31, 2025.
2.    Engineer Bulletin 11 is outdated and no 
longer used by ADEQ.
A)    Initiate an EROP case to remove Engineer 
Bulletin 11 from the Maricopa County 
A)    In Progress – MCESD will initiate 
the EROP process to remove 
Engineering Bulletin 11 from the

Environmental Services Department
301 W. Jefferson St., Suite 170 
Phoenix, Arizona 85003
P: 602.506.6616
Maricopa.gov/Enviro
Environmental Health Code (MCEHC) so it is no 
longer used as a regulatory document but as a 
reference for good engineering judgment.
B)    Form a workgroup with stakeholders, including 
ADEQ, to create a list of acceptable standards 
references to guide the engineering review 
process.
C)  Create a formal process for involving the 
Permitting Services Coordinator (“ombudsman”) 
when a stakeholder disagrees with a reviewer's 
comments.
Environmental Health Code as 
a regulatory document. 
Anticipated initiation date of 
December 31, 2025.
B)    In Progress – MCESD will set up 
a workgroup including 
stakeholders and ADEQ to 
create a list of acceptable 
standards to guide the 
wastewater engineering review 
process. Anticipated to be 
formed by March 31, 2026.
C)    In Progress – An SOP will be 
created for comment 
disagreement with specifics on 
involving the Permitting 
Services Coordinator. 
Anticipated completion date of 
January 31, 2026.
3.  It would be helpful to obtain a well New 
Source Approval (NSA) at the time of AOC or 
have a longer expiration date.
A)    Discontinue the practice of having expiration 
dates on New Source Approvals (NSA).
A)    Completed – The practice of 
placing expiration dates on 
NSAs was discontinued and an 
NSA customer guidance 
document was completed in 
September of 2025.

Environmental Services Department
301 W. Jefferson St., Suite 170 
Phoenix, Arizona 85003
P: 602.506.6616
Maricopa.gov/Enviro
4.  Lead and Copper rule clarity is needed. 
There is a lack of direction on how to prepare 
the submittal to satisfy the engineer.
A)    Create a working group to include ADEQ, 
MCESD, and interested stakeholders. This 
group would review the LCR requirements and 
generate more detailed guidance documents 
and processes to address LCR.  
A)    Completed – A working group 
was formed, including ADEQ, 
MCESD and stakeholders with 
the first meeting session having 
taken place on August 14, 2025.
5.   ATCs should have no expiration.
A)    Create a formal extension process for water 
ATCs. The submittal process would charge a 
quarter of the original fee and include a document 
stating that the design has not changed from the 
originally approved design and a new PWS 
signature form. This would provide a 1-year 
extension of the ATC.
A)    In Progress – An EROP process 
will be initiated to reduce the fee 
for renewals/extensions. 
MCESD will create a Water ATC 
extension form to be used for 
water ATC extensions. 
Anticipated completion date of 
December 31, 2025.

Environmental Services Department
301 W. Jefferson St., Suite 170 
Phoenix, Arizona 85003
P: 602.506.6616
Maricopa.gov/Enviro
B)  Send an automated email to the applicant 30 days 
before the expiration date with instructions on the 
extension process.
C)  Initiate an EROP case to change the Maricopa 
County Environmental Health Code to allow for 
extensions within 30 days of expiration.
D)  Create an internal process for resubmitted 
projects that identifies the original reviewer and 
assigns the resubmittal to the original reviewer. 
Once assigned to the original reviewer, they will 
check for code compliance only and will refrain 
from making comments that are not explicit code 
requirements (e.g., plan readability comments).
E)  Create a formalized process for expired projects 
that are constructed. This process would have the 
applicant submit the as-built drawings as the 
design drawings, and an ATC/AOC review would 
be conducted simultaneously. The review will 
check for code compliance only and will refrain 
from making comments that are not explicit code 
requirements (e.g., plan readability comments). 
The end result of the review, if all code design 
requirements are met, would be an ATC and an 
AOC.
B)    In Progress – An automated 
email will be created in Permit 
Center. Anticipated completion 
date of January 31, 2026.
C)    In Progress – An EROP case will 
be initiated in December 2025.
D)    In Progress – MCESD will create 
a training document for 
resubmittals, outlining the 
streamlined process. 
Anticipated completion date of 
December 31, 2025.
E)    In Progress – MCESD will create 
stakeholder guidance for 
resubmittals of constructed 
projects and create a staff 
training document for 
resubmittals of expired projects 
that have been constructed. 
Anticipated completion date of 
December 31, 2025.
6.    The County should publish Key 
Performance Indicators to create 
predictability for customers and to show what 
success looks like.
A)   Publish key performance indicators in the 
WaterWorks bulletin. 
B)   Key Performance Indicators will include:

Review times for each permit type

Volume of each permit type submitted

Initial review time for each permit type
A)    In Progress – KPIs will be 
included in the WaterWorks 
bulletin.  The first Waterworks 
bulletin is expected to be 
distributed by October 31, 2025.
B)    In Progress – The WaterWorks 
bulletin KPIs will include the 
bulleted items. The first 
Waterworks bulletin is expected

Environmental Services Department
301 W. Jefferson St., Suite 170 
Phoenix, Arizona 85003
P: 602.506.6616
Maricopa.gov/Enviro

The most common comments/deficiencies, 
along with guidance to correct/prevent these 
comments.
C) The internal goal turnaround times for each permit 
type can be published on the County website.
D)   Create a process whereby comments that are 
generated after the third round of review are 
routed to management for review and 
concurrence. If comments remain, the applicant 
will be offered a virtual meeting to discuss and 
address them.
to be distributed by October 31, 
2025.
C)    In Progress—MCESD will add a 
webpage listing goal turnaround 
times to the website for each of 
the permit types. Anticipated 
completion date is November 
30, 2025.
D)    In Progress — If a third round of 
comments is generated, an 
SOP outlining the process will 
be created and distributed to 
staff. The anticipated 
completion date is November 
21, 2025.
7.    There has not been a comprehensive 
cost recovery evaluation and/or adjustments 
to align increased workloads with available 
resources.
A)     Start the EROP process to incorporate updated 
fees into the Maricopa County Environmental 
Health Code.
B)    Develop a procedure that outlines how the 
department will brief the Board of Supervisors 
on an updated cost-recovery study every four 
years. 
A)      Completed – The EROP 
process to update fees has 
been started with the next step 
of stakeholder workshops 
taking place starting on 
October 14, 2025.
B)      In Progress – Procedure will be 
developed and implemented by 
December 31, 2025.

Environmental Services Department
301 W. Jefferson St., Suite 170 
Phoenix, Arizona 85003
P: 602.506.6616
Maricopa.gov/Enviro
   
 ACTION REQUESTED
The requested action is to consider the recommendations, accept the report, whole or in part, as submitted by the Ad Hoc 
Task Force, and provide guidance and direction to staff.

Environmental Services Department
301 W. Jefferson St., Suite 170 
Phoenix, Arizona 85003
P: 602.506.6616
Maricopa.gov/Enviro
Special thank you to staff and stakeholders for their time and commitment to this process: 
Process/Permit Center Subcommittee: Ox Auxier (Subcommittee Chair), Andrew Haas, Anthony Dudley, Art Nunez, Bill Lally, 
Bhaskar Kolluri, Eddie Solis, Julie Hoffman, Moses Thompson, Richard Hacker, Robert Kuta, Susan Butler
 
Standards/Scope Subcommittee: Doug Kobrick (Subcommittee Chair), Andrew Haas, Alan Palmquist, Amy Peterson, Andy 
Kunasek, Brandon Olson, Darlene Helm, Jeff Stuck, Jeremy Abbott, Joshua Rosas, Julie Hoffman, Mark Gross, Reid Guzy, 
Richard Hacker, Robert Kuta, Spencer Taylor, Susan Butler, Suzanne Grendahl
 
Staff: Ryan Hall, Sujana Attaluri, Logan Peiman, and Andy Linton