CC Resolution No. 24-052 approving the renewal and collection of the 1992 Storm Drain Fee with no increase in rates for Fiscal Year (FY) 2024-25RESOLUTION NO. 24-052
A RESOLUTION OF THE CUPERTINO CITY COUNCIL APPROVING THE
RENEWAL AND COLLECTION OF THE EXISTING STORM DRAIN FEE
WITH NO INCREASE IN RATES FOR FISCAL YEAR 2024-2025
WHEREAS, the City Council of the City of Cupertino enacted Municipal
Code Chapter 3.36 to meet the requirements of the federally mandated Stormwater
Pollution Prevention and Management Program, federal regulations, and the
City’s National Pollution Discharge Elimination System (NPDES) permit and
establishing the authority for imposing and charging a storm drainage service
charge (“storm drain fee” or “fee”); and
WHEREAS, Municipal Code Chapter 9.18 provides regulations and gives
legal effect to the Municipal Regional Permit issued to the City and assures
ongoing compliance with the most recent version of the City’s NPDES permit
regarding the effect of urban stormwater runoff on the ability of the City’s storm
drain system to comply with federal and state laws; and
WHEREAS, in 1992 the City adopted a storm drain fee based on the City’s
Master Storm Drain Study runoff coefficients and average area of impervious
surface per acre based on the type of land use of each parcel; and
WHEREAS, a written report titled “Engineer’s Report, Assessment of Fees
for Storm Drainage Purposes Nonpoint Source Pollution Program” (“report”),
concerning the method of assessing fees to fund the City’s Stormwater
Management Program, was prepared by the Director of Public Works pursuant to
Section 3.36.080(B) of the City’s Municipal Code and filed with the City Clerk on
June 1, 2024; and
WHEREAS, notice of the proposed rates was published in a local
newspaper on 5/22/2024 and 5/28/2024; and
WHEREAS, the City Council of the City of Cupertino finds and determines
as follows:
1. After considering the “Engineer’s Report, Assessment of Fees for Storm
Drainage Purposes Nonpoint Source Pollution Program,” attached hereto as
Exhibit A and incorporated herein, and the testimony received at this public
hearing, the City Council hereby approves the report.
Resolution No. 24-052
Page 2
2. There is a need in the City to continue collecting a storm drain fee to cover
the costs of federal and state requirements, as heretofore described, in that
properties within the City will not otherwise contribute a portion of costs toward
this program and without the availability of such storm drain fee, the City’s
general fund will further be negatively impacted in such a manner as to jeopardize
other essential services.
3. The facts and evidence presented establish that there is a reasonable
relationship between the need for this fee and the impacts for which this fee shall
be used, and that there is a reasonable relationship between the fee’s use and the
properties that are to be charged this fee. These relationships or nexus are
described in more detail in the above-referenced Engineer’s Report.
4. The amounts of the fee for each category of property, as set forth below, are
reasonable amounts, because the fee is based on the percent of impervious area
established in the Master Plan, City of Cupertino Storm Drainage System and are
below the amount needed to recover the cost of storm drainage services.
5. It is further determined that each and every parcel of land to which the fee
applies will, and has received, a benefit of flood control from the storm drainage
system and that the fees imposed herein on each such parcel are in conformity
with, and in fact lower than, the benefits that such parcel has received as further
described in the report.
NOW, THEREFORE, BE IT RESOLVED, by the City Council, that:
1. Charge. The storm drain fee shall continue to be charged to each parcel
within the City, unless exempt, to contribute to the costs of the City’s federal and
state requirements for Nonpoint Source Control and a Stormwater Management
Program.
2. Use of Revenue. The revenue derived from said fee shall be used in
connection with implementing and enforcing Chapters 3.36 of the Cupertino
Municipal Code titled “Storm Drainage Service Charge” and Chapter 9.18 titled
“Stormwater Pollution Prevention and Watershed Protection.”
3. Schedule of Charges.
Resolution No. 24-052
Page 3
a. Annual fees for each category of property will be assessed and collected as
follows:
Residential premises $ 12.00/parcel
Apartment premises $144.00/acre
Commercial/Industrial premises $144.00/acre
Unimproved/Recreational $ 36.00/acre
b. The following public properties are exempt from, and shall not be assessed
the environmental fee:
Cupertino Sanitary District
Santa Clara County
Santa Clara Valley Water District
Southern Pacific Transportation Company
State of California
The Santa Clara County Fire Department
The City of Cupertino
The Cupertino Union School District
The Foothill-De Anza Community College District
The Fremont Union High School District
The MidPeninsula Regional Open Space District
United States of America
4. Judicial Action to Challenge this Resolution. Any judicial action or
proceeding to challenge, review, set aside, void, or annul this resolution shall be
brought within 120 days from the date of its adoption.
PASSED AND ADOPTED at a regular meeting of the City Council of the City of
Cupertino this 4th day of June, 2024, by the following vote:
Resolution No. 24-052
Page 4
Members of the City Council
AYES: Mohan, Fruen, Chao, Moore, Wei
NOES: None
ABSENT: None
ABSTAIN: None
SIGNED:
___________
Sheila Mohan, Mayor
City of Cupertino
________________________
Date
ATTEST:
________________________
Kirsten Squarcia, City Clerk
________________________
Date
6/12/24
6/12/24
EXHIBIT A
ENGINEER'S REPORT
ASSESSMENT OF FEES FOR STORM DRAINAGE PURPOSES
NONPOINT SOURCE POLLUTION PROGRAM
A.Program Description and Purpose
The purpose of this assessment is to collect fees to fund the City of Cupertino's Nonpoint
Source Pollution Prevention Program mandated by the Environmental Protection Agency
(EPA) and the Clean Water Act. Regulations by the EPA and the State of California
require cities to take specific actions to eliminate or control pollutants in waters of the
State.
The term "nonpoint source pollution" represents a process whereby pollutants, debris,
trash, sediment, and chemicals which accumulate on streets, in neighborhoods, at
construction sites, in parking lots, and on other exposed surfaces are washed off by
rainfall and carried away by stormwater runoff (via city drain inlets and pipes installed
for flood control) into local creeks and the San Francisco Bay. Sources of these pollutants
may include automobile exhaust and oil, pesticides, fertilizers, eroded soil, detergents, pet
waste, paint, litter, and other material carried through the City's storm drainage system
without treatment directly to the Bay. Many of these pollutants are hazardous to aquatic
and human life.
The City of Cupertino has implemented several mandated and pro-active programs to
mitigate this problem. Among other activities, these programs include an illegal storm
drain discharge investigation and elimination complaint response program; scheduled
proactive inspections of outdoor housekeeping practices at business sites within the City;
sweeping of residential and commercial streets; installation of trash capture devices and
curb drain inlet screens to prevent litter from entering the City's storm drainage system;
inspection and cleaning of storm drain structures and trash capture devices; public
education and engagement with teachers and students, educational activities offered at
City events; and a popular, unique, and well established District-wide third-grade creek
education & field trip program led by the City's naturalist at McClellan Ranch Preserve
and Stevens Creek.
The San Francisco Bay Regional Water Quality Control Board (Water Board) approved
the first Municipal Regional Permit (MRP) on October 14, 2009, and, on November 18,
2015, adopted the second regional permit (MRP 2.0) with additional requirements that
became effective on January 1, 2016. A further update and reissuance (MRP 3.0) were
adopted by the Regional Water Quality Control Board and became effective on July 1,
2022. The MRP was issued to the City of Cupertino and 75 agencies or co-permittees
which discharge storm water through municipal drainage systems to local creeks and the
San Francisco Bay. The City of Cupertino and 14 other co-permittees in Santa Clara
County are members of the Santa Clara Valley Urban Runoff Pollution Prevention
Program (SCVURPPP) which works collaboratively to maintain compliance with MRP
3.0. In addition to conducting local activities, City staff work closely with the other
SCVURPPP jurisdictions to implement pollution prevention, source control, monitoring,
and educational programs.
B. Recent Notable Activities
In FY 2019-2020, the Nonpoint Source budget was increased to accommodate a new
street sweeping contract, enhanced assessment and maintenance of aging structures, and
additional staff to clean and maintain the city’s storm drain system. The City’s storm
drain system consists of 2092 drain inlets and 90 miles of storm drainage pipes. Of the
drain inlets 181 are fitted with full trash capture devices and 283 have curb screens. An
additional 19 full trash capture devices will be added during FY 23-24. Maintenance of
these assets includes twice per year cleaning of inlets and trash capture devices which
protects the city from flooding while preventing stormwater pollution. In FY 23-24, an
equivalent total of 5.87 full time employees are included in the Nonpoint Source program
budget distributed across 23 positions with varying allocations of each person’s time.
This represents a slight increase from the previous fiscal year because in 2023 the
Environmental Programs Division absorbed the Sustainability Division, which triggered
a reorganization resulting in shifts to funding allocations. Most notably, one part-time
staff went through an internal recruitment process to become a full-time Environmental
Compliance Technician to meet the increased demands of MRP compliance and to
accommodate succession planning. The part-time position has been eliminated, and other
minor shifts in funding allocations will take effect in FY 24-25. One maintenance worker
is covered at 100%, and the remaining positions are allocated at between 2% - 60%.
C. Estimated Expenditures
The total amended budget to implement the required programs described above for
FY 23-24 was approximately $2,554,669.
The breakdown of past actuals, current actuals as of Q3, and budgeted expenses for FY
24-25 are as follows:
FY 22-23
Actuals
FY 23-24 Q3
7/1/2023 –
3/31/2024
FY 24-25
Requested
Budget
Staffing $880,287 $575,108 $805,035
Materials $67,561 $52,604 $76,021
Contract Services $313,347 $303,909 $415,570
Allocations $332,864 $259,607 $598,995
Cost Share & Rebate
Programs
$9,159 $12,290 $10,707
Special Projects $12,161
Fixed Asset Acquisition $128,895
Total Expenses $1,615,378 $1,332,415 $1,906,328
Expected Final $2,228,113
Activities undertaken within the Nonpoint Source program for permit compliance:
Countywide Program
SCVURPPP Program Assessment - Regional Permit Implementation Regional
Watershed Monitoring (administered by EOA, Inc.1)
State NPDES2 Permit Fees
Countywide Public Education and Municipal Staff Training
CA Stormwater Quality Association (CASQA) Participation
County Policy Development
Operations and Maintenance
Catch Basin and Frequent Trash Capture Device Cleaning
Installation of Trash Capture and Retractable Screen Devices
On-call Emergency Spill and Discharge Response
Staff and Equipment to Implement City's Mandated Litter Reduction Plan
Street Sweeping
City Public Education Awareness
Public Outreach Materials & Events
Third-Grade Creek Education for Local Schools
Support High School Students' Watershed and Creek Education Support De Anza
College and Community Environmental Education
Community Engagement - Creek Cleanup & Watershed Monitoring Events
Staff to Conduct Public Education, Training and Outreach
CA Product Stewardship Council membership (Extended Producer Responsibility)
1 EOA, Inc. is the environmental engineering and regulatory consulting firm that manages the Santa Clara
Valley Urban Runoff Pollution Prevention Program for the co-permittees www.eoainc.com.
2 NPDES: National Pollutant Discharge Elimination System
Local Programs
Development, Administration, and Evaluation of Mandated Programs Environmental
Impact and New and Redevelopment Review
Rain barrel, rain garden, and landscape conversion rebates
Ordinance Revisions
Database Maintenance
Illegal Discharge Complaint Investigation and Enforcement
Industrial/Commercial Discharger Inspection Program
Construction Site Inspection Program
Verification of Treatment Measure Maintenance by Private Property Owners
Low Impact Development (LID) and Green Infrastructure Management
Litter Reduction Education and Enforcement
City's Participation in Multiple Countywide and Regional Programs
Annual Parcel Stormwater Fee Assessment
Other Staffing Costs
Cost Allocations
D. Revenue And Assessment
Revenues generated to fund this program come from two fees assessed on parcels in
Cupertino. The Storm Drain Fee was established in 1992. Revenues from that fee are
inadequate to meet the expenses associated with maintaining the storm drain system in
Cupertino and ensuring compliance with the MRP, so the Clean Water and Storm
Protection fee was established in 2019 and first appeared on 2019-2020 property tax bills.
As assessed on the 2023-2024 tax roll and direct billed, the revenue from the two fees
will total approximately $1,500,500.
FY 23-24 Assessed Actuals
1992 Storm Drain Fee $375,583.28
2019 Clean Water and Storm Protection Fee $1,124,917.20
Total Assessed $1,500,500.48
1992 Storm Drain Fee
Fees are based on a factor calculated from the City's Master Storm Drain Study runoff
coefficients and average area of impervious surface per acre based on type of land-use
development. The factor for each category is based on a comparison to an average
residential parcel assigned a factor of one. Certain parcel-owners such as schools and
government entities were exempt from such fees in 1992 and as such are not assessed this
fee.
The fee assessed on the 2023-2024 tax roll totaled $375,583.28. Those fees were applied
to 16,616 residential, commercial, and vacant or recreational use parcels.
2019 Clean Water and Storm Protection Fee
The Clean Water and Storm Protection Fee is imposed on properties that shed water,
directly or indirectly, into the City’s storm drainage system, and is calculated to be
proportionate to the amount of stormwater runoff contributed by each parcel, which is in
turn proportionate to the amount of impervious surface area. The details of the
methodology are described in the Fee Report as prepared by SCI Consulting Group (SCI)
in February of 2019 that is attached to the Clean Water and Storm Protection fee
ordinance. The calculations are informed by the City’s 2018 Storm Drain Master Plan,
which includes an analysis of the percentage of impervious area for Cupertino, and rates
are further calculated by parcel size and land use category. Unlike the 1992 fee, the 2019
Clean Water and Storm Protection fee is subject to treatment under prop 218 and as such
all parcels are assessed the fees without exemptions for parcel-owners such as schools
and government entities.
The fees assessed on the 2023-2024 tax rolls totaled $1,031,331.30. Those fees were
applied to 16,597 parcels in fourteen categories including single-family residential
parcels in four sizes, condominiums, and apartments, commercial, office, institutional,
recreational, and vacant. Fees billed directly to parcel-owners that do not receive property
tax bills (such as schools and government) totaled $93,585.90 applied to 71 parcels.
The total revenue from the Clean Water and Storm Protection fee for 2023-2024 is
$1,124,917.20.
For both of the fees, in coordination with the City’s contracted consultant for this
purpose, each parcel was identified, and a fee established in a separate report submitted to
the County entitled Certification of Special Assessment Annual Enrollment which lists
the APN and associated fee. The consultant used by the City, SCI, prepares both forms
and submits them to the County in accordance with the annual deadline in early August
so that the fees can appear on the property tax bills. Additionally, SCI staff are available
to answer questions via a phone number provided on the tax bill.
D. Annual Review
The 2019 Clean Water and Storm Protection Fee included annual review requirements
beginning with FY 2020-2021 as described in ordinance 19-2183 (Chapter 3.38 of the
Cupertino Municipal Code). Section 3.38.040 describes the review process and allows for
an annual increase based on the change in CPI as of December each year, up to 3%
maximum, if actual additional costs are incurred.
The expenses attributed to the Nonpoint Source Program through third quarter of
FY23-24 are $1,207,482 and are projected to reach $2,228,113 by the end of the fiscal
year. That expected total is about $326,586 below the approved budget for FY23-24;
however, it is above expected revenue by approximately $729,912. Available balance in
Fund 230 is sufficient to make up the difference for FY22-23.
The intention of the fee assessments is only to cover costs and not accrue a balance,
however several factors resulted in fund balance accruing. In 2019, before the Clean
Water and Storm Protection Fee ballot measure passed, a General Fund subsidy had
already been budgeted and transferred that was ultimately not needed. In FY19-20 the
program came in under budget largely because true staffing cost allocations had not yet
been applied, something that was corrected for FY20-21. In FY20-21 a storm drain video
and repair project was anticipated at $248,436, but no acceptable bids were received for
that project and then it was not conducted in FY21-22 either. An outfall survey is being
conducted in FY 23-24 to inform needed repair planning, but at less than the full
budgeted amount. In FY 23-24 a rover camera was acquired for $128,895 that will avoid
contract expenses in future for drain video services. The fund 230 balance was
$ 1,220,134 at the beginning of FY23-24. After covering the shortfall from the projected
expenditures from FY23-24, the remaining balance in Fund 230 at the end of the fiscal
year is expected to be approximately $492,521 heading into FY 24-25. The requested
budget for FY 24-25 totals $1,906,328. With anticipated revenue at $ 1,500,500, that
indicates a projected shortfall of an estimated $429,089. That shortfall will not exhaust
the remaining fund balance in Fund 230, however there are expected increased costs to
street sweeping under a new agreement and anticipated outfall repairs, meaning that an
increase to the Clean Water and Storm Protection fee is now recommended to reduce the
draw upon the General Fund to cover the difference. A 2.62% increase to the 2019 Clean
Water and Storm Protection fee would mean an increase of $1.20 per year for residents in
the most common size of residential property. The increase would generate
approximately $29,473 per year additional revenue for the program..
A full year of expenses and revenues for the Nonpoint Source Program were audited
under the City’s annual external audit and reviewed by the City’s Audit Committee. An
additional Agreed-Upon Procedures (AUP) audit specific to the Nonpoint Source
Program was developed to further assess this program using a calendar year cycle. An
additional Agreed-Upon Procedures (AUP) Audit, specific to the Nonpoint Source
Program, was developed to further assess this program using a calendar year cycle,
which will be completed for calendar year 2022 and 2023 with no expected exceptions
noted. The final AUP reports will be available to the public late June. The City requests
preparation of calendar year AUPs for the stormwater program in order to provide more
up to date findings to the City Council for review during this annual process, which must
happen prior to the normal fiscal year cycle in order to meet County tax roll deadlines.
Chad Mosley
Director of Public Works/City Engineer