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Water commission forwards Title 16 amendment to enable electronic industrial-waste reporting (SwiftComply, CROMERR)
Summary
Staff briefed the commission on a package to update the municipal code to support digital pretreatment reporting and compliance with EPA's Cross-Media Electronic Reporting Rule; commissioners voted to forward the ordinance to city council after hearing project scope, EPA approvals and software costs.
Staff presented proposed amendments to Santa Barbara's municipal code (Title 16) to modernize the city's pretreatment program for industrial dischargers and to enable electronic submittal and legally defensible electronic records under the EPA's Cross-Media Electronic Reporting Rule (CROMERR).
Ms. Thompson, who leads the pretreatment program, told commissioners the city has operated an approved pretreatment program since about 1989 and currently manages roughly 14 permitted industrial users and other discharges. She explained the program's goals: protect the environment, prevent introduction of incompatible pollutants, and enable reuse and reclamation of effluent and sludges. She described the legal components that give the program authority, including the local limits already updated in 2023 and the enforcement response plan.
What changed: to reduce manual paperwork and centralize compliance documents, staff selected SwiftComply as a purpose-built, cloud-based platform for pretreatment programs and pursued EPA concurrence so the city's approach will meet CROMERR requirements (identity proofing, tamper resistance and auditability). "We chose SwiftComply. It's cloud based, and it's purpose driven," Ms. Thompson said. She reported an initial purchase price of about $30,000 and an ongoing annual cost near $16,000, and said the city applied to EPA for approval to implement the approach.
Commission action: after the presentation and questions about training and change management for smaller permittees, the commission voted to forward the Title 16 ordinance amendment to the City Council for approval.
Context and next steps: Ms. Thompson noted the goal is to accept electronic submissions, reduce paper processes and allow permittees to view compliance status in real time. Staff will update municipal code language, the pretreatment administrative documents and the enforcement response plan, then seek approvals from state and regional water boards after council action. The meeting record shows staff said they are the first program in Region 3 to pursue this specific CROMERR-ready implementation path; staff will proceed with training and onboarding upon final approvals.
