A training video produced in partnership with the State Water Resources Control Board instructed sanitary sewer system enrollees on how to designate a legally responsible official (LRO) under the Statewide Sanitary Sewer Systems General Order No. 2022-0103.
Presenter 2, an unnamed instructor in the video, said: "This video covers how to designate a legally responsible official or LRO," and explained that the LRO must electronically certify applications, reports, sewer system management plans and updates "under perjury" as required by section 5.9 of the general order.
The video emphasized why designation matters: the LRO must have responsibility for management of the enrollee’s entire sanitary sewer system, authority to make managerial decisions including major capital improvement recommendations, and direct authority over personnel with relevant professional training or certification. The instructor summarized those duties: "A legally responsible official must have responsibility over management of the enrollee's entire sanitary sewer system" and must be able to "make managerial decisions that govern the operation of the sanitary sewer system."
For new applicants, the training said a duly authorized representative must be delegated at least 60 days before assuming operation and maintenance responsibilities; that representative must complete, sign and submit the enrollment application (Attachment B) and then create an LRO account in the reporting system. Continuing enrollees under the 2006 order were asked to confirm their current designee meets the section 5.1 requirements of the new general order and to delegate a replacement if not.
The video included a step-by-step demonstration for registering an LRO account in the state's reporting system (CIWQS): from the CIWQS home page, click user registration, select the option indicating "I am the legally responsible person for my facility or location," choose "sanitary sewer overflows" as the discharger type, and enter the facility WDID (Water Discharge Identification) number. The instructor instructed users to create a username and PIN, print the Electronic Submittal Authorization Form from the registration page, sign it, and mail it to the Division of Water Quality, Care of DMR Processing Center/CWQS Registration, PO Box 100, Sacramento, CA 95812-1000. The video also explained how an LRO can add multiple systems to a single account by using "view/change my personal information" and requesting an additional facility with validation of the WDID and organization selection.
The training reiterated an important limitation: State Water Resources Control Board staff "cannot suggest the designation of the legally responsible official for an enrolled system," but they "may clarify any questions regarding order requirements." For additional help the video provided contact information (sanitarysewer@waterboards.ca.gov) and pointed viewers to the General Order Compliance Tools tab on the State Water Resources Control Board website for more videos and resources.
The video credited Summit Partners and Ridgecresta Learning and Development Services and thanked several industry organizations for assistance.
Next steps for enrollees are procedural: confirm the current designee meets the order's tests in section 5.1, or delegate and register a qualified LRO in CIWQS and submit the signed authorization form to complete the account activation.