HomeMy WebLinkAbout05/20/2025 - Work Session - Meeting MaterialsSALT LAKE CITY COUNCIL
AGENDA
WORK SESSION
May 20, 2025 Tuesday 2:00 PM
Council meetings are held in a hybrid meeting format. Hybrid meetings allow people to join online or in
person at the City & County Building. Learn more at www.slc.gov/council/agendas.
Council Work Room
451 South State Street, Room 326
Salt Lake City, UT 84111
SLCCouncil.com
2:00 PM Work Session
Or immediately following the 1:00 PM
Community Reinvestment Agency Meeting
7:00 pm Formal Meeting
Room 315
(See separate agenda)
Welcome and public meeting rules
In accordance with State Statute and City Ordinance, the meeting may be held electronically. After 5:00 p.m., please enter
the City & County Building through the main east entrance.
The Work Session is a discussion among Council Members and select presenters. The public is welcome to listen. Items
scheduled on the Work Session or Formal Meeting may be moved and / or discussed during a different portion of the
Meeting based on circumstance or availability of speakers.
The Website addresses listed on the agenda may not be available after the Council votes on the item. Not all agenda items
will have a webpage for additional information read associated agenda paperwork.
Generated: 11:11:51
Note: Dates not identified in the project timeline are either not applicable or not yet determined. Item start
times and durations are approximate and are subject to change.
Work Session Items
Click Here for the Mayor’s Recommended Budget for Fiscal Year 2025-26.
1.Fiscal Year 2025-26 Budget: Information Management
Services ~ 2:15 p.m.
45 min.
The Council will receive a briefing about the proposed Information Management Services
(IMS) budget for Fiscal Year 2025-26. The department provides technical and
communication support for the City.
For more information visit https://tinyurl.com/SLCFY26.
FYI – Project Timeline: (subject to change per Chair direction or Council discussion)
Briefing - Tuesday, May 20, 2025
Set Public Hearing Date - Tuesday, April 15, 2025
Hold hearing to accept public comment - Tuesday, May 20, 2025 and Tuesday, June 3,
2025 at 7 p.m.
TENTATIVE Council Action - TBD
2.Informational: mySLC Update ~ 3:00 p.m.
30 min.
The Council will receive a briefing from the Administration about mySLC the City’s tool
for residents to submit requests and feedback. The Administration will review current
reporting features, dashboards, and give an update on the implementation of the tool
citywide.
FYI – Project Timeline: (subject to change per Chair direction or Council discussion)
Briefing - Tuesday, May 20, 2025
Set Public Hearing Date - n/a
Hold hearing to accept public comment - n/a
TENTATIVE Council Action - n/a
3.Ordinance: Zoning Map Amendment at Approximately 128
North N Street ~ 3:30 p.m.
20 min.
The Council will receive a briefing about a proposal that would amend the zoning for the
property at approximately 128 North N Street from the SR-1A (Special Development
Pattern Residential District) to RMF-30 (Low Density Multi-Family Residential District).
The proposal would enable the development of three residential infill rental housing
units behind the primary structure on the property. The property sits on the East side of
N Street one parcel south of the corner of N Street and 3rd Avenue. The property is
located in the Avenues Local Historic District. The existing structure is rated as
contributing to the historic district and would not be altered under the proposal.
Consideration may be given to rezoning the property to another zoning district with
similar characteristics. The project is within Council District 3. Petitioner: John Van
Trigt, the property owner.
FYI – Project Timeline: (subject to change per Chair direction or Council discussion)
Briefing - Tuesday, May 20, 2025
Set Public Hearing Date - Tuesday, June 3, 2025
Hold hearing to accept public comment - Tuesday, July 1, 2025 at 7 p.m.
TENTATIVE Council Action - Tuesday, July 8, 2025
4.Tentative Break ~ 3:50 p.m.
20 min.
FYI – Project Timeline: (subject to change per Chair direction or Council discussion)
Briefing -
Set Public Hearing Date -
Hold hearing to accept public comment -
TENTATIVE Council Action -
5.Fiscal Year 2025-26 Budget: Department of Public Services ~ 4:10 p.m.
45 min.
The Council will receive a briefing about the proposed Department of Public Services
budget for Fiscal Year 2025-26.
For more information visit https://tinyurl.com/SLCFY26.
FYI – Project Timeline: (subject to change per Chair direction or Council discussion)
Briefing - Tuesday, May 20, 2025
Set Public Hearing Date - Tuesday, April 15, 2025
Hold hearing to accept public comment - Tuesday, May 20, 2025 and Tuesday, June 3,
2025 at 7 p.m.
TENTATIVE Council Action - TBD
6.Board Appointment: Planning Commission – Lilah Rosenfield ~ 4:55 p.m.
5 min.
The Council will interview Lilah Rosenfield prior to considering appointment to the
Planning Commission for a term ending May 20, 2029.
FYI – Project Timeline: (subject to change per Chair direction or Council discussion)
Briefing - Tuesday, May 20, 2025
Set Public Hearing Date - n/a
Hold hearing to accept public comment - n/a
TENTATIVE Council Action - Tuesday, May 20, 2025
7.Board Appointment: Planning Commission – Michael Vela ~ 5:00 p.m.
5 min.
The Council will interview Michael Vela prior to considering appointment to the Planning
Commission for a term ending May 20, 2029.
FYI – Project Timeline: (subject to change per Chair direction or Council discussion)
Briefing - Tuesday, May 20, 2025
Set Public Hearing Date - n/a
Hold hearing to accept public comment - n/a
TENTATIVE Council Action - Tuesday, May 20, 2025
8.Board Appointment: Planning Commission – Jeffrey Barrett ~ 5:05 p.m.
5 min.
The Council will interview Jeffrey Barrett prior to considering appointment to the
Planning Commission for a term ending May 20, 2029.
FYI – Project Timeline: (subject to change per Chair direction or Council discussion)
Briefing - Tuesday, May 20, 2025
Set Public Hearing Date - n/a
Hold hearing to accept public comment - n/a
TENTATIVE Council Action - Tuesday, May 20, 2025
9.Board Appointment: Bicycle Advisory Committee – Esther
Daranciang ~ 5:10 p.m.
5 min.
The Council will interview Esther Daranciang prior to considering appointment to the
Bicycle Advisory Committee for a term ending May 20, 2028.
FYI – Project Timeline: (subject to change per Chair direction or Council discussion)
Briefing - Tuesday, May 20, 2025
Set Public Hearing Date - n/a
Hold hearing to accept public comment - n/a
TENTATIVE Council Action - Tuesday, May 20, 2025
10.Follow-up: Fiscal Year 2025-26 Proposed Budget: Public
Engagement Info for Department of Public Utilities ~ 5:15 p.m.
30 min.
The Council will continue to review the proposed rate changes and public engagement
of the recommended budget for the Department of Public Utilities for Fiscal Year 2025-
26.
For more information visit https://tinyurl.com/SLCFY26.
FYI – Project Timeline: (subject to change per Chair direction or Council
discussion)
Briefing - Tuesday, April 15, 2025 and Tuesday, May 20, 2025
Set Public Hearing Date - Tuesday, April 15, 2025
Hold hearing to accept public comment - Tuesday, May 20, 2025 and Tuesday, June 3,
2025 at 7 p.m.
TENTATIVE Council Action - TBD
11.Fiscal Year 2025-26 Budget: Justice Court Written Briefing
-
The Council will receive a written briefing about the proposed Justice Court budget for
Fiscal Year 2025-26. The Justice Court handles misdemeanor criminal citations, small
claims, traffic citations and traffic school for moving violations.
For more information visit https://tinyurl.com/SLCFY26.
FYI – Project Timeline: (subject to change per Chair direction or Council discussion)
Briefing - Tuesday, May 20, 2025
Set Public Hearing Date - Tuesday, April 15, 2025
Hold hearing to accept public comment - Tuesday, May 20, 2025 and Tuesday, June 3,
2025 at 7 p.m.
TENTATIVE Council Action - TBD
12.Ordinance: Title 17 Updates Compiling with Rate Study
and Regulatory Requirements Written Briefing
-
The Council will receive a written briefing about a proposal that would amend Chapter
17 of the Salt Lake City Code. The Department of Public Utilities requests the updates to
align with the City’s proposed water, sewer, and stormwater rate structures and to
comply with regulatory requirements.
FYI – Project Timeline: (subject to change per Chair direction or Council discussion)
Briefing - Tuesday, May 20, 2025
Set Public Hearing Date - Tuesday, April 15, 2025
Hold hearing to accept public comment - Tuesday, May 20, 2025 and Tuesday, June 3,
2025 at 7 p.m.
TENTATIVE Council Action - TBD
Standing Items
13.Report of the Chair and Vice Chair -
-
Report of Chair and Vice Chair.
14.Report and Announcements from the Executive Director -
-
Report of the Executive Director, including a review of Council information items and
announcements. The Council may give feedback or staff direction on any item related to
City Council business, including but not limited to scheduling items.
15.Tentative Closed Session -
-
The Council will consider a motion to enter into Closed Session. A closed meeting described
under Section 52-4-205 may be held for specific purposes including, but not limited to:
a. discussion of the character, professional competence, or physical or mental
health of an individual;
b. strategy sessions to discuss collective bargaining;
c. strategy sessions to discuss pending or reasonably imminent litigation;
d. strategy sessions to discuss the purchase, exchange, or lease of real property,
including any form of a water right or water shares, if public discussion of the
transaction would:
(i) disclose the appraisal or estimated value of the property under
consideration; or
(ii) prevent the public body from completing the transaction on the best
possible terms;
e. strategy sessions to discuss the sale of real property, including any form of a water
right or water shares, if:
(i) public discussion of the transaction would:
(A) disclose the appraisal or estimated value of the property under
consideration; or
(B) prevent the public body from completing the transaction on the best
possible terms;
(ii) the public body previously gave public notice that the property would be
offered for sale; and
(iii) the terms of the sale are publicly disclosed before the public body
approves the sale;
f. discussion regarding deployment of security personnel, devices, or systems; and
g. investigative proceedings regarding allegations of criminal misconduct.
A closed meeting may also be held for attorney-client matters that are privileged pursuant to
Utah Code § 78B-1-137, and for other lawful purposes that satisfy the pertinent
requirements of the Utah Open and Public Meetings Act.
CERTIFICATE OF POSTING
On or before 5:00 p.m. on Friday, May 16, 2025, the undersigned, duly appointed City Recorder,
does hereby certify that the above notice and agenda was (1) posted on the Utah Public Notice
Website created under Utah Code Section 63F-1-701, and (2) a copy of the foregoing provided to The
Salt Lake Tribune and/or the Deseret News and to a local media correspondent and any others who
have indicated interest.
KEITH REYNOLDS
SALT LAKE CITY RECORDER
Final action may be taken in relation to any topic listed on the agenda, including but
not limited to adoption, rejection, amendment, addition of conditions and variations
of options discussed.
The City & County Building is an accessible facility. People with disabilities may make requests for
reasonable accommodation, which may include alternate formats, interpreters, and other auxiliary
aids and services. Please make requests at least two business days in advance. To make a request,
please contact the City Council Office at council.comments@slc.gov, 801-535-7600, or relay service
711.
CITY COUNCIL OF SALT LAKE CITY
451 SOUTH STATE STREET, ROOM 304
P.O. BOX 145476, SALT LAKE CITY, UTAH 84114-5476
SLCCOUNCIL.COM
TEL 801-535-7600 FAX 801-535-7651
COUNCIL BUDGET
STAFF REPORT
CITY COUNCIL of SALT LAKE CITY
tinyurl.com/SLCFY25
TO: City Council Members
FROM: Kira Luke
Budget and Policy Analyst
DATE: May 20, 2025
RE: FY 2025-26 Budget – Information Management Services (IMS) Department
Budget book pages: Key Changes: 69, Department Overview: 203-210, Staffing Document: 299-
300
DEPARTMENT AT-A-GLANCE
The Department of Information Management Services (IMS) provides multiple forms of support for
General Fund departments and Enterprise Funds in the City. IMS provides technical support,
maintains and manages the City’s networks and technology, coordinates and supports the City’s
internal and public-facing communications, manages the City’s data and Geographic Information
Systems (GIS), and implements and manages new projects and initiatives.
IMS is an Internal Service Fund, which means that its revenue comes from charging fees to other
City departments and funds based on the services provided. In recent fiscal years, IMS’s budget has
grown due to consolidating software subscriptions withing their budget, rather than distributing
throughout each department. Similar to the General Fund, IMS has its own Fund Balance that can
be drawn from to accomplish budget recommendations.
The Mayor’s recommended budget for IMS totals $43,052,934 which is an increase of $2,526,653
or 6% over the final adopted budget for Fiscal Year 2024-25 (FY25).
Information Management Services
FY25 Adopted FY26 Mayor
Recommended
Budget
Difference
Personnel Services $
16,318,574
$
18,188,861
$
1,870,287
Charges And Services $
20,586,542
$
21,791,894
$
1,205,352
Operating And
Maintenance
$
3,244,366
$
2,695,380
$ -
548,986
Capital Expenditures $
376,800.00
$
376,800
0
Grand Total $
40,526,282
$
43,052,934
$2,526,653
The $2.5 million increase is largely due to the Citywide 4% salary proposal and the new employees
added in FY25, as well as $1.3 million in contractual increases. One new graphic design specialist
position has been requested in this year’s budget, but the position is considered budget neutral, as
the funding was achieved by consolidating part time positions.
The department has one vacancy, the Chief Data Officer, which was delayed until the new fiscal year
to align with funding availability. The position is currently filled in an acting capacity by the Data
Privacy Manager.
Key Expense Changes in FY25
$1,322,823 in contractual increases, which includes licenses for new staff and increased
costs from vendors. This covers software used throughout the City like Workday, Salesforce,
Microsoft, Adobe, and Accela. As the software industry has transitioned to the subscription
model, the cost to the City has been rising at approximately 1+ million each year. However,
the Department reports success in efforts to negotiate contracts capping these annual
increases, which is a factor in this year’s increase coming in $243,944 lower than the
increase in FY25.
$1,203,829 proposed salary and benefits increases
Personnel Services Line Item Change
Salary Proposal $ 630,182
Base-to-base changes $ 184,035
2 new FTEs from BA 3 & 5 -
Cybersecurity Engineer and
Communications Specialist $ 330,125
Insurance Rate Changes $ 35,112
Pension Changes $ 24,375
Total $ 1,203,829
Communication Centralization
Over the past few years, IMS has gathered significant resources to enable them to provide
communication, engagement and design services to all City Departments. Communication staff in
IMS has grown from 10 in FY2021-22, when the team was initially centralized in IMS, to 16 in FY25.
The teams within IMS serve several roles, from establishing best practices and branding consistency
citywide, offering trainings and guides for all departments’ communication staff, and providing
media and graphic support for City Departments.
In response to Council Member questions about the pros and cons of how the citywide engagement
staff is currently assigned and structured, IMS shared more information about how the Civic
Engagement Team (CET) and staff resources have been working with the dispersed communications
staff around the City. At last reporting, there are roughly 70 to 80 citywide communication staff
skilled in social media, graphic design, and public information roles. There are also another 50 or so
community liaisons, planners and project managers who also contribute to communication efforts
in addition, for a total of 121 FTEs spread through all City Departments.
Currently, the centralized staff in CET coordinate closely with the media and graphic staff
members on the Web & Media Services team.
According to IMS's budget responses, the Civic Engagement Team see their role as to 1)
"deliver quality professional customer services" and 2) "champion best practices that elevate
the City's Communications infrastructure."
IMS Staff also create connections for coordination with communications staff members
across City departments.
They report progress on these collaborative efforts, and the Council may want to ask for
more information about trainings, collaboration on projects, new software, etc.
The work with communication staff in other departments has focused on providing support
and guidance, working on projects together, and strategizing.
The CET has also created training and team building opportunities for all City
communications staff.
With the CET leadership, citywide software has been purchased and rolled out (or in the
process) to all departments to help with outreach, e-newsletters, social media posting,
graphic design, etc.
POLICY QUESTIONS
1.Communication centralization: Given the information above, the Council may want to
consider collaborating on a Legislative Intent that would identify measures to track
collaboration and engagement success.
a.The Council may wish to ask for more information about how the staff housed within
departments helps to advance each department’s message, and how the centralized
resources in IMS complement those efforts.
b. The Council may wish to hold a discussion about benefits and challenges of the current
model, especially in terms of:
i. coordination and general issues the City has faced with the number of separate
applications departments purchase,
ii. opportunities to share platforms and engagement tools to empower City
Department communicators with consistent standards,
iii. compliance with State and Federal mandates regarding privacy and security,
domains, etc.
iv.when it may be appropriate to advise departments, vs to recommend
requirements to the cabinet. The CET has established guidance on multiple
topics, which could provide guidance for when it’s appropriate for a department
to do communications work internally, when to enlist the Communication &
Engagement Team’s support, up to when work could (or shouldn’t) be performed
by an outside contractor.
2.Engagement Software: IMS is leading the implementation of a new citywide engagement
software, ShapeSLC.
a. The Council may wish to request a briefing or small group meetings to learn more about
the software, its features, and implementation timelines.
3.mySLC - Constituent Relationship Management (CRM) software (Note: the Council is
scheduled to receive a briefing and overview of the public-facing aspect of mySLC following
this May 20 budget briefing, so these questions may be more [or less] relevant after the
Council has received the information in that briefing.)
a.The Council may wish to discuss to what extent mySLC use has enabled Departments to
gather new insights on constituent requests, inform budget decisions, and assess the
resources used to respond to service requests.
b.The Council may wish to ask what is on the horizon to maximize the city’s use of mySLC
across all departments.
4.Digital Access: The City has supported a few initiatives over the past few years to address the
digital divide through adoption of a Digital Equity Policy, increasing access to laptops by
donating surplus or out-of-date inventory (Computers for the Community), and adding public-
facing free internet wherever possible when the City is implementing capital improvements
(currently available in several City parks until 10pm). Staff understands the
a. The Council may wish to ask about staffing resources required to administer these
programs.
b.The Council may wish to ask for any insights IMS has learned about public wifi use, and
whether they could inform promotion of public spaces or events.
c.The Council may wish to ask for any other updates on the role Salt Lake City plays in
addressing the digital divide.
ADDITIONAL & BACKGROUND INFORMATION
Total Full Time Employees (FTEs) if adopted: 104
Updates and running list of ongoing initiatives (information in italics is copied
directly from Department responses):
Apprenticeships: IMS has traditionally been a participant in the City’s apprenticeship program,
but shared during FY25’s Budget Amendment 3 that, after the most recent cohort’s graduation,
those part time positions were some of those consolidated to fund the graphic design position
currently requested. As of the proposed budget, the Department reports that they are still
participating in the program, but taking on fewer apprentices to ensure quality mentorship.
Free public Wi-Fi
1. Free public Wi-Fi can be found at Sorenson Unity Center, and the YouthCity locations
at Liberty Park, Fairmont Park and Ottinger Hall, through our partnership with
Comcast Lift Zones
2. Many Parks, and City properties offer free public Wi-Fi access through our City
Connect network.
3. We continue to expand this offering in Salt Lake City owned public spaces as we make
improvements to our network infrastructure, development of new spaces and when
possible, in conjunction with other Capital improvements.
Enterprise Resource Planning (ERP) Initiative: The IMS budget is the central fund for the
City’s Workday software. The software is a central system that tracks and manages processes
including:
Project management
Risk management & compliance
Supply chain operations
Human Resources
o Performance management
o Recruitment & onboarding
o Learning management
Financial systems
Document management and archival
Civic Engagement Surveys
The Innovation and Project Management Team coordinate the biennial city survey and manage the
contract with survey vendors. The last biennial survey led to some concerns about methodology and
representation, so the City’s process for conducting surveys has slowed while the Innovation Team
has led a working group with representatives from the Council Office, Mayor’s Office, and IMS to
refine best practices and expectations before conducting another formal survey.
Innovation and Project Managment Division
In previous fiscal years, significant staffing resources were devoted to the ERP implementation. The
Council indicated an interest in following the subsequent endeavors of the team that was put
together to support the Workday implementation, so listing current projects has become an ongoing
update during the budget discussions.
Four positions were originally created on the IMS Innovation Team to support the
Workday project. The team has grown to become the Innovation and Project Management
Division. The division helps Salt Lake City run more smoothly by leading technology and
citywide projects and improving how we work—both inside City government and with the
public. The division includes enterprise technology managers, innovation consultants and
the change manager. Below is a sample of the larger projects/initiatives the team
participated in FY24/25. The team has also supported multiple smaller projects. Another
core mission of the division is educating other city staff on Project and Change
Management practices and principles. That allows other city projects to follow best
practices without necessarily having a division team member available to support.
Public launch of mySLC
Real Time Information Center
SLC Radio Migration to P25 Standard and UCA Network
Various Airport IT Projects
Generative AI Policy and Adoption Standards
Content Management for SLC Web 3.0
Computers for the Community
Vision Zero
Capital Asset Plan
Public Safety Plan Experience Surveys and engagement report
Green Loop
mySLC – formerly referred to as Constituent Relationship Management (CRM)
Software:
mySLC is a huge overhaul to the way that constituents report service requests to the City. It is a
major implementation process and it is essential to get right, since it serves as a frequent touchpoint
for constituents interacting with the City, and directly affects how the public views the customer
service the City offers.
Since 2022, the focus has been on internal coordination & system refinements:
o City staff have gotten familiar with case creation, monitoring, and closure.
o Cross-department improvements have been made to ensure the cases are properly
documented and shared, and constituents are contacted.
o From a behavior standpoint, this has been the largest hurdle. City staff have always
processed these requests in email and adjusting the CRM has taken time.
In 2024, the “guest experience” was the main focus. This involves:
o isolating certain automated interactions and making improvements, especially when
automated responses cause confusion or frustration.
o creating and publishing the “mySLC.gov” user interface for online submission.
o develop dashboards for at-a-glance monitoring of the cases.
o Building the “Knowledge Base” which will have articles to explain City processes,
standard Q&A, etc.
In FY25, focus was on:
o department training & consistency,
o the mySLC interface,
o release of a new mobile app
o Other coordination with department heads and exploring the use of the data in policy
and budgeting decisions.
Help staff keep track of public requests for service or information, and contact information
Automate work assignments
Track responses or flag needed follow-ups on a topic
Save staff and constituents time by providing a knowledge base to answer common questions
Provide data elected officials can use in making service level decisions.
Budget Fiscal Year 2026
Presented by Aaron Bentley,
Nole Walkingshaw, and Chad Korb
ORG CHART
INFORMATION MANAGEMENT SERVICES
STAFFING
INFORMATION MANAGEMENT SERVICES
•OFFICE OF THE CIO – 12 FTEs
•INNOVATION & PROJECTS – 6 FTEs
•NETWORK & SECURITY SERVICES – 21 FTEs
•SOFTWARE SERVICES – 29 FTEs
•GIS and DATA ANALYTICS – 6 FTEs
•WEB & MEDIA SERVICES– 10 FTEs (1 PTE to FTE)
•FIELD SUPPORT SERVICES – 13 FTEs
•COMMUNICATION & ENGAGEMENT – 7 FTEs
9
104
8
OVERVIEW OF CHANGES
FY25 Approved Proposed Changes FY26 Recommended
Total Budget: $40,526,282 $2,526,652 $43,052,934
FTEs: 101 / PTE: 27 FTE: +3 / PTE: -9
(One FTE Approved in BA#3
One FTE Approved in BA#5)
FTE: 104 / PTE: 18
INFORMATION MANAGEMENT SERVICES
INSIGHTS & KEY CHANGES
INFORMATION MANAGEMENT SERVICES
Contractual Increases
•Includes items: ServiceNow, Canon, AutoCAD, Asana, Lucid, Smartsheet, Microsoft Office,
Microsoft Copilot, and other Microsoft Power Apps, Adobe, Canva, Blancco, Farnsworth Rental,
ESRI, Geocortex, Sprout Social
•$1,322,823 Increase in budget
New FTE’s
•FY25 BA#3 approved Cyber Security Engineer I – Fully loaded cost of $195,665
•FY25 BA#5 approved Communications Specialist I (for language access) – Fully Loaded cost of $134,460
•Convert Graphic Design Specialist from Part-time to Full-time. Covered by reduction in Part-time positions $0
•$330,125 Increase in budget
Personnel Changes
•Base to Base $184,035
•Insurance $35,112
•Retirement Changes $35,112
•COLA changes at the estimated 4% $630,182
•$873,704 Increase in budget
CITYWIDE COMMS & ENGAGEMENT
INFORMATION MANAGEMENT SERVICES
WEB SERVICES
INFORMATION MANAGEMENT SERVICES
MEDIA SERVICES
INFORMATION MANAGEMENT SERVICES
GRAPHIC DESIGN SPECIALIST
INFORMATION MANAGEMENT SERVICES
GRAPHIC DESIGN SPECIALIST
INFORMATION MANAGEMENT SERVICES
COMPUTER DONATION PROGRAM
INFORMATION MANAGEMENT SERVICES
FY25
•161 Computers donated
•High demand by the community
•940 laptops requested
•235 committed to the community
FY26
•Will continue annual donations of up to 500 in FY26
THANK YOU
Presented by: Aaron Bentley, CIO & Department Director
Nole Walkingshaw Deputy CIO
Chad Korb Deputy CIO
MySLC
Presented by Aaron Bentley
INFORMATION MANAGEMENT SERVICES - mySLC
mySLC 2024-2025
•Launch of mySLC App
•Sunset of SLC Mobile
•Replacement of “Request or Report”
page on slc.gov
•Integrate 10 request types with work
order systems
INFORMATION MANAGEMENT SERVICES - mySLC
Month Case Count Cases per day
April 2024 2068 68.9
May 2024 2562 82.6
June 2024 2093 69.8
July 2024 2568 82.8
August 2024 2340 75.5
September 2024 2091 69.7
October 2024 2287 73.8
November 2024 2403 80.1
December 2024 2226 71.8
January 2025 2424 78.2
February 2025 2591 92.5
March 2025 2921 94.2
April 2025 3298 109.9
Total 31872
80.8Average Cases per day
City-wide Case Volume Past Year
•Average 2500 cases a month
•Average 5% increase monthly
90%
Resolution
Rate
INFORMATION MANAGEMENT SERVICES - mySLC
mySLC Goals for ‘25-’26
•Establish Service Level Agreements
(SLA)
•Measure compliance with SLA
•Customer Service Training
•Standardize Responses-Templates
•Continue work order integrations
•Activate internal chatting functionality
•Product development for future releases
INFORMATION MANAGEMENT SERVICES - mySLC
mySLC Roadmap 2025-2028
INFORMATION MANAGEMENT SERVICES - mySLC
mySLC Adoption
Dashboard
mySLC Adoption
Dashboard
Dashboards and Reports
INFORMATION MANAGEMENT SERVICES - mySLC
Customer Experience – How to Submit a Request
Added to Investigations/
Work order Tasks
Received by
City
Department
Request completion/
Case Closed
Request
Entered in
MySLC
Investigation, Repair,
Review, & Implementation
Customer Experience - Process of a Request
INFORMATION MANAGEMENT SERVICES - mySLC
THANK YOU
MySLC – Information Management Services
CITY COUNCIL OF SALT LAKE CITY
451 SOUTH STATE STREET, ROOM 304
P.O. BOX 145476, SALT LAKE CITY, UTAH 84114-5476
SLCCOUNCIL.COM
TEL 801-535-7600 FAX 801-535-7651
COUNCIL STAFF REPORT
CITY COUNCIL of SALT LAKE CITY
TO:City Council Members
FROM:Brian Fullmer
Policy Analyst
DATE:May 20, 2025
RE: Zoning Map Amendment at Approximately 128 North N Street
PLNPCM2024-01079
ISSUE AT A GLANCE
The Council will be briefed about a proposal to amend the zoning map for the parcel at 128 North N Street
in City Council District Three from its current SR-1A (Special Pattern Residential District) zoning to RMF-
30 (Low Density Multi-Family Residential District). The property is in the Avenues Local Historic District
(LHD).
The applicant’s stated objective is to demolish four existing non-contributing detached garages and
construct three new two-bedroom rental units with attached garages behind an existing historic four-plex
on the property. The four-plex, a contributing structure in the LHD, would not be altered as part of the
proposal, and no tenants would be displaced. The applicant’s draft plan also includes retaining two existing
garages on the property’s southeast corner.
The Planning and Historic Landmark Commissions reviewed the proposal at their respective January 22,
and February 6, 2025 meetings and held public hearings at which a total of five people commented or had
their comments read. Four were opposed citing concerns with parking, construction, project cost,
affordable housing, piecemeal zoning, and community benefits. The commenter who was supportive of the
proposal noted additional housing that would be provided. Planning staff recommended and both
Commissions voted unanimously to forward positive recommendations to the City Council
with a condition that the developer enter into a development agreement with the City
ensuring each new dwelling unit includes a minimum of two bedrooms.
Goal of the briefing: Review the proposed zoning map amendments, determine if the Council supports
moving forward with the proposal.
Item Schedule:
Page | 3
POLICY QUESTION
1. The Council may wish to discuss the Planning and Historic Landmark Commission
recommendation for a development agreement requiring new housing units on the property to
include a minimum of two bedrooms.
ADDITIONAL INFORMATION
The approximately one quarter-acre lot is located one parcel south of the southeast corner of 3rd Avenue
and N Street. As shown in the area zoning map below, surrounding zoning is dominated by SR-1A, while
the adjacent property to the north is zoned R-MU-35 (Residential/Mixed Use). The neighborhood
development pattern consists primarily of single- and two-story homes. Some small-scale multi-family
buildings are found in the area, including condominium buildings on adjacent parcels to the north and
south of the subject site.
Area zoning map with subject parcel outlined in red.
Image courtesy of Salt Lake City Planning Division.
Current SR-1A zoning does not allow new multi-family dwellings unless they are part of an adaptive reuse
of eligible existing buildings. Maximum height within the zone is 23 feet for pitched roofs and 16 feet for
flat roofs. These limitations would not allow for the proposed dwellings to be constructed above the garage
units.
Proposed RMF-30 zoning allows a maximum building height of 30 feet which is sufficient height for the
planned residential units and would allow slightly increased density while maintaining the neighborhood
character. A table comparing the existing and proposed districts is found later in this report.
Page | 4
Because the existing four-plex is being preserved, the property qualifies for building preservation
incentives, including a reduction of required off-street parking. A total of four parking spaces is required
for the seven units (0.5 space per dwelling unit). With three attached garages for the new units, and two
existing garages, the applicant is proposing a total of five off-street parking spaces.
Original Intermediate Current
Zone Requested
Infill Units
Maximum Height
Side Yard Setbacks
Community Benefit
Salt Lake City Code.
Page | 4
Applicant’s current draft site plan with proposed dwelling units in blue.
KEY CONSIDERATIONS
Planning staff identified two key considerations related to the proposal which are found on pages 6-9 of the
Historic Landmark Commission staff report and summarized below. For the complete analysis, please see
the staff report.
It is worth noting a third key consideration was included in the Planning Commission staff report related to
zoning incentives and parking reductions. Because the applicant will go through a separate process for new
construction in a historic district that includes building preservation incentives and parking reductions,
Planning staff removed this consideration for the Historic Landmark Commission to review as part of the
rezone request. As discussed above, the Council is only reviewing the appropriateness of the proposed
zoning and not concept plans that may change if the property is ultimately developed.
Consideration 1 – General Plan Compatibility
Planning staff reviewed the proposed zoning map amendment and how it meets the goals found in Plan
Salt Lake, the Avenues Plan, Thriving in Place, and Housing SLC. They found the proposal aligns well
with several policy statements in the plans.
Consideration 2 – Neighborhood Concerns
Planning staff received several comments from area residents about the proposed additional dwelling
units. Some were supportive but the majority were not. Concerns cited were primarily focused on the
adjacent townhome development north of the subject site, and parking.
Negative impacts from the townhome development include construction noise, a lack of maintenance and
upkeep of the property, and unaffordability of the for-sale units. As of the writing of this report the
development is largely vacant.
Parking concerns from neighbors include additional demand for on-street parking from the new dwelling
units without a commensurate increase in off-street parking. Current tenants worry they will lose garage
Page | 5
access for parking and storage.
Zoning Comparison
Parameter SR-1A (Existing)RMF-30 (Proposed)
Building Height 23 feet (pitched roof) or 16
feet (flat roof).
30 feet
Minimum Front Setback Equal to the average of the
front yards of existing
buildings within the block
face.
20 feet or the average of the
block face.
Maximum Front Setback Equal to the average of the
front yards of existing
buildings within the block
face.
20 feet or the average of the
block face.
Corner Side Setback 10 feet 10 feet
Interior Side Setback 4 feet on one side, 10 feet on
the other.
10 feet for multi-family
residential.
Rear Setback 25% of the lot depth, but not
less than 15 feet and need not
exceed 30 feet
Minimum of 20% lot depth,
need not exceed 25 feet.
Minimum Lot Width None, as multi-family
dwellings are not permitted.
No minimum.
Maximum Lot Width None, as multi-family
dwellings are not permitted.
110 feet
Minimum Lot Size None, as multi-family
dwellings are not permitted.
2,000 square feet per dwelling
unit.
Open Space, Landscape
Yards, and Landscape
Buffers
None required.10 feet when abutting single or
two-family, or special
development district.
Analysis of Standards
Attachment F (pages 29-32) of the Planning Commission staff report outlines zoning map amendment standards
that should be considered as the Council reviews this proposal. The standards and findings are summarized
below. Please see the Planning Commission staff report for additional information.
Factor Finding
Page | 7
Whether a proposed map amendment is consistent
with and helps implement the purposes, goals,
objectives, and policies of the city as stated through
its various adopted planning documents.
Complies
Whether a proposed map amendment furthers the
specific purpose statements of the zoning ordinance.
Complies
The extent to which a proposed map amendment will
affect adjacent and nearby properties due to the
change in development potential and allowed uses
that do not currently apply to the property.
May affect abutting
properties due to
change in development
potential.
Whether a proposed map amendment is consistent
with the purposes and provisions of any applicable
overlay zoning districts which may impose additional
standards.
Applicable.
Any new development
will be subject to
Historic Landmark
Commission review.
The adequacy of public facilities and services
intended to serve the subject property, including, but
not limited to, roadways, parks and recreational
facilities, police and fire protection, schools,
stormwater drainage systems, water supplies, and
wastewater and refuse collection.
Public utility
infrastructure may
need to be upgraded at
the property owner’s
expense. All other
public facilities are
adequate to support
the zoning change.
The status of existing transportation facilities, any
planned changes to the transportation facilities, and
the impact that the proposed amendment may have
on the city’ s ability, need, and timing of future
transportation improvements.
Proposed changes
won’t impact future
transportation
improvements.
The proximity of necessary amenities such as parks,
open space, schools, fresh food, entertainment,
cultural facilities, and the ability of current and
future residents to access these amenities without
having to rely on a personal vehicle.
Some amenities are
within walking
distance and a frequent
bus route, though most
residents use personal
vehicles to access
others.
The potential impacts to public safety resources
created by the increase in development potential that
may result from the proposed amendment.
No anticipated impacts
to public safety.
The potential for displacement of people who reside
in any housing that is within the boundary of the
proposed amendment and the plan offered by the
petitioner to mitigate displacement.
No residents would be
displaced.
Page | 7
The potential for displacement of any business that is
located within the boundary of the proposed
amendment and the plan offered by the petitioner to
mitigate displacement.
Not applicable
The community benefits that would result from the
proposed map amendment.
Provides housing that
aligns with current or
future needs of the
community.
City Department Review
As discussed in the table above, Public Utilities noted some infrastructure may need to be upgraded at the
property owner’s expense. In addition, the Fire Department included requirements that must be met if the
property is developed. No other responding departments or divisions expressed concerns with the
proposal.
PROJECT CHRONOLOGY
• September 19 2024 – Petition for zoning map amendment received by Planning Division.
• October 8, 2024 –
o Petition assigned to Alicia Seeley, Principal Planner
o Information about the proposal was sent to the Greater Avenues Community Council to
solicit public comments and start the 45-day recognized organization input and comment
period.
o Planning staff sent an early notification announcement of the project to all residents and
property owners living within 300 feet of the project site, providing information about the
proposal and how to give public input on the project.
• October 2024-February 2025 – Online open house.
• November 2024-January 2025 – Planning staff worked with the applicant to improve the quality
of their application material, including revising the requested zone to better fit the neighborhood
context, reviewing options for meeting the community benefit requirements, and addressing
concerns brought up by the community.
• January 7, 2025 – Planning staff posted notices on City and State websites and sent notices via the
Planning listserv for the January 22, 2025 Planning Commission meeting. Public hearing notice
mailed.
• January 8, 2025 – Applicant adjusted their application and proposed a zoning district based on
concerns brough up through public comments and staff feedback.
• January 10, 2025 – Planning staff posted a public hearing notice sign with project information and
notice on the property of the Planning Commission public hearing.
• January 22, 2025 –
o The Planning Commission held a public hearing for the request and voted unanimously to
forward a positive recommendation to the City Council for the proposed zoning map
amendment.
o Planning staff posted notices on City and State websites and sent notices via the Planning
listserv for the Historic Landmark Commission meeting on February 6, 2025. Public
hearing notice mailed.
Page | 8
• January 25, 2025 – Planning staff posted a public hearing notice on the property with project
information and notice of the Historic Landmark Commission public hearing.
• February 6, 2025 – The Historic Landmark Commission held a public hearing for the request and
voted unanimously to forward a positive recommendation to the City Council for the proposed
zoning map amendment.
• April 15, 2025 – Ordinance requested from City Attorney’s Office.
• April 21,2025 – Planning received signed ordinance from the Attorney’s Office.
• April 29, 2025 – Transmittal received in City Council Office.
Salt Lake City // Planning Division www.slc.gov/planning
City Council Briefing // May 20, 2025
PLNPCM2024-01079
ZONING MAP AMENDMENT –128 N N ST:
SR-1A TO RMF-30
Salt Lake City //Planning Division www.slc.gov/planning
SITE DETAILS
•Address:
128 N N St
•Current Zoning District:
SR-1A – Special
Development Pattern
Residential
•Proposed Zoning
District:
RMF-30 – Low Density
Multi-Family Residential
District
•Overlay District:
Avenues Historic District
Salt Lake City // Planning Division www.slc.gov/planning
SITE DETAILS
Current four-plex residential building as seen from N St – not to be alteredCurrent zoning in vicinity of subject property
Salt Lake City // Planning Division www.slc.gov/planning
SUBJECT SITE
Existing detached garages – to be removed Existing detached garages – Side view
Existing detached garages – Southeast cornerView of four-plex from rear of lot
Salt Lake City // Planning Division www.slc.gov/planning
PROPOSAL DETAILS
•Purpose of Rezone: To
add a three-unit
multifamily building
(rental units) to the rear
of the existing lot
Salt Lake City // Planning Division www.slc.gov/planning
NEIGHBORHOOD CONTEXT
Abutting property to the south: Notting Court Condominiums
10 Units
30 Feet in Height
Abutting property to the north: Newly finished townhomes
6 Units
35 Feet in Height
Salt Lake City // Planning Division www.slc.gov/planning
NEIGHBORHOOD CONTEXT
N street, across
from subject site
3rd Ave, across from
subject site
Salt Lake City // Planning Division www.slc.gov/planning
WHAT WOULD RMF-30 CHANGE?
Standard SR-1A RMF-30
Building Height Maximum 23 feet 30 feet
Minimum Lot Area 5,000 sqft for single family home,
4,000 per twin home unit 2,000 sqft per dwelling unit
Allowed Housing Types Single and two family Addition of multi-family dwellings
and rowhouses
Buildings per Parcel One principle building per parcel Multiple buildings on a parcel
without all having street frontage
Bonus Unit Eligibility N/A Bonus units awarded when
preserving a principal structure
Salt Lake City // Planning Division www.slc.gov/planning
GENERAL PLAN COMPLIANCE
“Enable moderate density increases
within existing neighborhoods
where appropriate”
“Encourage and support a diversity
of new housing options and types
with a range of densities
throughout the City to best meet
the changing population”
“Create gentle infill and
rental housing opportunities
in every neighborhood”
“Support zoning and code changes
as well as City investments that help
create more missing middle
housing types in neighborhoods
throughout the city”
Salt Lake City // Planning Division www.slc.gov/planning
COMMUNITY BENEFIT
Proposed community benefit: All additional units shall be two-bedroom units
•Planning Commission and Historic
Landmark Commission agreed that
the scale of development is
appropriate and aligns with current
and future needs of the community
as determined by the general plan.
Salt Lake City // Planning Division www.slc.gov/planning
PUBLIC COMMENTS
In Favor Opposed
Needed Housing Type: More mid-sized
housing needed as city grows
No Displacement: Development without
loss of existing housing
Neighborhood Compatibility: Consistent
with existing development pattern of the
neighborhood
Access to Public Transit: Increased density
supported by access to high frequency bus
routes
Privacy, Air and Sunlight: Potential impacts on
immediate neighbors
Parking and Traffic: Accessibility and availability
of parking on site, increased congestion
Townhomes on 863 E 3rd Ave: Neighbors fear
another long construction period resulting in
luxury housing that doesn’t fit into the existing
neighborhood
Salt Lake City // Planning Division www.slc.gov/planning
EVOLUTION OF PROJECT
Reasons for Changes
•Fire Code Review
•Public Comments
•Zoning Review
•Planning Staff Direction
Original Amended
Zone Requested R-MU-35: Residential
Mixed Use RMF-30
Infill Units Five one-bedroom
units
Three two-bedroom
units
Maximum Height 35 feet 30 feet
Side Yard Setbacks Zero Setbacks 10 feet for multi-family
residential
Community Benefit One affordable unit
at 80% AMI
Two-bedrooms per
unit
Salt Lake City // Planning Division www.slc.gov/planning
RECOMMENDATION
Approve with Condition
•That the property owner enter into a development agreement with
the City Council that the proposed community benefit, which is that
all new units shall provide a minimum of two bedrooms, prior to
receiving a certificate of occupancy
Salt Lake City // Planning Division www.slc.gov/planning
QUESTIONS AND
COMMENTS
Salt Lake City // Planning Division www.slc.gov/planning
Alicia Seeley // Principal Planner
alicia.seeley@slc.gov
SALT LAKE CITY TRANSMITTAL
To:
Salt Lake City Council Chair
Submission Date:
04/21/2025
Date Sent to Council:
04/29/2025
From:
Department *
Community and Neighborhood
Employee Name:
Seeley, Alicia
E-mail
Alicia.Seeley@slc.gov
Department Director Signature
Director Signed Date
04/25/2025
Chief Administrator Officer's Signature
Chief Administrator Officer's Signed Date
04/29/2025
Subject:
Zoning Map Amendment - 128 N N St
Additional Staff Contact:
Alicia Seeley | alicia.seeley@slc.govKelsey Lindquist | kelsey.lindquist@slc.gov
Presenters/Staff Table
Alicia Seeley | alicia.seeley@slc.govKelsey Lindquist | kelsey.lindquist@slc.gov
Document Type
Ordinance
Budget Impact?
Yes
No
Recommendation:
Approve
Background/Discussion
See first attachment for Background/Discussion
Will there need to be a public hearing for this item?*
Yes
No
Public Process
Recommended for approval by Planning Commission - January 22, 2025Recommended for approval by Historic Landmark Commission - February 6, 2025
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ERIN MENDENHALL DEPARTMENT of COMMUNITY
Mayor and NEIGHBORHOODS
Tammy Hunsaker
Director
SALT LAKE CITY CORPORATION
451 SOUTH STATE STREET, ROOM 404 WWW.SLC.GOV
P.O. BOX 145486, SALT LAKE CITY, UTAH 84114-5486 TEL 801.535.6230 FAX 801.535.6005
CITY COUNCIL TRANSMITTAL
BACKGROUND/DISCUSSION:
Salt Lake City has received a request from John Van Trigt, the property owner, to amend the zoning map
for (or rezone) the property at approximately 128 N N St (Parcel ID 09323790090000) from the SR-1A
Special Development Pattern Residential District to the RMF-30 Low Density Multi-Family Residential
District. The intent of this rezone is to enable an infill development comprising of three rental housing
units behind the principal structure. The property sits on the East side of N St and one parcel South of the
corner of N St and 3rd Ave. It is currently occupied by a historic four-plex structure and six detached
garages at the rear of the lot. The four-plex would not be altered as part of this proposal, but four of the
existing detached garages would be demolished and replaced by the new housing units.
Location map of Subject Property
The SR-1A district does not permit multi-family dwellings. Multi-family and row house units can be
achieved through either zoning incentive options, the Affordable Housing Incentive or the Building
Preservation Incentive. It also limits building height to 23 feet and minimum lot size restrictions of 5,000
square feet per dwelling unit (or 4,000 square feet per unit for a twin home). The proposed RMF-30
district permits multi-family structures, allows a maximum height of 30 feet, and has a minimum lot size
restriction of 2,000 square feet per dwelling unit. The RMF-30 district also allows bonus units for infill
developments when a principal structure is retained. Per 21A.50.050.C the applicant is proposing
providing a minimum of two bedrooms in each of the newly built units for a community benefit.
Additionally, the applicant is not required to submit a plan amendment to the Avenues Future Land Use
Map, as proposed infill development is compatible with surrounding neighborhood in terms of bulk and
intensity. The project also meets the criteria in title 19 requiring compliance with the general plan.
The subject property is located in the Avenues Local Historic District. If this requested amendment is
adopted, the applicant would be required to seek approval for new construction from the Historic
Landmark Commission.
PUBLIC PROCESS:
Early Notification – On October 8, 2024, Planning staff sent the Greater Avenues Community Council
the required 45-day notice for recognized community organizations. The community council did not
request a presentation from the applicant, but sent back a letter of support for the rezone. In addition to
the notice sent to the Greater Avenues Community Council, staff also sent notices to all property owners
and occupants within 300 feet of the subject property, posted a public notice sign on the property, and
provided an online open house on the Planning Division’s website from October 2024 to February 2025.
Planning Commission Meeting – On January 22, 2025, the Planning Commission held a public hearing
for the request. The commission voted unanimously to recommend that the City Council approve the
Zoning Map Amendment request with the condition that the City Council enter into a development
agreement to ensure the agreed upon public benefit is provided by the applicant. The full public meeting
can be viewed at this link. This request begins at 19:35.
Historic Landmark Commission Meeting – On February 6, 2025, the Historic Landmark Commission
held a public hearing for the request. The commission voted unanimously to recommend that the City
Council approve the Zoning Map Amendment request. The full public meeting can be viewed at this
link. This request begins at 1:44:35.
Planning Commission (PC) Records
a) PC Agenda of January 22, 2025
b) PC Minutes of January 22, 2025
c) Planning Commission Staff Report January 22, 2025
Historic Planning Commission (HLC) Records
a) HLC Agenda of February 6, 2025
b) HLC Minutes February 6, 2025
c) Historic Landmark Commission Staff Report February 6, 2025
EXHIBITS:
1. Ordinance
2. Project Chronology
3. Notice of City Council Public Hearing
4. Staff Report
5. Mailing List
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1. ORDINANCE
1
SALT LAKE CITY ORDINANCE
No. _____ of 2025
(Amending the zoning map pertaining to a parcel of property located at 128 North N Street from
SR-1A Special Development Pattern Residential District to RMF-30 Low Density Multi-Family
Residential District)
An ordinance amending the zoning map pertaining to a parcel of property located at 128
North N Street (“Property”) from SR-1A Special Development Pattern Residential District to
RMF-30 Low Density Multi-Family Residential District pursuant to Petition No. PLNPCM2024-
01079.
WHEREAS, the Salt Lake City Planning Commission (“Planning Commission”) held a
public hearing on January 22, 2025, on an application submitted by John Van Tright, on behalf
of the owner of the Property, to rezone the Property from SR-1A Special Development Pattern
Residential District to RMF-30 Low Density Multi-Family Residential District pursuant to
Petition No. PLNPCM2024-01079; and
WHEREAS, at its January 22, 2025, meeting, the Planning Commission voted in favor of
forwarding a positive recommendation to the Salt Lake City Council (“City Council”) on said
petition; and
WHEREAS, at its February 6, 2025, meeting, the Salt Lake City Historic Landmarks
Commission held a public hearing on the petition and also voted in favor of forwarding a
positive recommendation to the City Council on said petition; and
WHEREAS, after a public hearing on this matter, the City Council has determined that
adopting this ordinance is in the city’s best interests.
NOW, THEREFORE, be it ordained by the City Council of Salt Lake City, Utah:
SECTION 1. Amending the Zoning Map. The Salt Lake City zoning map, as adopted
by the Salt Lake City Code, relating to the fixing of boundaries and zoning districts, shall be and
2
hereby is amended to reflect that the Property, as more particularly described on Exhibit “A”
attached hereto, shall be and hereby is rezoned from SR-1A Special Development Pattern
Residential District to RMF-30 Low Density Multi-Family Residential District.
SECTION 2. Condition. This map amendment is conditioned upon the owner of the
Property entering into a development agreement requiring that any new dwelling unit on the
Property be comprised of at least two bedrooms before a certificate of occupancy is issued for
such dwelling unit.
SECTION 3. Effective Date. This ordinance shall become effective on the date of its
first publication and shall be recorded with the Salt Lake County Recorder. The Salt Lake City
Recorder is instructed to not publish this ordinance until the condition set forth in Section 2 is
satisfied as certified by the Salt Lake City Planning Director or his designee.
SECTION 4. Time. If the condition set forth in Section 2 above has not been met within
one year after adoption, then this ordinance shall become null and void. The City Council may,
for good cause shown, by resolution, extend the time period for satisfying the condition
identified above.
Passed by the City Council of Salt Lake City, Utah, this ______ day of ______________,
2025.
______________________________
CHAIRPERSON
ATTEST AND COUNTERSIGN:
______________________________
CITY RECORDER
Transmitted to Mayor on _______________________.
3
Mayor's Action: _______Approved. _______Vetoed.
______________________________
MAYOR
______________________________
CITY RECORDER
(SEAL)
Bill No. ________ of 2025.
Published: ______________.
Ordinance Rezoning 128 North N St to RMF-30_v1
APPROVED AS TO FORM
Salt Lake City Attorney’s Office
Date:__________________________________
By: ___________________________________
Katherine D. Pasker, Senior City Attorney
April 21, 2025
4
Exhibit “A”
Legal description of the Property
Tax ID No. 09-32-379-009-0000
Parcel 1:
Commencing 12-1/2 feet North of the Southwest comer of Lot 3, Block 24, Plat G, Salt Lake
City, Survey; and running thence North 70 feet; thence East 165 feet; thence South 70 feet;
thence West 165 feet to the point of beginning.
Parcel 1A (Easement Estate):
Together with a Shared Access Easement as created by that certain Declaration recorded June 2,
2005 as Entry No. 9393224, Book 9139, Page 7344 of Official Records, more particularly
described as follows:
Beginning at the Northwest comer of Lot 2, Block 24, Plat G, Salt Lake City Survey and running
thence North 00°00'26" West along the Westerly line of said Block 24, 20.50 feet; thence North
89°52'50" East 128.50 feet; thence North 23.83 feet; thence East 36.59 feet to a point on the
Westerly line of Lot 4 of said Block 24, thence South 00°00'17" West along said Westerly line
12.01 feet; thence West 18.59 feet; thence South 20.29 feet; thence West 4.58 feet; thence South
7.97 feet; thence West 25.01 feet; thence South 89°43'40" West 12.59 feet; thence South 1.21
feet; thence North 89°45'09" West 11.68 feet; thence South 00°03'58" East 2.64 feet; thence
South 89°56'02" West 30.26 feet; thence South 85°19'18" West 3.68 feet to a point on the North
line of said Lot 2; thence South 89°52'50" West along said North line 58.72 feet to the point of
beginning.
Parcel 1B (Easement Estate):
Together with a Common Entrance Easement as created by that certain Amended and Restated
Declaration recorded March 13, 2006 as Entry No. 9660652, Book 9265, Page 8769 of Official
Records, more particularly described as follows:
Beginning at a point on the Westerly line of said Block 25, said point being South 00°00'26"
West along said Westerly line 144.62 feet from the Northwest comer of said Block 24, and
running thence North 89°52'50" East 126.64 feet; thence South 00°41'34" East 16.44 feet; thence
West 9.92 feet; thence South 89°43'40" West 116.92 feet to said Westerly line; thence North
00°00'26" East along said Westerly line 16.73 feet to the point of beginning.
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2. PROJECT
CHRONOLOGY
ERIN MENDENHALL DEPARTMENT of COMMUNITY
Mayor and NEIGHBORHOODS
Blake Thomas
Director
SALT LAKE CITY CORPORATION
451 SOUTH STATE STREET, ROOM 404 WWW.SLC.GOV
P.O. BOX 145486, SALT LAKE CITY, UTAH 84114-5486 TEL 801.535.6230 FAX 801.535.6005
PROJECT CHRONOLOGY
Petition: PLNPCM2024-01079
September 19, 2024 Petition for the zoning map amendment received by the Salt Lake City Planning
Division.
October 8, 2024 Petition assigned to Alicia Seeley, Principal Planner.
October 8, 2024 Information about the proposal was sent to the Greater Avenues Community
Council to solicit public comments and start the 45-day Recognized Organization
input and comment period.
October 8, 2024 Planning staff sent an early notification announcement of the project to all
residents and property owners living within 300 feet of the project site, providing
information about the proposal and how to give public input on the project.
Oct 2024-Feb 2025 Planning staff hosted an online Open House to solicit public comments on the
proposal.
Nov 2024-Jan 2025 Planning staff worked with the applicant to improve the quality of their application
material, including revising the requested zone to better fit the neighborhood
context, reviewing options for meeting the Community Benefit requirements, and
addressing concerns brought up by the community.
January 7, 2025 Planning Staff posted notices on City and State websites and sent notices via the
Planning list serve for the Planning Commission meeting on January 22, 2025.
Public hearing notice mailed.
January 8, 2025 Applicant adjusted their application and proposed zoning district based on
concerns brought up through public comments and staff feedback.
January 10, 2025 Planning staff posted a public hearing notice sign with project information and
notice of the Planning Commission public hearing on the property.
January 22, 2025 The Planning Commission held a public hearing for the request. By a vote of 6-0,
the Planning Commission forwarded a positive recommendation to the City
Council for the proposed zoning map amendment.
January 22, 2025 Planning Staff posted notices on City and State websites and sent notices via the
Planning list serve for the Historic Landmark Commission meeting on February 6,
2025. Public hearing notice mailed.
January 25, 2025 Planning staff posted a public hearing notice sign with project information and
notice of the Historic Landmark Commission public hearing on the property.
February 6, 2025 The Historic Landmark Commission held a public hearing for the request. By a
vote of 7-0, the Historic Landmark Commission forwarded a positive
recommendation to the City Council for the proposed zoning map amendment.
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3. NOTICE OF CITY COUNCIL PUBLIC
HEARING
SALT LAKE CITY CORPORATION
451 SOUTH STATE STREET, ROOM 404 WWW.SLC.GOV
P.O. BOX 145486, SALT LAKE CITY, UTAH 84114-5486 TEL 801.535.6230 FAX 801.535.6005
NOTICE OF PUBLIC HEARING
The Salt Lake City Council is considering Petition PLNPCM2024-01079 128 N N St Rezone. Salt
Lake City has received a request from John Van Trigt, the property owner, to amend the zoning map
for (or rezone) the property at approximately 128 N N St (Parcel ID 09323790090000) from the SR-
1A Special Development Pattern Residential District to the RMF-30 Low Density Multi-Family
Residential District. The intent of this rezone is to enable the development of three residential infill
rental housing units behind the primary structure on the property. The property sits on the East side of
N St one parcel South of the corner of N St and 3rd Avenue.
As part of their study, the City Council is holding an advertised public hearing to receive comments
regarding the petition. During this hearing, anyone desiring to address the City Council concerning
this issue will be given an opportunity to speak. The hearing will be held:
DATE:
PLACE: Electronic and in-person options.
451 South State Street, Salt Lake City, Utah
** This meeting will be held via electronic means while also providing an in-person opportunity
to attend or participate in the hearing at the City and County Building, located at 451 South
State Street, Room 326, Salt Lake City, Utah. For more information, including WebEx
connection information, please visit www.slc.gov/council/virtual-meetings. Comments may also
be provided by calling the 24-Hour comment line at 801.535.7654 or sending an email to
council.comments@slcgov.com. All comments received through any source are shared with the
Council and added to the public record.
If you have any questions relating to this proposal or would like to review the file, please call Alicia
Seeley at 801.535.7922 between the hours of 9:00 a.m. and 5:00 p.m., Monday through Friday, or by
e-mail at alicia.seeley@slcgov.com. The application details can be accessed at
https://www.slc.gov/planning/2024/10/29/openhouse2024-01079/.
The City & County Building is an accessible facility. People with disabilities may make requests for
reasonable accommodation, which may include alternate formats, interpreters, and other auxiliary aids
and services. Please make requests at least two business days in advance. To make a request, please
contact the City Council Office at council.comments@slcgov.com, 801-535-7600, or relay service
711.
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5. MAILING LIST
OWN_FULL_NAME OWN_ADDR own_unit OWN_CITY OWN_STATE OWN_ZIP
DREW SHARP; SARAH WILLS (JT)821 E THIRD AVE SALT LAKE CITY UT 84103
THIRD AVENUE INVESTMENTS, LLC 11113 S OLD ROSEBUD LN SOUTH JORDAN UT 84095
STEFFEY REVOCABLE TRUST 12/30/2008 786 PARK WY SOUTH SAN FRANCISCO CA 94080
HANSEN LIVING TRUST 04/17/2023 659 N LOMA VISTA CIR MESA AZ 85213
TRUST NOT IDENTIFIED 1791 E MICHIGAN AVE SALT LAKE CITY UT 84108
TRUST NOT IDENTIFIED 164 N N ST SALT LAKE CITY UT 84103
TOTH-STOESSER LLC 327 N I ST SALT LAKE CITY UT 84103
JARED MEADORS PO BOX 541842 HOUSTON TX 77254
SANDRA KOPANON 859 E THIRD AVE # 2 SALT LAKE CITY UT 84103
KYLIE KATICH; ALEX KATICH (JT)867 E THIRD AVE SALT LAKE CITY UT 84103
HEATHER ROCHELLE CURTIS 873 E THIRD AVE SALT LAKE CITY UT 84103
MARTHA T GONZALES; EDUARDO A VALDEZ (JT)879 E THIRD AVE SALT LAKE CITY UT 84103
MARTHA T GONZALES; EDUARDO A VALDEZ (JT)879 E THIRD AVE SALT LAKE CITY UT 84103
TRUST NOT IDENTIFIED 881 E THIRD AVE SALT LAKE CITY UT 84103
HAO NGOC EVANS TRUST 12/23/2015 887 E THIRD AVE SALT LAKE CITY UT 84103
SUSAN L DICKINSON 818 E THIRD AVE SALT LAKE CITY UT 84103
820 EAST 3RD AVE LLC 4120 BONAVILLA DR OGDEN UT 84403
LESLIE G KELEN; JOYCE A KELEN (JT)128 N M ST SALT LAKE CITY UT 84103
HEATHER HOLMES REVOCABLE TRUST 12/20/20 124 N M ST SALT LAKE CITY UT 84103
TRISTAN KM MOORE; KRISTY L MOORE (JT)14624 72ND ST E 96 SUMNER WA 98390
LANDWEST, LLC 2074 E MARYLAND CIR HOLLADAY UT 84124
R&JKFT 827 E SECOND AVE SALT LAKE CITY UT 84103
COLOMBIA-WASATCH LLC 535 SW WINTER CIR PULLMAN WA 99163
FRED J EVANS 133 N N ST SALT LAKE CITY UT 84103
TRUST NOT IDENTIFIED; ROBERT A DAY PO BOX 11959 SALT LAKE CITY UT 84147
ALE A GICQUEAU 1930 VILLAGE CENTER CIR LAS VEGAS NV 89134
LANDWEST, LLC 2074 E MARYLAND CIR HOLLADAY UT 84124
119 NORTH N STREET, LLC 11616 S STATE ST # 1504 DRAPER UT 84020
JONATHAN EUGENE HOLLOWAY 7230 E 1000 N HUNTSVILLE UT 84317
JO ANN WHIRLEDGE 103 N N ST SALT LAKE CITY UT 84103
DAVID W PETERS 872 E THIRD AVE SALT LAKE CITY UT 84103
BECKIE A BRADSHAW LIVING TRUST 05/19/2020 878 E THIRD AVE SALT LAKE CITY UT 84103
PATRICIA OWEN 884 E THIRD AVE SALT LAKE CITY UT 84103
JOHN C CANDELARIA 1564 W ALMOND LN WEST JORDAN UT 84088
DP FAM TRUST 888 E THIRD AVE SALT LAKE CITY UT 84103
BUSHWEEK, LLC PO BOX 2753 SALT LAKE CITY UT 84110
WILL & ALEX LLC 10799 LAS POSAS RD CAMORILLO CA 93012
DP FAM TRUST 888 E THIRD AVE SALT LAKE CITY UT 84103
MICHAEL GARRY CRANDALL REVOCABLE TRUST 0118 N N ST SALT LAKE CITY UT 84103
ROBERT JAMES SYLVESTER 853 E SECOND AVE SALT LAKE CITY UT 84103
DANIEL ERMANN; VICTORIA VARDELL (JT)859 E SECOND AVE SALT LAKE CITY UT 84103
ANDREA R GLOBOKAR TRUST 02/17/2023 PO BOX 9070 SALT LAKE CITY UT 84109
MARY A STONEMAN 865 E SECOND AVE SALT LAKE CITY UT 84103
WALTER M WILHELM; NATALIE B WILHELM (JT)7061 SUNLIGHT DR HUNTINGTON BEACH CA 92647
KATHERINE G HOLMSTROM; SCOTT T HOLMSTRO 879 E SECOND AVE SALT LAKE CITY UT 84103
BORGENICHT-LAMBERT FAMILY TRUST 08/07/20881 E SECOND AVE SALT LAKE CITY UT 84103
TRUST NOT IDENTIFIED 111 N O ST SALT LAKE CITY UT 84103
158 E 1460 N OREM UT 84057
860 E 3RD AVE TH LLC 11707 S MORNING POINT WY SOUTH JORDAN UT 84009
860 E 3RD AVE TH LLC 11707 S MORNING POINT WY SOUTH JORDAN UT 84009
860 E 3RD AVE TH LLC 11707 S MORNING POINT WY SOUTH JORDAN UT 84009
860 E 3RD AVE TH LLC 11707 S MORNING POINT WY SOUTH JORDAN UT 84009
860 E 3RD AVE TH LLC 11707 S MORNING POINT WY SOUTH JORDAN UT 84009
860 E 3RD AVE TH LLC 11707 S MORNING POINT WY SOUTH JORDAN UT 84009
KIMBERLY FRAZER MCKINLEY 89 N N ST SALT LAKE CITY UT 84103
ALEXANDER M MCCOMBS 90 N N ST SALT LAKE CITY UT 84103
VICTORIA LIN 86 N N ST SALT LAKE CITY UT 84103
JOSEPH HUGH KAMERATH; TAMARA KIDD KAME 866 E SECOND AVE SALT LAKE CITY UT 84103
ZACHARY E IMEL; KAREN W TAO (JT)870 E SECOND AVE SALT LAKE CITY UT 84103
WALTER S PALMER; SANDRA K PALMER (JT)46 HINCKLEY RD MILTON MA 02186
JOSEPH HUGH KAMERATH; TAMARA KIDD KAME 868 E SECOND AVE SALT LAKE CITY UT 84103
LINDA GAIL KUHN LERUTH; MIRANDA EVE KUHN 122 N N ST 1 SALT LAKE CITY UT 84103
JESSICA WESTON STILES 122 N N ST SALT LAKE CITY UT 84103
DEANNE R WILLIAMS FAMILY TRUST 09/02/2008122 N N ST 3 SALT LAKE CITY UT 84103
TERESA WHARTON; KYLE WHARTON (JT)PO BOX 263 MIDWAY UT 84049
MARK J STUBBS 506 W 100 S # 154 SALT LAKE CITY UT 84101
GRACE BROWN 122 N N ST # 6 SALT LAKE CITY UT 84103
JERRY D GODWIN; LISA L GODWIN (JT)1317 SALMON FALLS RD EL DORADO HILLS CA 95762
JAMES CARRINGTON; PATRICK N BURNAH (JT)122 N N ST 8 SALT LAKE CITY UT 84103
ANNE MARIE L ALFRED; CAROLINE M ALFRED; JA 122 N N ST 9 SALT LAKE CITY UT 84103
ANNE MERCEDES GOODMAN; DILLON SCOTT BE 20041 OSTERMAN RD #U1 LAKE FOREST CA 92630
NOTTING COURT CONDOMINIUMS OWNERS ASS1949 E MURRAY HOLLADAY RD HOLLADAY UT 84117
JUILIA D SILGE; ROBERT L SILGE (JT)903 E THIRD AVE SALT LAKE CITY UT 84103
DOMINIC J SMITH; SHALENE A SMITH (JT)1820 E SIGGARD DR MILLCREEK UT 84106
JEAN-JACQUES D GROSSI; SONJA T GROSSI (JT)124 N O ST SALT LAKE CITY UT 84103
STEVEN E SWENSON 120 N O ST SALT LAKE CITY UT 84103
WILLIAM THOMAS XANDO NEVINS 118 N O ST SALT LAKE CITY UT 84103
DAVID R BEAUFORT; M LINDA BEAUFORT (JT)116 N O ST SALT LAKE CITY UT 84103
KARLIAN LEE ZUCKERMAN GIFT TRUST 04/14/20 903 E SECOND AVE SALT LAKE CITY UT 84103
Current Occupant 821 E 3RD AVE Salt Lake City UT 84103
Current Occupant 825 E 3RD AVE Salt Lake City UT 84103
Current Occupant 827 E 3RD AVE Salt Lake City UT 84103
Current Occupant 829 E 3RD AVE Salt Lake City UT 84103
Current Occupant 166 N N ST Salt Lake City UT 84103
Current Occupant 167 N O ST Salt Lake City UT 84103
Current Occupant 851 E 3RD AVE Salt Lake City UT 84103
Current Occupant 859 E 3RD AVE Salt Lake City UT 84103
Current Occupant 867 E 3RD AVE Salt Lake City UT 84103
Current Occupant 873 E 3RD AVE Salt Lake City UT 84103
Current Occupant 879 E 3RD AVE Salt Lake City UT 84103
Current Occupant 879 E 3RD AVE EAST Salt Lake City UT 84103
Current Occupant 881 E 3RD AVE Salt Lake City UT 84103
Current Occupant 887 E 3RD AVE Salt Lake City UT 84103
Current Occupant 818 E 3RD AVE Salt Lake City UT 84103
Current Occupant 820 E 3RD AVE Salt Lake City UT 84103
Current Occupant 817 E 2ND AVE Salt Lake City UT 84103
Current Occupant 823 E 2ND AVE Salt Lake City UT 84103
Current Occupant 827 E 2ND AVE Salt Lake City UT 84103
Current Occupant 149 N N ST Salt Lake City UT 84103
Current Occupant 127 N N ST Salt Lake City UT 84103
Current Occupant 123 N N ST Salt Lake City UT 84103
Current Occupant 823 E 2ND AVE NFF1 Salt Lake City UT 84103
Current Occupant 119 N N ST Salt Lake City UT 84103
Current Occupant 109 N N ST Salt Lake City UT 84103
Current Occupant 872 E 3RD AVE Salt Lake City UT 84103
Current Occupant 878 E 3RD AVE Salt Lake City UT 84103
Current Occupant 884 E 3RD AVE Salt Lake City UT 84103
Current Occupant 886 E 3RD AVE Salt Lake City UT 84103
Current Occupant 888 E 3RD AVE Salt Lake City UT 84103
Current Occupant 119 N O ST Salt Lake City UT 84103
Current Occupant 128 N N ST Salt Lake City UT 84103
Current Occupant 117 N O ST NFF1 Salt Lake City UT 84103
Current Occupant 853 E 2ND AVE Salt Lake City UT 84103
Current Occupant 859 E 2ND AVE Salt Lake City UT 84103
Current Occupant 863 E 2ND AVE Salt Lake City UT 84103
Current Occupant 865 E 2ND AVE Salt Lake City UT 84103
Current Occupant 871 E 2ND AVE Salt Lake City UT 84103
Current Occupant 879 E 2ND AVE Salt Lake City UT 84103
Current Occupant 881 E 2ND AVE Salt Lake City UT 84103
Current Occupant 868 E 3RD AVE Salt Lake City UT 84103
Current Occupant 860 E 3RD AVE Salt Lake City UT 84103
Current Occupant 860 E 3RD AVE Salt Lake City UT 84103
Current Occupant 860 E 3RD AVE Salt Lake City UT 84103
Current Occupant 860 E 3RD AVE Salt Lake City UT 84103
Current Occupant 860 E 3RD AVE Salt Lake City UT 84103
Current Occupant 860 E 3RD AVE Salt Lake City UT 84103
Current Occupant 866 E 2ND AVE Salt Lake City UT 84103
Current Occupant 870 E 2ND AVE Salt Lake City UT 84103
Current Occupant 81 N O ST Salt Lake City UT 84103
Current Occupant 868 E 2ND AVE Salt Lake City UT 84103
Current Occupant 122 N N ST 4 Salt Lake City UT 84103
Current Occupant 122 N N ST 5 Salt Lake City UT 84103
Current Occupant 122 N N ST 6 Salt Lake City UT 84103
Current Occupant 122 N N ST 7 Salt Lake City UT 84103
Current Occupant 122 N N ST 10 Salt Lake City UT 84103
Current Occupant 122 N N ST Salt Lake City UT 84103
Current Occupant 903 E 3RD AVE Salt Lake City UT 84103
Current Occupant 906 E 3RD AVE Salt Lake City UT 84103
Current Occupant 903 E 2ND AVE Salt Lake City UT 84103
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4. STAFF REPORT
PLNPCM2024-01079 1 February 6, 2025
PLANNING DIVISION
DEPARTMENT of COMMUNITY and NEIGHBORHOODS
Staff Report
To: Salt Lake City Historic Landmarks Commission
From: Alicia Seeley, Principal Planner, alicia.seeley@slc.gov, 801-535-7922
Date: February 6, 2025
Re: PLNPCM2024-01079: Zoning Map Amendment from SR-1A Special Development
Pattern Residential District to RMF-30 Low Density Multi-Family Residential
District at 128 N N St
Zoning Map Amendment
PROPERTY ADDRESS: 128 N N ST
PARCEL ID: 09-32-379-009-0000
GENERAL PLAN: Avenues Plan
CURRENT ZONING DISTRICT: SR-1A Special Pattern Residential District
PROPOSED ZONING DISTRICT: RMF-30 Low Density Multi-Family Residential District
COUNCIL DISTRICT: District 3, Chris Wharton
REQUEST:
John Van Trigt, representing the property owner, is requesting to amend the zoning map for the
property located at approximately 128 N N St from the SR-1A Special Development Pattern Residential
District to RMF-30 Low Density Multi-Family Residential District. The intent of this rezone is to add
three new residential units with attached garages. To address additional parking needs, the applicant
intends to construct two free-standing carports. The historic four-plex currently located on the subject
property would not be altered and no tenants would be displaced.
RECOMMENDATION:
Based on the findings in this report, Planning staff recommends that the Historic Landmarks
Commission forward a positive recommendation to the City Council for the proposed Zoning Map
Amendment with the following condition:
1. That City Council enter into a development agreement to ensure the agreed upon
public benefit, which is that each of the newly built units provides a minimum of two
bedrooms, is provided prior to a certificate of occupancy being issued for any building
within the future development.
ATTACHMENTS:
A. ATTACHMENT A: Location Map
B. ATTACHMENT B: Applicant Submission
C. ATTACHMENT C: Site Photos
PLNPCM2024-01079 2 February 6, 2025
D. ATTACHMENT D: Zoning District Comparison
E. ATTACHMENT E: General Plan Policies
F. ATTACHMENT F: Analysis of Relevant Standards
G. ATTACHMENT G: Public Process & Comments
H. ATTACHMENT H: Department Review Comments
PROJECT DESCRIPTION
Background
This request is for a zoning map amendment for the property located at approximately 128 N N
St. Specifically, the applicant has requested to rezone the property from the current SR-1A Special
Development Pattern Residential District to RMF-30 Low Density Multi-Family Residential
District. The property sits on the east side of N St, one parcel south of 3rd Ave. It is currently
occupied by a historic four-plex residence fronting N St. To the south of the historic four-plex is a
driveway providing access to five rear garages; 4 on the north property line, and one in the
southeast corner (see the map below or in Attachment A). The subject property is located in the
Avenues Local Historic District and the existing 4-plex is identified as a contributing structure to
the district. The regulations found in 21A.34.020.H are applicable to this property.
PLNPCM2024-01079 3 February 6, 2025
Intent of the Zoning Amendment Request
The applicant, John Van Trigt, has submitted this request with the intent to add three residential
infill units to the rear of the property. While official development plans and building designs have
not yet been produced, a preliminary site plan was included with the submission for reference.
That preliminary plan and all other materials submitted by the applicant can be found in
Attachment B.
The SR-1A district does not permit construction of multi-family dwellings unless they are part of
an adaptive reuse project in eligible buildings. The maximum building height allowed in the SR-
1A district is twenty-three feet (23’) for a pitched roof and sixteen feet (16’) for a flat roof. These
height limitations would not allow for dwellings to be built on top of garage units.
If the Salt Lake City Council adopts this rezone request, the applicant would then need to submit
the necessary development applications, and the project would need to comply with all relevant
regulations within the Salt Lake City Zoning Ordinance. Review by the Planning Commission
would be required if the applicant requests modifications to zoning regulations through the
Planned Development or Design Review processes. Since this request is not for the development
of the site, Planning staff has not reviewed the submitted plans for compliance with applicable
zoning requirements.
Existing and Proposed Zoning Districts
The following provides an overview of the existing and proposed zoning designations. Attachment
D provides a detailed comparison of each district’s standards.
Existing Zoning District – SR-1A Special Development Pattern Residential District
The subject site and all adjacent properties, with the exception of the property directly north, are
zoned SR-1A. The SR-1A district is intended to promote the character of older, predominantly
single-family and two-family dwelling neighborhoods. It encourages low intensity, small-scale
residential uses.
PLNPCM2024-01079 4 February 6, 2025
Proposed Zoning District – RMF-30 Low Density Multi-Family Residential District
The primary intent of the RMF-30 district is to maintain the physical character of established
neighborhoods while allowing for incremental growth through the integration of small-scale
multi-family building types. It promotes new development to provide increased housing
opportunities that are compatible in mass and scale with existing structures.
Comparison
While both these districts are intended to promote low density residential development, the RMF-
30 district allows for greater variety in height and bulk standards, as well as a modest increase in
density from the SR-1A district. Both districts are appropriate for the Avenues neighborhood
context, but the RMF-30 district will allow for gentle infill development that would not be
permitted in SR-1A. For additional information on the comparison of the development and land
use allowances see Attachment D.
Neighborhood Context
Historic Preservation Overlay
The subject property is located in a Historic Preservation Overlay District and is considered an eligible
or contributing structure. As such, it is subject to regulations as outlined in 21A.34.010:G. In the case
of new construction, the historic landmark commission shall determine whether the project
substantially complies with adopted preservation standards to ensure that the proposed project fits
into the established context in ways that respect and contribute to the evolution of Salt Lake City’s
architectural and cultural traditions. The future new construction will be reviewed by the Historic
Landmark Commission. More information on the historic status of the structure can be found in the
attachments to this report.
Property and Surrounding Zoning Districts
PLNPCM2024-01079 5 February 6, 2025
Characteristics
As discussed earlier in this report, the subject property is occupied by a historic multi-family building
with four dwelling units. Buildings within the vicinity are strictly residential uses and contain mostly
single-family homes and a few condo units and multi-family homes. To the immediate south along N
Street are the Notting Court Condominiums, and to the immediate north on the corner of N Street and
3rd Avenue are the newly built townhomes zoned R-MU-35. Buildings along N street are mostly one to
two stories in height, but the properties on either side of the subject site are three stories.
Amenities
The surrounding neighborhood is almost exclusively residential use. The subject site is located about a
block and a half directly south of the Salt Lake City Cemetery. The closest grocery store is Smiths,
located approximately one mile away. There are also a few amenities such as coffee shops and small
cafes within a mile of the property. The nearest school is Wasatch elementary, located approximately
half a mile southeast of the property, and the nearest public park is Dr Ellis Reynolds Shipp Park,
located half a mile west of the property.
Infrastructure and Public Services
Transportation
This neighborhood is fairly car-dependent for residents’ daily needs. The closest walkable public transit
amenity is the bus stop located at 3rd Ave/N St, with service via UTA bus route 223, which runs once an
hour. The nearest frequent bus service is route 1 which runs along South Temple, with the nearest stop
located 0.3 miles from the site (approximately a 5-minute walk). The neighborhood is relatively
Historic Photo of the Subject Property
PLNPCM2024-01079 6 February 6, 2025
pedestrian and bike friendly, with a dedicated bike lane along 3rd Ave and a robust network of
sidewalks.
Utilities
Public Utilities staff reviewed the proposed site plan and noted that the proposed densification may
place greater demands on water, sewer, and storm drain systems, which could exceed the capacity
of the existing infrastructure. In that case, the property owners and developers would be required
to upgrade the offsite public utilities to ensure sufficient capacity for the new development. (see
Attachment H for additional discussion from the department of Public Utilities)
APPROVAL PROCESS AND COMMISSION AUTHORITY
Review Processes: Zoning Map Amendment
Zoning map amendment proposals are legislative decisions reviewed against a set of
considerations from the Zoning Ordinance (found in section 21A.50.050.B). Those considerations
are listed in Attachment F. Planning staff is required by ordinance to analyze proposed zoning
map amendments against existing adopted City policies and other related adopted City
regulations, as well as consider how a zoning map amendment will affect adjacent properties. The
Planning Commission must recommend approval or denial of the amendment to the City Council
and should do so based on their review of the applicable considerations. Ultimately, a decision to
amend the zoning map is up to the discretion of the City Council, who are not held to any one
standard.
KEY CONSIDERATIONS
Planning staff reviewed this proposal and identified the following key considerations:
1. General Plan Compatibility
2. Neighborhood Concerns
Consideration 1: General Plan Compatibility
The standards for zoning map amendments (21A.50.050.B) suggest that rezone requests should
be consistent with “the purposes, goals, objectives, and policies of the City as stated through its
various adopted planning documents.” In other words, the request should ideally align with stated
policies in the City’s adopted plans. Planning staff’s analysis of the proposed amendment’s
compliance with specific applicable initiatives within each plan can be found in Attachment E.
Plan Salt Lake (2015)
Policy Statement 1: "Density in the appropriate locations, including near existing
infrastructure, compatible development, and major transportation corridors, can help
to accommodate future growth more efficiently. This type of compact development
allows people to live closer to where they work, recreate, shop, and carry out their daily
lives, resulting in less automobile dependency and greater mobility"
Discussion: The Avenues neighborhood offers a complete network of existing
infrastructure and safe and pleasant pedestrian conditions. A reasonable increase
in density in this neighborhood can promote walkability.
PLNPCM2024-01079 7 February 6, 2025
Policy Statement 2: "It will be critical for us to encourage and support a diversity of
new housing options and types with a range of densities throughout the City to best
meet the changing population."
Discussion: The proposed rezone would allow the development of rental
housing other than single-family detached homes or a large apartment building.
It will also provide two-bedroom units, increasing housing options for renters in
the neighborhood.
Policy Statement 3: “Initiative: Enable moderate density increases within existing
neighborhoods where appropriate.”
Discussion: The proposed rezone would allow for a moderate density increase
that is not permitted under current zoning regulations.
Avenues Plan (1987)
Policy Statement 1: “Many of the incompatibility problems created by new
construction in residential areas are associated with excessing building height; new
dwellings that tower over adjacent homes, and second-level or rear additions that
overwhelm the original structure."
Discussion: The RMF-30 zoning district has a maximum height of 30 feet,
which would allow the desired infill development without overwhelming the
original four-plex on the subject lot.
Policy Statement 2: Future land use map designation.
Discussion: According to the future land use map in the Avenues plan, the
subject site is listed as appropriate for ‘low density development’, being
PLNPCM2024-01079 8 February 6, 2025
identified in the plan as 4-8 units per gross acre. The proposed infill would bring
this property to a higher density than the plan calls for. However, planning staff
analysis finds that a future land use map amendment is not needed, as the
surrounding neighborhood has grown since this plan was written to allow
moderate density increases in the immediate vicinity. The proposed infill
development is therefore compatible with the bulk and intensity of the block on
which it is located. Additionally, in accordance with Title 19.02.040:B.1,
community plans and associated land use plans for the city that include a future
land use map or description of future development characteristics qualify as
element plans and are part of the general plan. As this proposal is supported by
Plan Salt Lake and other relevant housing plans that provide direction for future
changes to the zoning code, it meets the criteria outlined in title 19 requiring
compliance with the general plan of Salt Lake City.
Thriving in Place (2023)
Policy Statement 1: “Create and preserve rental housing and ownership options in all
part of the city, especially housing that is affordable in perpetuity. More affordable
housing is needed, of different types, and in every neighborhood.”
Discussion: The proposed rezone is intended to allow the creation of more
rental housing which intends to serve the needs of small families.
Policy Statement 2: " Support zoning and code changes as well as City investments
that help to create more middle housing types in neighborhoods throughout the city.”
Discussion: The proposed change will allow additional housing units that would
be classified as a type of middle housing.
Housing SLC 2023-2027 (2022)
Policy Statement 1: “Increase housing options and choices everywhere. Create gentle
infill and rental housing opportunities in every neighborhood.”
Discussion: The proposed rezone would allow gentle infill where it is not
currently permitted and increase the supply of rental units in the Avenues.
Policy Statement 2: “”Promote the development of affordable family-sized housing
Discussion: The additional housing units being proposed will each include two
bedrooms and are intended to provide family-sized housing.
Consideration 2: Neighborhood Concerns
Planning staff received several comments from surrounding residents (included in Attachment
G). While a handful were in support of the proposal, many expressed concerns. Planning staff
reviewed these comments and found that the majority of concerns were related to negative
impacts from the recent townhome development on the corner of N Street and 3rd Avenue, and
lack of parking. Staff made sure to consider these concerns while reviewing the proposal’s
compliance with the required standards (which are listed and reviewed in Attachment F). A
summary of the proposal’s impact on the above-listed issues can be found below.
PLNPCM2024-01079 9 February 6, 2025
Recent abutting townhome development
Many comments from neighbors cited negative impacts experienced from the recent townhome
development on the corner of N Street and 3rd Avenue, fearing that allowing a multi-family project
on the subject property would bring similar impacts. Several comments complained of the
disruptive construction noise, lack of maintenance and upkeep on the property, and the highly
unaffordable prices of the new units. This development is still vacant and is seen as an undesirable
project by surrounding residents.
Parking
Neighbors raised concerns about the plan to increase housing units on this parcel without
increasing the number of parking spaces. Current tenants of the property worry that this means
they will lose access to the garages they currently use for parking and storage. Neighbors worry
about the displacement of cars will increase demand for street parking as well as general parking
congestion in the area.
STAFF RECOMMENDATION
Staff finds that the proposed zoning map amendment is compatible with applicable master plan
policies and initiatives, and the proposed zone is compatible with the surrounding neighborhood.
Based on the information and findings listed in the staff report, it is the Planning staff’s finding
that the request generally meets the applicable standards of approval and therefore recommends
the Historic Landmarks Commission forward a positive recommendation to City Council.
NEXT STEPS
Approval or Denial of the Request
Recommendations from both the Planning Commission and Historic Landmark Commission will
then be forwarded to the City Council for their consideration as part of the final decision on this
petition. If the council approves the proposed Zoning Amendment, the applicant may proceed
with their stated proposal or any other development proposal that complies with the RMF-30
district standards and other relevant regulations.
PLNPCM2024-01079 10 February 6, 2025
ATTACHMENT A: Location Map
PLNPCM2024-01079 11 February 6, 2025
ATTACHMENT B: Applicant Submission
Note: The applicant submission has been revised since the completion of this document and no
longer reflects the current proposal.
PLNPCM2024-01079 12 February 6, 2025
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ATTACHMENT C: Site Photos
Historic four-plex, viewed from N street
Drive access on south side of property and adjacent apartment building
PLNPCM2024-01079 20 February 6, 2025
Additional garages in the southeast corner of subject lot Detached garages on north side of subject lot
North property line and grade change Detached garages viewed from existing four-plex
PLNPCM2024-01079 21 February 6, 2025
View from N street looking north Street parking on N street
View from N street looking south North property line and adjacent townhomes
PLNPCM2024-01079 22 February 6, 2025
ATTACHMENT D: Zoning District
Comparison
The proposed RMF-30 district has different development standards than the current SR-1A district. A
comparison can be found below:
Parameter SR-1A (existing) RMF-30 (proposed)
Building Height 23’ (pitched roof) or 16’ (flat
roof)
30’
Minimum Front Setback equal to the average of the
front yards of existing
buildings within the block
face
20' or the average of the block
face
Maximum Front Setback equal to
face
20' or the average of the block
face
Corner Side Setback 10’ 10’
Interior Side Setback 4’ on one side, 10’ on the
other
10’ for multi-family residential
Rear Setback Twenty-five percent (25%) of
than fifteen
(30').
Minimum of 20% lot depth,
need not exceed 25'
Minimum Lot Width None, as multi-family
dwellings not permitted
No minimum
Maximum Lot Width None, as multi-family
dwellings not permitted
110’
Minimum Lot Size None, as multi-family
dwellings not permitted
2,000 sq. ft. per dwelling unit
Open Space, Landscape
Yards, and Landscape
Buffers
None required 10’ when abutting single or two-
family, or special development
district
Design Standards
While the SR-1A district is not subject to additional design standards, RMF-30 requires adherence to
certain standards (found in Chapter 21.A.37). The table below summarizes what is required in this
district
PLNPCM2024-01079 23 February 6, 2025
Parameter RMF-30 (proposed)
Building Materials, ground
floor (%) (21A.37.050.B2)
At least 50% of street-facing
facades must be clad in durable
materials (excluding doors and
windows)
Building Materials, upper
floors (%) (21A.37.050.B.2)
At least 50% of street-facing
facades must be clad in durable
materials (excluding doors and
windows)
Glass: ground floor (%)
(21A.37.050.C.1)
At least 20% of the street-
facing façade’s ground floor
must have glass between 3 and
8 feet above grade
Glass: upper floor
(21A.37.050.C.2)
At least 15% of street-facing
facades must have transparent
glass
Building Entrances
(21A.37.050.D)
At least one operable building
entrance on the ground floor is
required for every street facing
façade
Blank Wall Maximum
Length (21A.37.050.E)
15 feet
Entry features
(21A.37.050.P)
Each required entrance per
Section 21A.37.050.D
and 21A.37.050.L of this title
shall include a permitted entry
connected to a public sidewalk
and exterior lighting that
highlights the entryway(s).
Where a building does not have
direct public street frontage,
the entry feature should be
applied to the façade where the
determined to be located. A
two-family dwelling arranged
side by side, row house and
cottage court developments
shall include at least one entry
feature per dwelling unit
adjacent to a public street.
Uses
The following is a list of permitted and conditional uses unique to each district. Uses marked with a (C)
are conditional within their respective districts
SR-1A (existing) RMF-30 (proposed)
PLNPCM2024-01079 24 February 6, 2025
Accessory use, except those that are otherwise
specifically regulated elsewhere in this title
Accessory use, except those that are otherwise
specifically regulated elsewhere in this title
Adaptive reuse for additional uses in eligible
buildings (C)
Adaptive reuse for additional uses in eligible
buildings (C)
Affordable housing incentives development Affordable housing incentives development
Community garden (C) Community garden
Daycare center, child Daycare center, child
Dwelling, accessory unit Dwelling, accessory unit
Dwelling, assisted living facility (limited capacity)
(C)
Dwelling, assisted living facility (limited
capacity) (C)
Dwelling, congregate care facility (small) (C) Dwelling, congregate care facility (small) (C)
Dwelling, group home (small) Dwelling, group home (large) (C)
Dwelling, manufactured home Dwelling, group home (small)
Dwelling, multi- family Dwelling, manufactured home
Dwelling, single- family (detached) Dwelling, multi- family
Dwelling, twin home Dwelling, single- family (attached)
Dwelling, two- family Dwelling, single- family (detached)
Governmental facility (C) Dwelling, twin home
Home occupation Dwelling, two- family
Municipal service use, including City utility use and
police and fire station (C)
Governmental facility (C)
Open space on lots less than 4 acres in size Home occupation
Park Municipal service use, including City utility use
and police and fire station (C)
Parking, park and ride lot shared with existing use Open space on lots less than 4 acres in size
Place of worship on lots less than 4 acres in size (C) Park
School, seminary and religious institute (C) Parking, park and ride lot shared with existing
use
Urban farm Place of worship on lots less than 4 acres in size
(C)
Utility, building or structure School, seminary and religious institute (C)
Utility, transmission wire, line, pipe or pole Urban farm
PLNPCM2024-01079 25 February 6, 2025
Utility, building or structure
Utility, transmission wire, line, pipe or pole
The following are conditional uses within the SR-1A district that would be permitted within the RMF-
30 district
• Community garden
The following are not permitted uses within the SR-1A district that would be permitted within the
RMF-30 district
• Dwelling, group home (large) (Conditional)
• Dwelling, single- family (attached)
PURPOSE STATEMENTS
SR-1A: Special Development Pattern Residential District
Purpose Statement: The purpose of the SR-1 Special Development Pattern Residential District is to
maintain the unique character of older predominantly single-family and two-family dwelling
neighborhoods that display a variety of yards, lot sizes and bulk characteristics. Uses are intended to
be compatible with the existing scale and intensity of the neighborhood. The standards for the district
are intended to provide for safe and comfortable places to live and play, promote sustainable and
compatible development patterns and to preserve the existing character of the neighborhood.
RMF-30: Low Density Multi-Family Residential District
Purpose Statement: The purpose of the RMF-30 Low Density Multi-Family Residential District is to
provide area in the city for various multi-family housing types that are small scale in nature and that
provide a transition between single-family housing and larger multi-family housing developments.
The primary intent of the district is to maintain the existing physical character of established
residential neighborhoods in the city, while allowing for incremental growth through the integration
of small-scale multi-family building types. The standards for the district are intended to promote new
development that is compatible in mass and scale with existing structures in these areas along with
a variety of housing options. This district reinforces the walkable nature of multi-family
neighborhoods, supports adjacent neighborhood-serving commercial uses, and promotes alternative
transportation modes.
PLNPCM2024-01079 26 February 6, 2025
ATTACHMENT E: General Plan Policies
The tables below contain language from several adopted plans that apply to this proposal. Each table
also briefly discusses how the language may apply to the proposal and whether the proposed zoning
amendment is consistent with the adopted policy.
In general, the proposed rezone from SR-1A to RMF-30 is supported by the various adopted plans.
SUMMARY.
Plan Salt Lake (2015)
Policy or Objective Status Discussion
Pg 9 – SUSTAINABLE GROWTH & DEVELOPMENT
"Density and compact
development are important
principles of sustainable
growth, allowing for more
affordable transportation
options and creating vibrant
and diverse places. Density in
the appropriate locations…can
help to accommodate future
growth more efficiently"
Consistent The Avenues is an existing
walkable neighborhood with
making it an appropriate
compact development.
Pg 19 - GROWTH
Locate new development in
areas with existing
infrastructure and amenities,
such as transit and
transportation corridors.
Neutral/Consistent The Avenues neighborhood has
a complete network of existing
amenities and infrastructure,
with a few connections to
frequent transit.
Pg 21 - HOUSING
"... it will be critical for us to
encourage and support a
diversity of new housing
options and types with a range
of densities throughout the City
to best meet the changing
population."
Consistent Project plans to provide a
housing option other than
single family detached homes
or a large apartment building.
Pg 21 - HOUSING
Enable moderate density
increases within existing
neighborhoods where
appropriate.
Consistent
moderate density increase.
Avenues Plan (1987)
Policy or Objective Status Discussion
PLNPCM2024-01079 27 February 6, 2025
Pg 2 – LAND USE
"Reduce Building Height
Potential - Many of the
incompatibility problems
created by new construction in
residential areas are associated
with excessing building height;
new dwellings that tower over
adjacent homes, and second-
level or rear additions that
overwhelm the original
structure."
Consistent Although the rezone will allow a
moderate increase in height, by
limiting the height to 30’
consistent with RMF-30
structures will not overwhelm
the original four-plex and will
be shorter than abutting
developments on both the
north and south sides
Thriving in Place (2023)
Policy or Objective Status Discussion
Pg 48 – FACILITATE CREATION OF MORE DIVERSE HOUSING CHOICES
“Support zoning and code
changes as well as City
investments that help to create
more middle housing types in
neighborhoods throughout the
city.”
Consistent
requested in order to provide
more dwelling units that would
be classified as a middle
housing type.
“Create and preserve rental
housing and ownership options
in all part of the city, especially
housing that is affordable in
perpetuity. More affordable
housing is needed, of different
types, and in every
neighborhood.”
Consistent The Avenues is a highly
desirable neighborhood in Salt
Lake City. Adding new rental
units, especially with two or
more bedrooms, will help
expand housing options for
renters.
Housing SLC 2023-2027 (2022)
Policy or Objective Status Discussion
Pg 3 – SALT LAKE CITY’S ANTI-DISPLACEMENT STRATEGY
“Increase housing options and
choices everywhere. Create
gentle infill and rental housing
opportunities in every
neighborhood.”
Consistent The proposed rezone would
allow for a gentle infill project
that is not possible under the
regulations of the current zone.
The project also intends to
provide more rental units.
ATTACHMENT F: Analysis of Relevant
Standards
PLNPCM2024-01079 28 February 6, 2025
Zoning Map Amendment
21A.50.050: A decision to amend the text of this title of the zoning map by general amendment is a
matter committed to the legislative discretion of the City Council and is not controlled by any one
standard. In making a decision to amend the zoning map, the City Council should consider the
following:
1. Whether a proposed map amendment is consistent with and helps
implement the purposes, goals, objectives, and policies of the city as
Finding: The proposed amendment is consistent with and helps implement adopted City goals and
objectives. Key Considerations 1 and Attachment E provides a full analysis of relevant standards and
objectives in the City’s adopted planning documents.
Discussion: The proposed rezone aligns with initiatives found in multiple adopted neighborhood and
city-wide plans. Initiatives in Salt Lake City’s general plan, Plan Salt Lake (2015) call for more density
and compact development to promote sustainable growth, including allowing for moderate density
increases where appropriate. The plan also calls for supporting a mix of housing types, particularly
middle housing types, that give residents options other than single-family detached homes or large-
scale apartment buildings.
Other city-wide housing plans, including Thriving in Place (2023) and Housing SLC (2022) also set
forth policies that align with this proposal. They echo the need for increased support for middle
housing types, family-sized units, affordability at all levels, gentle infill development, and rental
housing opportunities in every neighborhood.
Finally, the Avenues Plan (1987) cautions against incompatible development that is not consistent with
height and bulk of the existing surrounding neighborhood, but designates the subject site as
appropriate for multi-family development.
2. Whether a proposed map amendment furthers the applicable purpose
statements of the zoning ordinance;
Finding: The proposed amendment generally meets the intent of applicable purpose statements
Discussion: Applicable purpose statements from the zoning ordinance are listed and discussed below
General Purpose and Intent of the Salt Lake City Zoning Ordinance
The purpose of the zoning ordinance is to promote the health, safety, morals, convenience, order,
prosperity, and welfare of the present and future inhabitants of Salt Lake City, to implement the
adopted plans of the city, and, in addition:
A. Lessen congestion in the streets or roads;
B. Secure safety from fire and other dangers;
C. Provide adequate light and air;
D. Classify land uses and distribute land development and utilization;
E. Protect the tax base;
F. Secure economy in governmental expenditures;
G. Foster the city's industrial, business, and residential development; and
H. Protect the environment.
The SR-1A and RMF-30 districts are both low-density residential districts that encourage small-scale
housing development. However, the RMF-30 district is intended to provide multi-family housing and
allows for more flexibility in lot size per unit, height, and bulk standards.
While many aspects of the general purpose statement appear to be neutral to the change, at least three
points support it: D. Classify land uses and distribute land development and utilization; G, Foster the
city’s industrial, business, and residential development; and H. Protect the environment.
PLNPCM2024-01079 29 February 6, 2025
Purpose of the Current and Proposed Zoning Districts
SR-1A Special Development Pattern Residential District
Purpose Statement: The purpose of the SR-1 Special Development Pattern Residential District is to
maintain the unique character of older predominantly single-family and two-family dwelling
neighborhoods that display a variety of yards, lot sizes and bulk characteristics. Uses are intended to
be compatible with the existing scale and intensity of the neighborhood. The standards for the district
are intended to provide for safe and comfortable places to live and play, promote sustainable and
compatible development patterns and to preserve the existing character of the neighborhood.
RMF-30 Low Density Multi-Family Residential District
Purpose Statement: The purpose of the RMF-30 Low Density Multi-Family Residential
District is to provide area in the city for various multi-family housing types that are
small scale in nature and that provide a transition between single-family housing and
larger multi-family housing developments. The primary intent of the district is to
maintain the existing physical character of established residential neighborhoods in
the city, while allowing for incremental growth through the integration of small-scale
multi-family building types. The standards for the district are intended to promote new
development that is compatible in mass and scale with existing structures in these
areas along with a variety of housing options. This district reinforces the walkable
nature of multi-family neighborhoods, supports adjacent neighborhood-serving
commercial uses, and promotes alternative transportation modes
As discussed in other areas of this report, the SR-1A and RMF-30 districts are similar in many ways.
They both promote small-scale residential development designed to be compatible with the character of
older neighborhoods. However, they differ in permitted dwelling unit types as well as height, bulk, and
lot size per unit standards. This means that RMF-30 allows for gentle infill and a moderate density
increase that would not be possible with current SR-1A regulations.
General Purpose of the Zoning Amendments Process
The purpose of this chapter is to provide standards and procedures for making amendments
to the text of this title and to the zoning map. This amendment process is not intended to relieve
particular hardships nor to confer special privileges or rights upon any person, but only to
make adjustments necessary in light of changed conditions or changes in public policy.
3. The extent to which a proposed map amendment will affect adjacent and nearby
properties due to the change in development potential and allowed uses that do
not currently apply to the property;
Finding: The proposed zoning amendment would somewhat impact the nearby properties due to the
change in development potential (modest increase in height and increased intensity), although the
allowed use will remain the same.
Discussion:
The subject site is surrounded by residential dwellings on all sides. The increased height, while
noticeable, will keep any new development at a lower height than adjacent buildings to the North and
South of the property, and will not overwhelm the original historic structure. The increased density at
the site may cause noticeable impacts to nearby properties in terms of parking demand, but should
generally be compatible with existing uses and will not affect the ability of adjacent residents to enjoy
their properties.
4. Whether a proposed map amendment is consistent with the purposes and
provisions of any applicable overlay zoning districts which may impose additional
standards;
PLNPCM2024-01079 30 February 6, 2025
Finding: The proposed map amendment is consistent with the overlaying historic district. Any
development or alteration to the site will be subject to the standards of the historic district. Any new
construction would be reviewed by the Historic Landmark Commission.
5. The adequacy of public facilities and services intended to serve the subject
property, including, but not limited to, roadways, parks and recreational
facilities, police and fire protection, schools, stormwater drainage systems, water
supplies, and wastewater and refuse collection.
Finding: Public utility infrastructure may need to be upgraded at the property owner’s expense. All
other public facilities are adequate to support the zoning change.
Discussion: Each applicable public facility is listed and discussed below (see Attachment H for
additional discussion):
• Roadways: The roads and transportation facilities intended to serve the subject property have
adequate capacity for a change to the RMF-30 district.
• Parks and Recreation Facilities: As discussed earlier in this report, the subject site is
within half a mile of Salt Lake Cemetery and several parks. The nearby park and recreational
facilities have more than adequate capacity to support this small increase in dwelling units.
• Police and Fire Protection: Fire code reviewers noted that any proposed development
would need to comply with all fire codes, but they did not indicate insufficient capacity from
nearby fire stations or an inability to develop the infill structures compliant with current
regulations.
• Schools: Several elementary schools have been closed due to the drop in enrollment within
the Salt Lake City School District. However, for that same reason, the remaining schools are
likely to be able to accommodate an increase in school-aged children. The potential increase in
school-aged children due to the addition of four dwelling units will likely be negligible.
• Public Utilities: Staff from the Department of Public Facilities have noted that the property
owner will be responsible for any upgrades to public facilities that may be required due to
increased density on the site.
6. The status of existing transportation facilities, any planned changes to the
transportation facilities, and the impact that the proposed amendment may have
on the city’s ability, need, and timing of future transportation improvements;
Finding: The proposed change will not impact the city’s ability, need, and timing of future
transportation improvements.
Discussion: The existing transportation facilities are adequate to support the zoning change. The
Transportation division has noted that they are supportive of the request (see Attachment H)
7. The proximity of necessary amenities such as parks, open space, schools, fresh
food, entertainment, cultural facilities, and the ability of current and future
residents to access these amenities without having to rely on a personal vehicle;
Finding: The site is accessible to some of the above amenities without reliance on a personal vehicle,
but the neighborhood is still fairly car dependent.
Discussion: Although there are some amenities within walking distance and a frequent bus route
nearby, most residents still rely on a personal vehicle to access a wider variety of amenities than those
available on foot or by transit.
8. The potential impacts to public safety resources created by the increase in
development potential that may result from the proposed amendment;
Finding: There are no anticipated impacts to public safety.
PLNPCM2024-01079 31 February 6, 2025
9. The potential for displacement of people who reside in any housing that is within
the boundary of the proposed amendment and the plan offered by the petitioner
to mitigate displacement;
Finding: No residents would be displaced as a result of the proposed zoning change.
Discussion: The historic four-plex on the subject site will be retained and none of the current
residents will be displaced.
10. The potential for displacement of any business that is located within the
boundary of the proposed amendment and the plan offered by the petitioner to
mitigate displacement;
Finding: There are no businesses located within the boundary of the proposed amendment.
11. The community benefits that would result from the proposed map amendment as
identified in Section 21A.50.050.C;
Finding: Staff finds that the proposed community benefit of “Providing housing that aligns with the
current or future needs of the community as determined by the general plan.” sufficiently reflects the
scale and the intent of the proposed rezone.
Discussion: Please review staff’s analysis of the Community Benefit Standards below.
Community Benefit Standards
21A.50.050.C: Each petition for a zoning amendment that is initiated by a private property owner shall
identify a community benefit(s) provided by the proposal that would not otherwise by provided without
the amendment as provided for in this section.
Type of Community Benefit
1. The proposed community benefit(s) shall be within any of the following
categories:
a. Providing housing that aligns with the current or future needs of the community as
determined by the general plan. Needs could include the level of affordability in excess of
the number of dwellings that exist on the site, size in terms of number of bedrooms, or
availability of housing for purchase;
b. Providing commercial space for local businesses or charitable organizations;
c. Providing a dedication of public open space;
d. Providing a dedication or other legal form of protection from future development of land
that is adjacent to a river, creek, wetland, floodplain, wildlife habitat, or natural lands;
e. Preserving historic structures not otherwise protected;
f. Expanding public infrastructure that expands capacity for future development.
Finding/Discussion: Staff finds that the proposed rezone and subsequent housing development
aligns with current needs of the community and is supported by initiatives and goals in the general plan
and city-wide housing plans. Those needs include the increase in housing supply, and size in terms of
number of bedrooms.
Community Benefit Standards
21A.50.050.C.2: The proposed community benefit may be evaluated based on the following, if
applicable:
PLNPCM2024-01079 32 February 6, 2025
a. For proposals that are intended to increase the housing supply, the level of
affordability of the additional density that may be allowed if the proposal were to
be adopted;
Finding: The proposed benefit does not meet this standard.
Discussion: The additional housing will be provided at market rate.
b. The percentage of space allocated to commercial use compared to the total
ground floor area that could be developed on the site;
Finding: This standard is not applicable to the proposed community benefit.
c. The size of the public open space compared to the total developable area of the
lot, exclusive of setbacks, required landscaped yards, and any open space
requirement of the proposed zoning district;
Finding: This standard is not applicable to the proposed community benefit.
d. The relative size and environmental value of any land that is to be dedicated;
Finding: This standard is not applicable to the proposed community benefit
e. The historic significance of the structures proposed to be preserved;
Finding: The proposed benefit does not meet this standard
Discussion: The historic four-plex fronting the property is already protected by the historic district
overlay and thus does not qualify for community benefit.
f. The amount of development that could be accommodated due to the increase in
public infrastructure capacity compared to the general need for the area;
Finding: The proposed benefit does not meet this standard
Discussion: Any public infrastructure improvements needed will only be made to support the
additional units on the subject site and will not expand capacity for further future development.
g. The input received related to the community benefit during the 45-day
engagement period;
Finding: The applicant adjusted the request in response to public feedback received.
Discussion: The property owner originally submitted a petition to rezone to R-MU-35 and add five
units to the subject site. After a number of concerns were raised by the public during the 45-day
engagement period, the applicant revised the proposal to request RMF-30 and add three units to the
site, in order to mitigate public concerns and keep the project compatible with the existing
neighborhood. The Greater Avenues Community Council Land Use Committee wrote a letter in favor of
the proposed rezone, stating that ‘this is a thoughtful project in an appropriate location.”
h. Policies in the general plan that support the proposed community benefit;
Finding: Adopted plans are supportive of the proposed community benefit.
Discussion: As discussed earlier in the report, the proposed rezone and subsequent housing
development aligns with current needs of the community and is supported by initiatives and goals in
the general plan and city-wide housing plans.
PLNPCM2024-01079 33 February 6, 2025
ATTACHMENT G: Public Process &
Comments
Public Notice, Meetings, Comments
The following is a list of public meetings that have been held, and other public input opportunities,
related to the proposed project since the applications were submitted:
• October 8, 2024 – The Downtown Community Council was sent the 45 day required notice
for recognized community organizations. The council did not provide comments.
• October 8, 2024 - Property owners and residents within 300 feet of the development were
provided early notification of the proposal.
• October 2024 - January 2025 – The project was posted to the Online Open House
webpage.
Notice of the public hearing for the proposal included:
• January 10, 2025
o Public hearing notice sign posted on the property
• January 10, 2025
o Public hearing notice mailed
o Public notice posted on City and State websites and Planning Division list serve
Public Input:
Planning staff received several comments opposing this proposal and a few that were supportive.
It is worth noting that during the public comment period, the requested zoning district for this
property was R-MU-35. After reviewing the public comments received as well as staff feedback,
the applicant agreed to revise the proposal to mitigate concerns and create a project that is more
compatible with the existing neighborhood, requesting to rezone to RMF-30. All public comments
received are included with this attachment.
PLNPCM2024-01079 34 February 6, 2025
ATTACHMENT H: Department Review
Comments
This proposal was reviewed by the following departments. Any requirement identified by a City
Department is required to be complied with.
Engineering: Scott Weiler - Scott.Weiler@slc.gov
No objections
Transportation: Jena Carver – Jena.Carver@slc.gov
Given the modification to the site plan and reduction in the required parking due to the
building preservation incentives, Transportation has no concerns with the proposed
rezone.
Fire: Doug Bateman - Douglas.Bateman@slc.gov
Unsure of building heights and the maximum distance from fire access roads to all ground
level exterior walls as the hose would be deployed. If they are proposing to use the shared
drive as part of fire access, it would need to be rated for 75,000 pounds and have no
parking signs installed. The verification would need to be come from an engineering
analysis.
Public Utilities: Kristeen Beitel - Kristeen.Beitel@slc.gov
With increased densification, applicant must consider the potential increase in
construction costs resulting from required offsite utility improvements, potentially
downstream of the subject property. Densification may place greater demands on water,
sewer, and storm drain systems, which could exceed the capacity of the existing
infrastructure. Property owners and developers will be required to upgrade the offsite
public utilities to ensure sufficient capacity for the new development.
Additional comments have been provided to assist in the future development of the property. The
following comments are provided for information only and do not provide official project review
or approval. Comments are provided to assist in design and development by providing guidance
for project requirements.
• Public Utility permit, connection, survey, and inspection fees will apply.
• All utility design and construction must comply with APWA Standards and SLCPU
Standard Practices.
• All utilities must meet horizontal and vertical clearance requirements. Water and sewer
lines require 10 ft minimum horizontal separation and 18” minimum vertical separation.
Sewer must maintain 5 ft minimum horizontal separation and 12” vertical separation from
any non-water utilities. Water must maintain 3 ft minimum horizontal separation and 12”
vertical separation from any non-sewer utilities.
• Public street light requirements are determined during building permit review.
• CC&R’s must address utility service ownership and maintenance responsibility from the
public main to each individual unit.
PLNPCM2024-01079 35 February 6, 2025
• Utilities cannot cross property lines without appropriate easements and agreements
between property owners.
• Site utility and grading plans will be required for building permit review. Site utility plans
should include all existing and proposed utilities, including water, irrigation, fire, sewer,
stormwater, street lighting, power, gas, and communications. Grading plans should
include arrows directing stormwater away from neighboring property. Please refer to
APWA, SLCDPU Standard Practices, and the SLC Design Process Guide for utility design
requirements. Other plans such as erosion control plans and plumbing plans may also be
required, depending on the scope of work. Submit supporting documents and calculations
along with the plans. OR Site utility and grading plans will be required for building permit
review. Site utility plans should include all existing and proposed utilities, including water,
irrigation, fire, sewer, stormwater, street lighting, power, gas, and communications. Please
refer to APWA, SLCDPU Standard Practices, and the SLC Design Process Guide for utility
design requirements.
• Applicant must provide fire flow, culinary water, and sewer demand calculations to
SLCDPU for review. The public sewer and water system will be modeled with these
demands. If the demand is not adequately delivered or if one or more reaches of the sewer
system reach capacity as a result of the development, a water/sewer main upsizing will be
required at the property owner’s expense. Required improvements on the public water and
sewer system will be determined by the Development Review Engineer and may be
downstream of the project. Additionally, if a new fire hydrant is required, then a water
main upsize will be required. Per State law, hydrants cannot be installed on the existing
6” water main.
• One culinary water meter is permitted per parcel and fire services, as required, will be
permitted for this property. Each service must have a separate tap to the main.
• A minimum of one sewer lateral is required per building. The laterals must be 4” or 6” and
meet minimum slope requirements (2% for 4" laterals, 1% for 6" laterals). Any unused
sewer laterals must be capped and plugged at the main. AND Shared laterals require a
request for variance.
• A minimum of one exterior cleanout is required on the sewer lateral within 5 feet of the
building. Additional cleanouts are required at each bend and at least one every 50 feet for
4" laterals and every 100 feet for 6" laterals.
• Site stormwater must be collected on site and routed to the public storm drain system.
Stormwater cannot discharge across property lines or public sidewalks.
• Stormwater treatment is required prior to discharge to the public storm drain. Utilize
stormwater Best Management Practices (BMP's) to remove solids and oils. Green
Infrastructure should be used whenever possible. Green Infrastructure and LID treatment
of stormwater is a design requirement and required by the Salt Lake City UPDES permit
for Municipal Separate Storm Sewer System (MS4). If green infrastructure is not used,
then applicant must provide documentation of what green infrastructure measures were
considered and why these were not deemed feasible. Please verify that plans include
appropriate treatment measures. Please visit the following websites for guidance with Low
Impact Development: https://deq.utah.gov/water-quality/low-impact-
development?form=M
https://documents.deq.utah.gov/water-quality/stormwater/updes/DWQ-2019-
000161.pdf?form=MY01SV&OCID=MY01SV.
J. Shane and Sharon C. Franz
Third Avenue Investments, LLC.
11113 Old Rosebud Ln
South Jordan, UT 84095
Councilman Chris Wharton,
Planning Commission Members,
Alicia Seeley, Planning Division
451 S State Street Room 406
Salt Lake City, UT 84114
(801) 535-7922
Alicia.seeley@slc.gov
October 23, 2024
VIA UNITED STATES POSTAL MAIL AND ELECTRONIC MAIL
Re: John Van Trigt, Will & Alex LLC, Petition Number: PLNPCM2024-01079
proposal to rezone the subject property from SR-1A to R-MU-35.
Dear Councilman Wharton, Planning Commission Members and Ms. Seeley,
We are the family owners of the property located at 825 E 3rd Ave, located some
232 feet from the subject property located at 128 N N Street (EXHIBIT A). We are
writing to express our opposition to the proposal to rezone the subject
property from SR-1A to R-MU-35.
As lifelong residents of Salt Lake City, with deep interest in historic preservation,
we would respectfully outline our concerns below. We own and have restored
five historic homes within the Avenues Historic District and the Salt Lake City
Historic District. We have dedicated much of our life savings to the preservation
and improvement of historic structures for the next generation. We are
passionate about maintaining the delicate balance that exists within our Historic
Districts to maintain the exceptional lifestyle that makes the area attractive to
residents of our city. We are intimately familiar with the 128 N N Street location
and neighborhood, and are uniquely qualified to comment on the application.
Our concerns are as follows:
1) Property not large enough. The subject property is simply not large
enough to accommodate what the applicant is trying to do. The property
would lack green space and setback from other buildings. The applicant
claims that their goal is “To create a housing solution addressing the City's
need for small- and mid-sized developments compatible with the
surrounding neighborhood”. This plan will be disastrous for the
surrounding area property owners and tenants.
2) Lack of street parking. Adding Five units to the rear of the property
would bring additional tenants which would require additional parking.
Limited provision is made in the proposed plan to account for off street
parking, and the new or existing tenants would be forced to park on
already crowded streets. Lack of off-street parking would be especially
problematic during the winter snow season. Street parking in the
proximity to the subject property is already constrained for existing
residents.
Note that based on applicant’s plan, if every resident had one car, 19
parking spaces would be needed. The proposed plan calls for only 6
spaces. (8 bedrooms in existing four plex, plus 4 two-bedroom units, plus
1 three-bedroom unit.). Under the applicant’s plan, a minimum of 13 cars
plus their guests would be pushed onto the surrounding streets, whereas
now, all residents can park on the property. The petitioner argues that
residents will use bus lines, and they may occasionally, however there are
few local grocery stores or work locations – the Avenues Historic District
is a commuter area.
3) Height concerns. Applicant’s architectural drawings state that new units
could be up to 35 feet in height. This would have an adversarial effect on
surrounding neighbors by blocking light, as illustrated in EXHIBIT C.
Most existing structures in the historic district are only one or two stories.
This would be inharmonious with the character of the surrounding
properties.
4) Lack of proper planning. Note that there are key errors in the proposal,
(EXHIBIT B, C) including labeling the existing fourplex on as a triplex,
lack of planning for a large dumpster and recycling container placement,
and lack of storage for tenant items such as bicycles, snow removal
equipment, property maintenance equipment, etc. Other areas of concern
are utilities and access. Where would 5 additional gas and power meters
be located? Where would overhead electric lines run from?
5) Incongruous with Historic District. The proposed zone density is
inharmonious with the surrounding historic district. The applicant claims
their goal is: “To create a sensitive design solution that maintains historic
preservation of the district.” Avenues living is for people who want to live
downtown but still enjoy a small yard and the historic charm of the quaint
cottage homes, small walkable streets and vibrant old neighborhood. If
people want high density housing, there is now an abundance of it
downtown. Our avenues tenants cite that they specifically wish to live
outside of the high-density buildings which have become so abundant.
We do not need this type of housing here.
6) Dangerous precedent. Our Avenues Historic district is full of properties
where someone else could try to over densify their property, just as this
applicant. Where does it stop? If we continue, we will destroy the special
character and desirability of the historic district. What we have now is
special and can be found only here. This proposal is far more dangerous
than allowing someone to build an ADU above their garage.
7) Exploitation of our city by non-native investors. Applicant and owner’s
LLC is located in California, and not a Salt Lake native (EXHIBIT D, E).
This is someone from out-of-town trying to exploit our city for profit. The
petitioner wants to increase their wealth by creating housing in the quaint
Avenues Historic District at the expense of those that currently live in the
district. They do not care if they damage the delicate Historic District – it
is all about profit. There is no vested interested in maintaining the historic
area.
(Note that the tax notice for WILL & ALEX LLC is mailed to 10799 LAS
POSAS RD CAMORILLO CA 93012).
8) Manufactured “housing crisis”. Our city is now overbuilt with common
“four over one,” “five over one,” and other high-density apartments. We
have more of a problem as to what jobs are available and where will
people work and shop. If the applicant is indeed altruistic, there are far
better locations to build high density housing rather than the Avenues
Historic District. The proposed solution is looking to answer a problem
that does not exist in the Avenues Historic District.
9) Illusion of Affordable Housing. The petitioner states that their goal is “To
provide 1 unit (20% of additional units) of affordable housing to address
the City's required community benefit.” The applicant could do this today
with their existing property. There is no need for radical rezoning to
accomplish this goal. Make no mistake, this is a for-profit venture.
10) History of Unethical Personal and Professional Conduct. Be it further
noted that petitioner’s company, HOLTHOUSE CARLIN & VAN TRIGT
LLP, for which the petitioner is a founder and partner, and directs the
accounting and audit group (Exhibit E), has a history of unethical
behavior. The company was issued a cease-and-desist order, censured
and ordered to pay significant fines by the Securities and Exchange
Commission for engaging in unethical or improper professional conduct
for improperly simultaneously keeping and auditing their client’s books.
(EXHIBIT F). This illustrates that petitioner has a history of omitting or
misstating material facts, or inappropriate self-dealing to induce improper
outcomes. City staff and leaders should employ extra caution when
considering this application.
In summary, we want protection for our precious Avenues Historic District from
high density development. The proposed improvements will be harmful to our
property and tenants, disrupting their peaceful way of life. What we have in the
Avenues is unique and special – it is the kind of thing that people seek out when
visiting our city. It is what makes it charming and distinct. We do not want to
happen here what happened in Sugar House. It is unconscionable to us that we
would entertain the idea of permanently rezoning our unique avenues landscape
so some outside investor could make a quick buck.
Respectfully,
/Signed/
J. Shane and Sharon C. Franz
Cc: Trustees and other interested parties of the Third Avenue Investments
Limited Partnership,
Avenues Community Council,
Mr. Judson T. Pitts, Legal Counsel for Third Avenue Investments.
EXHIBIT A – LOCATION OF SUBJECT PROPERTY
TO 825 E 3RD AVE
EXHIBIT B – PETITIONER’S ARCHITECTURAL DRAWING
WITH ERRORS
Note mislabeling of existing building as a tri-plex, instead of four plex, and
other errors (lack of dumpster space, utility meters, etc. as detailed in text.)
EXHIBIT C – EXISTING GARAGES
(Photo courtesy Building Salt Lake, Samantha Hawkins). Note surrounding
properties what will be immediately and totally blocked from view/sunlight
if the proposed structure is built.
EXHIBIT D – PROPERTY TAX NOTICE FOR SUBJECT
PROPERTY
ILLUSTRATING CALIFORNIA OWNERSHIP
EXHIBIT E – JOHN VAN TRIGT BIO
NON-UTAH NATIVE – NO VESTED INTEREST IN MAINTAINING THE
DELICATE NATURE OF THE HISTORIC AVENUES DISTRICT.
EXHIBIT F – SEC ACTION (EXCERPTS) FOR PETITIONER’S
COMPANY
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From:Shane Franz
To:Seeley, Alicia; Wharton, Chris; Planning Public Comments; City Council Liaisons
Cc:
Subject:(EXTERNAL) OPPOSITION TO ZONING AMENDMENT 128 N N STREET
Date:Wednesday, October 23, 2024 1:30:44 PM
Attachments:Public Input 128 N N Street.pdf
Dear Ms. Seeley, Planning Commission, Councilman Wharton, et al.,
Please see the attached letter detailing our OPPOSITION to the proposed rezoning for 128 N
N Street from SR-1A to R-MU-35 petition number PLNPCM2024-01079.
Please feel free to contact me if you have any questions.
Respectfully,
J. Shane and Sharon C. Franz
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From:Emma Roberts
To:Seeley, Alicia
Subject:(EXTERNAL) Public Comment on 128 North N St. Zoning Map Agreement
Date:Thursday, November 7, 2024 12:42:07 AM
Hi Alicia,
I am a tenant of 128 N St, and my partner and I have lived here for almost 5 years now. I feel
that this email may be futile, but I still would like to share my requests. I am asking that you
please do not do this! Our entire apartment unit has endured a year and a half of constant
construction due to the condos that were built next to us (that are still sitting empty by the
way). The construction made our whole building constantly shake, and the noise was
unbearable. It truly made our lives very stressful from day to day. I got very little sleep from
being awoken at 7 AM (sometimes earlier) by crumbling concrete and a buzzsaw. This is
especially disheartening because all of the units seem to have gone bankrupt and are EMPTY.
I implore the city to focus on making all of these empty buildings more affordable, instead of
building more that are unaffordable.
In addition to this, we use our current garage to hold all of our portable A/C units during the
winter months. The summer is so hot inside, that we have to have 4 portable units for the
whole place. A carport would not be a suitable replacement for what we have been using for
this time. I know that my fellow tenants also use their garages for spare storage.
Thank you for your time and for allowing public comments.
Best Regards,
Emma Roberts
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From:Jessica Stiles
To:Seeley, Alicia
Subject:(EXTERNAL) Re: Proposed zoning change for 128 N N St SLC
Date:Monday, October 14, 2024 3:40:10 PM
Attachments:image001.png
Alicia,
I vote a hard no for this zoning proposal. I do live at 122 N St E, Salt Lake City, UT 84103. As
a direct neighbor of this building, this would cause a lot of issues, concerning both short term
and long term. For my own building, which most of us are owners and not renters, I wouldn’t
want these new units making the space even tighter and more difficult to live next door,
there’s already noise/parking issues late at all times of the day with the current tenants. My
most important concern is the short term construction noise, for someone who sleeps during
the day here. I bought and paid good money for my condo, for many a reason in this
neighborhood. Let me know if you need any other information. Is there a way of finding out if
the proposal will pass or not? Looking forward to hearing from you. Thank you.
Jessica Stiles
On Thu, Oct 10, 2024 at 10:48 Seeley, Alicia <Alicia.Seeley@slc.gov> wrote:
Good morning, Jessica.
Thank you for reaching out. At this time, you can send comments directly to me. All public
comments I receive will go directly into the staff report to be reviewed by the planning
commission and the city council as they evaluate this zoning change.
If you wish to also participate in person, there will be a public hearing held after the 45-day
public comment period. The public hearing is tentatively scheduled for December 11, but is
subject to be pushed to January if city staff request more time for review. Notices will be
sent out 10 days before the public hearing. All who wish to learn more about the proposed
change and address the planning commission in person are welcome. In case you miss the
notice, keep an eye on the planning commission website, as agendas are posted one week
before each meeting: https://www.slc.gov/planning/public-meetings/planning-commission-
agendas-minutes/
Let me know if you have any other questions.
ALICIA SEELEY | (She/Her/Hers)
Principal Planner
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attachments.
COMMUNITY AND NEIGHBORHOODS | SALT LAKE CITY CORPORATION
Office: 801-535-7922
Email: alicia.seeley@slc.gov
WWW.SLC.GOV
From: Jessica Stiles
Sent: Thursday, October 10, 2024 10:32 AM
To: Zoning <zoning@slc.gov>
Subject: (EXTERNAL) Proposed zoning change for 128 N N St SLC
Hi to whom this may concern,
Could I get help with how to petition against this zoning change? There’s no links on the
website and wanted to make sure we go about this correctly. Would love for your help and
support. Looking forward to hearing from you! Thank you.
A concerned citizen,
Jessica Stiles
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From:Cat McQueen
To:Seeley, Alicia
Subject:(EXTERNAL) Re: Zoning amendment
Date:Thursday, October 17, 2024 1:49:53 PM
Attachments:image002.png
image001.png
Alicia,
I am concerned that the people who currently park in the garage area will no longer have
parking once this construction is complete. I am also concerned that there is no way to do this
construction without blocking the driveway, preventing 5 residents of 122 N from using their
designated parking spaces. Additionally, the residents of 122 N use part of that driveway area
to back their cars into their parking area. If the new building blocks parts of the driveway area
then multiple of the people who use the parking behind 122 N would not be able to access
their parking. That’s 6-7 cars that would be displaced to street parking for a period of time or
indefinitely. The driveway is also an exit for walking out of 122 N, as the staircase is on the
far side of the building. If there is to be construction on the driveway, part of the driveway
would need to remain cleared for people to at least walk out of the complex. If there is no plan
to minimize the time blocking the driveway, I have concerns for the people who currently live
here. This is already a relatively high density area for the avenues with 10 units at 122 N and 4
units in 128 N. I hope that the current residents here are considered when the plans are made
for the construction and for the layout of the new building.
Thank you,
Cat
On Tue, Oct 15, 2024 at 11:27 AM Seeley, Alicia <alicia.seeley@slc.gov> wrote:
Good morning, Cat. Thanks for reaching out.
At this point, the property owner has not submitted building plans or designs, but they
would like to demolish and rebuild the garages in the rear of the property and build the five
additional units on top of the newly build garages in the same location, not visible from the
street (see the attached map screenshot). The zoning change from SR-1A to R-MU-35 would
allow these units to be built to a maximum height of 35 feet, rather than the maximum of 23
feet currently allowed. The new homes are proposed to be rental units, one of which will
have a deed restriction to be rented out at an affordable rate for 30 years.
Please let me know if you have any other comments you would like to be included in the
staff report for planning commission to review. This proposal is currently scheduled to go
before the planning commission on December 11, and notices will be sent out 10 days prior
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attachments.
Respectfully,
ALICIA SEELEY | (She/Her/Hers)
Principal Planner
COMMUNITY AND NEIGHBORHOODS | SALT LAKE CITY CORPORATION
Office: 801-535-7922
Email: alicia.seeley@slc.gov
WWW.SLC.GOV
From: Cat McQueen
Sent: Tuesday, October 15, 2024 11:04 AM
To: Seeley, Alicia <alicia.seeley@slc.gov>
Subject: (EXTERNAL) Zoning amendment
Hello,
I am a resident of 122 N St, and I was wondering if I could get more information on the 128
N St zoning amendment. I am fully supportive of adding additional housing in slc and
especially the avenues but if possible I would like to see plans. Specifically on how the
construction would be done and how they would keep from disrupting the two multi-unit
buildings that share the driveway. I would also like to see plans on how construction could
be done without significantly disrupting the lives of the people in either of these buildings.
There are 4 units on the 128 N property and 10 units at 122 N. Thank you,
Cat
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From:
To:Seeley, Alicia
Subject:(EXTERNAL) zoning amendment - 128 N N Street
Date:Wednesday, October 30, 2024 6:37:43 PM
I live on the opposite side of this block, and just wanted to lend my support to this rezoning.
More multi unit mid-sized housing is always needed in a growing city like ours. I see no
downsides to this proposed change, and don't expect it will impact the neighbors or
neighborhood in a negative way.
Thanks for your work on this.
-Robert Silge, 3rd Ave and O St.
From:William Barnett
To:Seeley, Alicia
Subject:(EXTERNAL) Zoning Amendment - 128 N N Street
Date:Saturday, November 2, 2024 1:36:54 PM
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Dear Alicia,
My husband, Dr. Bernard Simbari, and I are not in favor of this zoning amendment. Townhome construction at
3rd Ave. and N Street(opposite corner of our block) took over 2 years, was very noisy, and they still sit empty
several months after completion. Outside property there was not maintained and was an eyesore for the
neighborhood. I toured the end unit in February and was shocked at the inflated asking price of $1.5 million each.
Construction of the proposed units would be very noisy, especially for my husband who stays home all day.
These again would have no guarantee of being occupied once completed. Home construction in the Avenues attracts
developers due to the high average prices demanded for properties. This is not an appropriate time for zoning
changes in the Avenues as also seen recently on the F Street green space fight between developers and the
neighborhood.
For these reasons we oppose this proposed zoning change on our block,
Sincerely,
William Barnett and Dr. Bernard Simbari
Sent from my iPhone
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From:Raquel Speroni
To:Seeley, Alicia
Subject:(EXTERNAL) Zoning Amendment 128 N N Street
Date:Tuesday, November 5, 2024 1:02:16 PM
Dear Alicia,
I am the resident at 871 E 2nd Ave, and this proposed construction is pretty much my
backyard. I oppose this construction. We both know all the surrounding neighbors oppose this
construction. And we both know Salt Lake City will allow it anyway.
I find it comical these letters are sent out, under the guise that the city cares about what the
affected residents have to say. The highest bidder always wins in our lovely little city.
Salt Lake City already allowed the new construction on the corner of 3rd Ave and N St., and
not only does it destroy the charm and historic value of this neighborhood, they still sit there
vacant. Monstrosities sitting outside their surrounding era. They collected weeds all summer,
which were recently just freshly mowed down with what appears to be a renewed vigor to get
these sold. I wonder if the broken windows have been replaced?
These new builds aren't good for our neighborhood, or us. It would be nice if the residents
were heard, for once, but we both know that would require we pay you more than John Van
Trigt/Will & Alex LLC will pay in whatever form to Salt Lake City. Personally speaking;
again, this is almost quite literally my backyard. That white car you see in the photograph, on
the south east corner of your border? That's mine. I sip coffee out there in the mornings and
spend evenings unwinding out there. And Salt Lake City wants to turn it into a construction
zone, again. It just sucks.
So, put me down as another "no" vote that Salt Lake City will choose to ignore for $$$.
Sincerely,
Raquel Speroni
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From:Jim Jenkin
To:Seeley, Alicia
Cc:Jurphy
Subject:(EXTERNAL) Petition Number: PLNPCM2024-01079, community response
Date:Monday, November 18, 2024 3:42:12 PM
Attachments:128 N GACC response.pdf
]Appended below and as attached PDF]
18 November, 2024
Ms Alicia Seeley, Principal Planner
Salt Lake City Corporation
By Email: Alicia.Seeley@slc.gov
Re: Community Response, 128 N Street Rezoning Application, Greater Avenues
Community Council Land Use Committee.
Dear Ms. Seeley, et.al.,
The requested rezone from SR-1A to RMF-35 at this address was reviewed by the Land
Use Committee of the Greater Avenues Community Council (GACC) in two consecutive
meetings. The applicant was not asked by the GACC Board to make a community
council presentation to the GACC. A presentation of the project details (as submitted)
was presented by the Land Use Committee Chair, Jim Jenkin, at the GACC Meeting of 6
November. Comments made are listed below.
The Land Use Committee is generally in favor of the Proposed Rezoning for 128 N Street.
As presented, this is a thoughtful project in an appropriate location. Our specific focus is
on:
Development Pattern:
The existing historic building facing N Street will be preserved, maintaining the street
front aspect of the property. There is no loss of existing housing, and, therefore, no loss
of affordable housing. The proposed zoning is compatible with zoning or use of adjoining
parcels and the existing development pattern of this area of the Avenues.
The re-zone meets the intent of the Avenues Master Plan, which generally places
higher density housing between South Temple and Third Avenue.
Access of the new units to Public Transportation:
The project is served by frequent service on South Temple (Route 1), and infrequent
service (hourly) on Third Avenue (Route 223). We note the recent elimination by UTA of
Bus Route 3, which historically connected rental properties and homes along Third
Avenue with the University of Utah at a 30-minute frequency.
Light and Air, Massing:
We note that more open space in this project may be more desirable than the tandem
on-site parking shown in the proposal, which could be achieved by narrowing the
entrance driveway and reconfiguring the site plan.
We note that the construction of 35-foot structures on minimal setbacks along the North
border will produce a loss of light and air to the property directly to the North. Since this
property is zoned RM-U-35, this is not considered a significant detriment.
Summary
The Land Use Committee recommends approval of the project.
In the November 6th GACC community meeting, residents viewing the project had
questions about the affordability of the new housing and what affordable conditions
were part of the development, the preservation of the existing fourplex structure, and the
impact to the block face of the difference in height between the new and the existing
structures/garages. No other action was taken at this meeting.
Respectfully submitted,
Jim Jenkin, GACC Land Use Committee Chair
Jim Jenkin
Chair, Land Use Committee
Greater Avenues Community Council
18 November, 2024
Ms Alicia Seeley, Principal Planner
Salt Lake City Corporation
By Email: Alicia.Seeley@slc.gov
Re: Community Response, 128 N Street Rezoning Application, Petition Number:
PLNPCM2024-01079, Greater Avenues Community Council Land Use Committee.
Dear Ms. Seeley, et.al.,
The requested rezone from SR-1A to RMF-35 at this address was reviewed by the Land
Use Committee of the Greater Avenues Community Council (GACC) in two consecutive
meetings. The applicant was not asked by the GACC Board to make a community
council presentation to the GACC. A presentation of the project details (as submitted)
was presented by the Land Use Committee Chair, Jim Jenkin, at the GACC Meeting of
6 November. Comments made are listed below.
The Land Use Committee is generally in favor of the Proposed Rezoning for 128 N
Street. As presented, this is a thoughtful project in an appropriate location. Our specific
focus is on:
Development Pattern :
The existing historic building facing N Street will be preserved, maintaining the street
front aspect of the property. There is no loss of existing housing, and, therefore, no
loss of affordable housing. The proposed zoning is compatible with zoning or use of
adjoining parcels and the existing development pattern of this area of the Avenues.
The re-zone meets the intent of the Avenues Master Plan, which generally places
higher density housing between South Temple and Third Avenue.
Access of the new units to Public Transportation :
The project is served by frequent service on South Temple (Route 1), and
infrequent service (hourly) on Third Avenue (Route 223). We note the recent
elimination by UTA of Bus Route 3, which historically connected rental properties and
homes along Third Avenue with the University of Utah at a 30-minute frequency.
Light and Air, Massing:
We note that more open space in this project may be more desirable than the tandem
on-site parking shown in the proposal, which could be achieved by narrowing the
entrance driveway and reconfiguring the site plan.
We note that the construction of 35-foot structures on minimal setbacks along the North
border will produce a loss of light and air to the property directly to the North. Since this
property is zoned RM-U-35, this is not considered a significant detriment.
Summary
The Land Use Committee recommends approval of the project.
In the November 6 th GACC community meeting, residents viewing the project had
questions about the affordability of the new housing and what affordable conditions
were part of the development, the preservation of the existing fourplex structure, and
the impact to the block face of the difference in height between the new and the existing
structures/garages. No other action was taken at this meeting.
Respectfully submitted,
Jim Jenkin, GACC Land Use Committee Chair
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From:Miranda LeRuth
To:Seeley, Alicia
Subject:(EXTERNAL) Concerns Regarding Rezoning at 128 N N St - Miranda LeRuth
Date:Thursday, November 21, 2024 5:36:32 PM
Dear Principal Planner Alicia Seeley,
I am writing as the owner of Unit 1 within Notting Court Condominium,
122 N St, to express my concerns regarding the proposed rezoning and
development at 128 N N St. This project risks negatively affecting my
property, shared resources, and the broader neighborhood. The HOA
board will be sending more detailed complaints and concerns
shortly, though I am emailing separately with key points most critical to
me. I urge the city to address the following before considering rezoning
approval:
1. Easement Rights and Driveway Maintenance
The shared driveway, protected under an easement recorded with Salt
Lake County (March 13, 2006, Book 9265, pg 8769-8787, file 9660652),
will endure significant stress from increased traffic and construction
activity. My parking spot is in the back of the building and oftentimes two
cars cannot pass one another via our driveway. If construction vehicles are
in our driveway, I will not have access to my parking space.
Further requests will be sent via the HOA board.
2. Parking and Traffic
The proposed development lacks clarity on parking and will exacerbate
existing congestion. Our parking, even via the street, is limited.
Oftentimes my partner and I cannot park on our street, as it is fully
occupied. This is a significant concern, as 128 N Street has numerous
vehicles per unit (1-3 or 4 per unit).
Further requests will be sent via the HOA board.
3. Construction Disruptions and Structural Risks
Proximity to our back carport raises concerns about structural risks due to
ground slopes, drainage, and construction disruptions.
Enforce strict work hours (e.g., 8 a.m.–6 p.m. weekdays, no weekend
activity).
Require daily communication with a designated project manager.
Obtain written assurances for immediate repair of damages to shared
property.
4. Environmental and Property Value Concerns
The proposed density and height of the development could overshadow
neighboring properties, limit sunlight, and alter the neighborhood's
historical character. Additionally, the increased population density will
negatively impact my property value, which is my highest concern.
A shadow study is essential to ensure compliance with zoning
restrictions.
Tangible community benefits, such as subsidized transit passes or
infrastructure improvements, should be mandated as conditions for
approval.
5. Broader Safety Concerns
While not directly related to zoning, the behavior of individuals associated
with this property raises significant safety concerns, underscoring the need
for fostering a respectful and safe residential community.
Matthew May, a tenant of the property, has exhibited threatening
and unsafe behavior, including yelling at neighbors, making
intimidating gestures, threatening to kill people (police were called),
and directing derogatory and ableist comments toward my partner,
who is disabled. These actions create a hostile environment and
highlight the risks posed by a lack of proper tenant management.
Jack Van Trigt, the landlord, has failed to address these ongoing
issues effectively, allowing the unsafe behavior to persist. This lack of
accountability contributes to an environment where tenants feel
unsafe and unsupported.
Thank you for your attention to these matters. I look forward to your
response.
Sincerely,
Miranda LeRuth
Owner, Unit 1
Notting Court Condominium
122 N Street SLC UT 84103
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From:James Carrington
To:Seeley, Alicia
Cc:J Stiles; John Alfred
Subject:(EXTERNAL) Rezoning Map Amendment at 128 N N St
Date:Friday, November 22, 2024 9:55:20 AM
Attachments:NCC_Rezoning.pdf
Dear Principal Planner Alicia Seeley,
Please see attached letter from the Notting Court Condominium Association in regards to
zoning map amendment of 128 N St. We look forward to your response.
Best,
James Carrington
Notting Court Condominium Association
HOA Board, President
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COUNCIL BUDGET
STAFF REPORT
CITY COUNCIL of SALT LAKE CITY
tinyurl.com/SLCFY26
TO:City Council Members
FROM:Kate Werrett
DATE:May 20, 2025
RE: FY2026 BUDGET – PUBLIC SERVICES DEPARTMENT
Budget Book Pages: Key Changes: 53, Department Overview: 231-239
DEPARTMENT BUDGET AT-A-GLANCE
The Public Services Department manages public-facing services through its Streets and Compliance
Divisions and provides support for internal City functions through the Facilities Services, Engineering,
Administrative Services Divisions, and the Fleet Enterprise Fund. The Fleet Enterprise Fund is briefed
separately, while this briefing covers the General Fund Divisions. Much of the equipment and
infrastructure for projects Public Services handles is covered separately in the Capital Improvement
Program (CIP) budget, which is briefed later in the year.
The FY26 budget includes renaming one Public Service division and the transfer of several teams, both
within the Public Services Department and other City departments. With the addition of expanded
services, the Compliance Division is proposed to become the Urban Services Division.
The proposed budget for FY 2026 is $49,273,018, which is 6.8% ($3.1 million) more than the adopted
budget for Fiscal Year 2024-25 (FY25) largely due to the shifting of City functions into Public Services.
$46,144,257 $49,273,018 $3,128,761 6.8%
KEY BUDGET HIGHLIGHTS:
Project Timeline:
Briefing: May 20, 2025
Budget Hearing: May 20 & June 3, 2025
Potential Action: June 10 or 12, 2025
Department of Public Services
3
Urban Services Division: The most significant changes in the proposed Public Services budget
includes the change to the Urban Services Division (formerly the Compliance Division) in response to
some of the most common themes in discussions in the past year involving Public Services – bio-waste
cleanup and urban cleanliness – with a focus on Westside.
Expansion of the Compliance Division into the Urban Services Division to provide more broad
‘compliance and dispatch’ services. This includes:
o Transfer of three Homeless Engagement and Response Team (HEART) members from
the Community and Neighborhoods Department
o Transfer the Graffiti Response Team from Public Lands
o Transfer 23 FTEs from the Facilities Services Division, including the Rapid Intervention
Team (RIT)
The Facilities Services Division will have 35 FTEs more concentrated on general
maintenance for the 98 City-owned buildings
Moving the RIT Team to Urban Services will provide a holistic response to
cleaning City property and reduce response times as they work with sub-teams in
the Clean City Team.
o System improvements for the City’s response and deployment of the Rapid Intervention
Team (RIT) for services requests.
o Five proposed new full time employees (FTEs) in Urban Services:
$218,000 for three new FTEs for the new Clean City Team. They will be tasked
with improving cleanliness by handling waste removal, illegal dumping, camping
mitigation, and surface cleaning on City property. Their focus will be on
improving cleanliness response times, graffiti removal within 24 hours, and daily
trash can emptying.
$131,000 for two new FTEs for the proposed Right of Way Services North Temple
Team. This dedicated team will service North Temple with limited clean-up
services similar to the Central and Sugar House business districts.
Engineering Division: Within the Public Services budget, the Engineering Division will decrease by
65.4% ($2,520,816) due to:
Proposed move of 37 FTEs in the Engineering Division from Public Services to Community and
Neighborhoods (CAN). This division transfer is expected to increase multi-division collaboration
on roadway projects from conceptual design to project completion
The remaining 13 FTEs of the Engineering Division will include the Architect and the architecture
team. Public Services requests to change the name to the Architecture, Facilities and Construction
Management Team (AFCM) and move the AFCM team within Public Services’ Administrative
Services Division.
Other Budget changes:
All other division budget increases include increases to Personal Services costs for employees,
which include salaries, merit changes, and insurance rate changes.
Staffing Public Services employees covered by the General Fund (including Funding Our
Future), with the proposed transfers, would be a total of 254 FTEs.
Department of Public Services
4
Base to Base Changes $1,718,465
4% Salary Proposal $841,036
Insurance Increase $31,190
Pension Changes $42,346
$796,015 for Smith’s Ballpark Property Management
$750,000 for an increased level of service related to Homeless Advantage Services
$300,000 Street striping redesign and maintenance
$11,850 Fire Station Yard Maintenance, a transferred expense from the Fire Department
Vacancies
The Department reports multiple vacancies throughout their divisions. There will be six vacant funded
positions if all division transfers are approved. The vacancies broken down by division include:
- Compliance/Urban Services: There are 2 existing funded open positions. One compliance
enforcement officer position has been open for more than two months. As part of the proposed
changes to the division, Urban Services plans to reclassify the position as an operations manager
to oversee parking enforcement functions.
- Engineering (Proposed AFCM Team): While overall for Engineering, there are 4 funded open
positions, only 1 of these positions is planned to stay in the AFCM Team. Two Engineer positions
have been open for more than 2 months. Public Services has advised that hiring licensed
engineers has been a challenge due to competition from the private sector.
- Streets: There are 2 funded open positions in Streets, including a Traffic Maintenance Operator
and an Asphalt Maintenance Lead. The vacant positions are posted on Workday.
- Facility Services: There is 1 funded open position for a Facilities Specialist 1. While no positions
currently have been vacant for more than two months, the division had two positions remain
$- $2,000,000.00 $4,000,000.00 $6,000,000.00 $8,000,000.00 $10,000,000.00 $12,000,000.00 $14,000,000.00 $16,000,000.00 $18,000,000.00 $20,000,000.00
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FY25 FY26
General Fund Public Services Division Funding
Department of Public Services
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vacant for more than two months this fiscal year. The vacancies were due to current labor market
conditions.
POLICY QUESTIONS
1. The Council may wish to discuss the changes to the Clean City Team proposed in this budget.
a. The Council may wish to ask the Administration to outline the benefits of consolidating the
rapid response team members into Public Services, and to discuss the benefits of
consolidating instead of keeping these responsibilities shared through multiple
departments.
b. The Council may wish to discuss the proposed creation Right of Way Services Team for
North Temple, its proposed two new FTEs, and how the Administration will track and
report their impact on the neighborhood. The Council may wish to suggest key metrics of
importance.
2. The Council may wish to discuss the proposed Engineering Division transfer from Public Services to
Community and Neighborhoods.
a. The Council may wish to discuss where they want to see the Engineer Division placed in
order to provide the best results for the City.
3. The Council may wish to continue the policy discussion of who should pay for electric vehicle
charging electricity (City currently subsidizes) and whether to explore privatizing the chargers.
4. City-owned asset maintenance, like roads, can often be behind schedule despite significant
investments of staff and fiscal resources in recent years.
a. The Council may wish to ask for more information on funding timelines and strategies, and
whether the most urgent concerns are sufficiently funded.
b. The Council may wish to hold a policy discussion on overall goals for City-owned asset
conditions.
c. The Council may wish to discuss with the Department what the Department’s goals are for
street maintenance.
i. Is proposed funding for streets maintenance sufficient to meet the Council’s
goals?
ii. Is the funding distribution between local and major roads meeting the Council’s
policy goals?
5. The Council may wish to ask about the status of the Space Needs Assessment and how plans for City
facilities, expansion, and remodeling will be considered over the coming year.
BACKGROUND AND ADDITIONAL INFORMATION
Public Utilities and Contractual Charges. A large portion of Public Services’ budget is related to
paying expenses whose ultimate amount is largely determined by other departments. The primary
example is utility bills for departments that are housed in the City County Building and Plaza 349. Other
examples are: Facilities pays for public EV charging, and Streets pays street signal electricity costs. Several
other departments—Fire, Police, and Public Lands—along with most enterprise funds, do pay their own
utilities. Budgeting in the face of this variety is further complicated by year-to-year fluctuations that
depend on weather conditions, the City’s new asset purchases, contractual changes, and more.
Department of Public Services
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Several years ago, at the Department’s request, the Council adopted an approach that funds Utilities and
Contractual Increases for Public Services on an annual basis. By explicitly placing anticipated amounts for
these items in the annual budget, the Department avoids the mid-year budget amendment to shift funding
from approved areas into what are essentially predictable but unfunded expenses.
FY25
Adopted
FY26
Recommended
Other Changes by Division:
Administrative Services Division ($6,649,862, 19 FTEs). The Administrative Services
Division provides the management, financial operations, project management, technology, and
communication coordination and support required for all Public Services operations. This Division
also includes the Citywide internal security program.
Staffing. As part of the transfer of Engineering to CAN, one Financial Analyst I-IV is proposed to
move to CAN and the AFCM Team’s 13 FTEs will join Administrative Services. The Administration is
revising the Mayor’s Recommended Budget and Staffing Document to correctly reflect the addition
of the AFCM Team budget ($2,520,816) and 13 FTEs within the Public Services Administration
Division.
Streets Division ($18,774,624, 117 FTEs). The largest General Fund-funded Division in Public
Services would remain so, with 13.5% budget growth. (Note: Streets is separate from the
Transportation Division located in the Community and Neighborhoods Department). The Streets
Division provides snow plowing, street sweeping for storm water management, and traffic signals
maintenance—all of which require after-hours response capacity. In addition, the Division provides
all roadway painting (including crosswalks), maintenance activities such as pothole patching and chip
seal projects, and significant asphalt road maintenance.
Staffing: No new FTEs are being proposed within this Division for FY26. The Streets Response
Team within the division has a lot of turnover due to their schedule, which includes frequent swing,
graveyard, and weekend shifts.
conversations later this year and will also likely be evaluated over the coming year and included in
FY27 budget proposals.
Mill and Asphalt Overlay Program. The program adds a middle layer to the current approach of
road maintenance by focusing on overlaying roads that are not sufficiently deteriorated to need
reconstruction, but are in poor enough condition to merit more than standard upkeep. Otherwise,
Department of Public Services
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reconstructing the worst roads first is Engineering role’s and typically funded through CIP with
contracts and some City-performed work; and maintaining roads in good condition is Streets’ role
and typically funded in the General Fund, including Funding Our Future sales tax dollars), The City
uses the Overall Condition Index (OCI)1 to determine which roads fall under which conditions and
prioritize maintenance.
In FY24, this was a pilot program funded at $130,000 to reach 5 lane miles of treatment. The pilot
program was considered successful and is now part of the Streets Division’s maintenance operations.
In FY25, the budget included a proposal of $296,000 to treat 10 lane miles. For FY26, Streets is
targeting to mill and overlay 10 miles of local roads. The Administration estimates that as of Spring
2025, there are 108 local street lane miles that could use a mill and overlay. However, current
staffing and equipment are budgeted to cover a maximum of 10 miles in one fiscal year.
The Engineering Division submitted a CIP request for a 2025 pavement condition survey to gauge
the impact of the last four years of roadway capital investments and to assist in future strategies.
Public Services provided the following chart to report the estimated current condition of City
roadways:
Based on the 2021 pavement condition survey, $45 million per year for 5 years was recommended to
achieve the industry standard of the ratio of roadways needing maintenance. Streets anticipates that
the requested late summer 2025 pavement condition survey will likely reflect road reconstruction or
overlay needs totaling $50 million-$55 million per year for 5 years or longer to reach the industry
standard roadway maintenance ratio. The table below displays the City’s spending on street
reconstruction requests and awards from FY2017 to FY2025.
Fiscal Year Street Reconstruction /
Overlay Request
Street Reconstruction
/ Overlay Award
2024-2025 $8,000,000 $8,000,000
2023-2024 $ 6,000,000 $ 6,000,000
2022-2023 $ 12,920,000 $ 6,700,000
2021-2022 $ 3,500,000 $ 2,046,329
1 SLC Pavement Condition Map
Department of Public Services
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2020-2021 $ 3,500,000 $ 2,046,329
2019-2020 $ 7,076,400 $ 5,576,400
2018-2019 $ 6,346,790 $ 1,200,000
2017-2018 $ 6,620,900 $ 3,620,900
2016-2017 $ 6,691,000 $ 3,667,846
Averages/YR $ 8,415,013 $ 4,710,103
C.Facilities Services Division ($10,143,218, 35 FTEs). The Facilities Division manages City-
owned buildings and public spaces. This includes everything from maintenance to tracking the
condition and needs of all City assets.
Asset Management. Part of the division’s responsibilities is overseeing and maintaining city-owned
properties. The Division maintains a list of factors, including contractual obligations, threats to
property and infrastructure, and funding availability/timeliness to determine which assets to
prioritize for updates or repairs. Ongoing maintenance typically falls within the Public Services
budget, while addressing and prioritizing onetime capital replacements or improvements is usually
part of the annual CIP discussion.
Staffing. No new FTEs are proposed within this division for FY26. The Facilities reports very
positive impacts from apprenticeship positions, with one apprentice taking a FTE position after
gaining the necessary qualifications in FY25. 23 FTEs are proposed to move to the Urban Services
Division.
D.Proposed Urban Services ($11,184,498, 70 FTEs). The proposed Clean City Team is housed
within the Urban Services Division. Below is the proposed Clean City Team organizational chart:
Budget FY26
Presented by , Director
CBD Maintenance
DEPARTMENT OF
PUBLIC SERVICES
Jorge Chamorro
Director
ADMIN SERVICES
Communications
Finance
Technology
Strategic Planning
Safety & Security
CAPITAL
JP Goates
Deputy Director
CITY ARCHITECT
Sean Fyfe
FACILITIES
Riley Bird
OPERATIONS
Julie Crookston
Deputy Director
COMPLIANCE*
Jordan Smith
*Proposed change:
Urban Services
FLEET
Nancy Bean
STREETS
James AguilarDE
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Insights Description
1 Clean City Program
2 Engineering to CAN
3 Smith's Ballpark Transition
4 Underfunded Services
5 PTE COLA Increases
6 5th of the 5th Street Maintenance
7 Utility Inflation
Current Proposed Total
$46,144,258 +$3,128,760 $49,273,018
FTE: 276 / PTE: 153 FTE: +5 (new)
+10-37 (transfers)/PTE: -5 FTE: 254 / PTE: 148
PUBLIC SERVICES
^ Table numbers do not include Fleet
Monument Plaza
OVERVIEW OF CHANGES
CLEAN CITY PROGRAM
Public Services will create a Clean City Program
under the restructured Urban Services Division.
Key changes include:
•Expand the RIT and transfer to Urban Services
•Facilities’ CBD and SBD maintenance groups
transfer to Urban Services and are renamed
•Addition of small North Temple team
•Transfer Public Lands’ Graffiti Removal Team
•Transfer HEART coordination team
PUBLIC SERVICES
SBD Maintenance
URBAN SERVICES DIVISION*
Jordan Smith
*Currently: Compliance Division
CLEAN CITY
Operations Manager
GRAFFITI RESPONSE
CLEAN CITY PROGRAM
RIT
(Camping Mitigation)
COORDINATORS
STAFFING OVERVIEW:
Existing: 33 FTE, 10 PTE
New: 5 FTE
Total: 38 FTE, 10 PTE
ADVANTAGE SERVICES
CONTRACT
ROW SERVICES
(Downtown, North
Temple, & Sugar
House - S-Line)
FY26 COSTS
Item Cost Type
(1) Three new FTE for RIT $218,000 Ongoing
(2) Start up costs $25,000 One-Time
(3) ROW Services – North Temple two new FTE $131,000 Ongoing
(4) ROW Services – North Temple operating budget $124,000 Ongoing
(5) Increased Advantage Services Contract $750,000 Ongoing
TOTAL $1,248,000 -
PUBLIC SERVICES
CLEAN CITY
+5
ENGINEERING TO CAN
City Engineer and their reports move to CAN. The
Architectural group remains in Public Services.
•Engineering (37 FTE) to CAN
•Architecture Group (13 FTE) becomes
Architecture & Construction Management
Services, including City Architect
PUBLIC SERVICES
Engineering Surveyors
BUDGET NEUTRAL
Property management and contracts. Replacing
previous operations performed by Bees for stadium..
This includes and maintains use of:
•Building, and admin space
•Grounds and parking
•Field use
•Security and monitoring
•Utilities and major systems
•Fire systems monitoring
•Event-related issues
PUBLIC SERVICES
Smith’s Ballpark
SMITH'S BALLPARK TRANSITION
FY26 COSTS
Item Cost Type
(1) Facility Management Contracted Services
(Security, General Maintenance/Repairs, Ballfield
and Landscape Maintenance)
$789,815 One-Time
(2) Equipment Expense $6,200 One-Time
TOTAL $796,015 One-Time
PUBLIC SERVICES
SMITH'S BALLPARK TRANSITION
UNDERFUNDED SERVICES
Maintenance/landscaping for the following facilities:
•300 N Pedestrian Bridge
•Wasatch Hills Tennis Center
•Police Substations
•Monument Plaza Splashpad pool contract
PUBLIC SERVICES
FY26 COSTS
Item Cost Type
(1) Underfunded services $168,485 Ongoing
300 N Pedestrian Bridge
PTE COLA INCREASES
PUBLIC SERVICES
FY26 COSTS
Item Cost Type
(1) Part Time COLA $57,060 Ongoing
To remain competitive in the job market, this funding
will be used to increase the hourly rates of:
•Existing part-time employees
•Seasonal employees
5th of the 5th STREET MAINTENANCE
County sales tax funding allocated to the Streets
Division to contract out:
•Transportation Division striping redesigns on
certain roadways
•Increasing the ongoing maintenance funding for
roadway markings
PUBLIC SERVICES
FY26 COSTS
Item Cost Type
(1) Striping contractual services $300,000 Ongoing
Striping Operations
PUBLIC SERVICES
UTILITY INFLATION
FY26 COSTS
Item Cost Type
(1) Utility inflation $632,664 Ongoing
The Facilities Division is responsible for the utility bills
for most of the City-occupied buildings. Cost
increases include the following utilities:
•Water, sewer, trash collection, gas, electricity,
etc.
Insight Description FTEs FY26 Request
1 Clean City Program 5 $1,248,000
2 Engineering to CAN -Budget Neutral
3 Smith's Ballpark Transition -$796,015
4 Underfunded Services -$168,485
5 PTE COLA Increases -$57,060
6 5th of the 5th Street Maintenance -$300,000
7 Utility Inflation -$632,664
TOTAL 5 $3,202,224
PUBLIC SERVICES
SUMMARY OF REQUESTS
+5
THANK YOU!
Jorge Chamorro, Department Director
URBAN SERVICES DIVISION*
Jordan Smith
*Currently: Compliance Division
CLEAN CITY
Operations Manager
Graffiti
Response
Supervisor
Field
Technician
6 FTE
ROW
Services CBD
Supervisor
Maintenance
Worker 8 FTE
Maintenance
Worker 5
PTE/S
ROW
Services SBD
Supervisor
Maintenance
Worker 6 FTE
Maintenance
Worker 5
PTE/S
CLEAN CITY PROGRAM
RIT
Supervisor
Clean-Up
Equipment
Operator
8 FTE
Special
Projects
Supervisor
Special
Projects
Assistant
2 FTE
ROW
Services –
North
Temple
2 FTE
STAFFING OVERVIEW:
Existing: 33 FTE, 10 PTE
New: 5 FTE
Total: 38 FTE, 10 PTE
URBAN SERVICES*
Jordan Smith
*Currently: Compliance
CLEAN CITY
Operations Manager
Graffiti Response
Supervisor
Field Technician
6 FTE
Maintenance
Worker
7 FTE & 5 PTE/S
ROW Services B
Supervisor
ROW Services A
Supervisor
Maintenance
Worker
7 FTE & 5 PTE/S
RIT
Supervisor
Clean-Up
Equipment
Operator 8 FTE
PARKING SERVICES
Operations Manager
CROSSING GUARD & ADMIN SUPPORT
Supervisor
Day Shift
Supervisor
Swing Shift
Supervisor
Long-Term
Parking
Mitigation
Supervisor
Parking Pay
Stations
Technician
Enforcement
Officer
10 FTE
Dispatcher
1 FTE
Enforcement
Officer
7 FTE
Dispatcher
1 FTE & 1 PTE
Long-Term
Parking
Mitigation
Officer
2 FTE
Support Worker
1 PTE
ADMIN SUPPORT
Office
Technician
2 FTE & 2 PTE
CROSSING GUARDS
Office
Technician
1 FTE
CROSSING GUARDS
Lead Crossing
Guard
4 PTE
CROSSING
GUARDS
Crossing Guard
70-75 PTE
ADMIN SUPPORT
Business Systems
Analyst
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Special Projects
Supervisor
Special Projects
Assistant 2 FTE
ROW Services –
North Temple
2 FTE
FY26 COSTS
Item Cost Type
(1) F250 Truck $55,000 One-Time
(2) F150 Truck Electric $54,000 One-Time
(3) Trailer $15,000 One-Time
(4) Auto Scrubber $118,000 One-Time
(5) Two Litter Vacuums $185,000 One-Time
(6) Kubota $45,000 One-Time
TOTAL $472,000 One-Time
PUBLIC SERVICES
CLEAN CITY - EQUIPMENT COSTS
SALT LAKE CITY BOARD MEMBER APPOINTMENT
To:
Salt Lake City Council Chair Submission Date:
04/28/2025
Date Sent To Council:
04/28/2025
From:
Otto, Rachel
Subject: Board Appointment Recommendation: Planning Commission
Recommendation:
The Administration recommends the Council approve the appointment of Lilah Rosenfield to the Planning Commission for a 4 year term
starting on the date of City Council advice and consent .
Approved:*
Otto, Rachel
SALT LAKE CITY BOARD MEMBER APPOINTMENT
To:
Salt Lake City Council Chair Submission Date:
04/28/2025
Date Sent To Council:
04/28/2025
From:
Otto, Rachel
Subject: Board Appointment Recommendation: Planning Commission
Recommendation:
The Administration recommends the Council approve the appointment of Michael Wayne Vela to the Planning Commission for a 4 year term
starting on the date of City Council advice and consent .
Approved:*
Otto, Rachel
SALT LAKE CITY BOARD MEMBER APPOINTMENT
To:
Salt Lake City Council Chair Submission Date:
04/28/2025
Date Sent To Council:
04/28/2025
From:
Otto, Rachel
Subject: Board Appointment Recommendation: Planning Commission
Recommendation:
The Administration recommends the Council approve the appointment of Jeffrey H Barrett to the Planning Commission for a 4 year term
starting on the date of City Council advice and consent .
Approved:*
Otto, Rachel
SALT LAKE CITY BOARD MEMBER APPOINTMENT
To:
Salt Lake City Council Chair Submission Date:
04/30/2025
Date Sent To Council:
05/05/2025
From:
Otto, Rachel
Subject: Board Appointment Recommendation: Bicycle Advisory Committee
Recommendation:
The Administration recommends the Council approve the appointment of Esther Daranciang to the Bicycle Advisory Committee for a 3 year
term starting on the date of City Council advice and consent.
Approved:*
Otto, Rachel
Page | 1
COUNCIL STAFF REPORT
CITY COUNCIL of SALT LAKE CITY
tinyurl.com/SLCFY26
TO:City Council Members
FROM: Austin Kimmel, Public Policy Analyst
DATE:April 15, 2025
RE: FISCAL YEAR 2025-2026 BUDGET,
DEPARTMENT OF PUBLIC UTILITIES,
Water, Sewer, Stormwater, and Street Lighting Funds
FOLLOW-UP BRIEFING
The Department of Public Utilities will provide a follow-up briefing to the Council regarding the new rates for
water, sewer, stormwater, and streetlights. The presentation will highlight changes in the rate structure and
demonstrate tools available to help residents understand the impact on their utility bills. It will also provide an
opportunity for the Council to ask questions.
Public Utilities staff has prepared engagement materials to inform customers and constituents about the
proposed rates, including a rate increase website and other resources.
ISSUE AT-A-GLANCE
The total proposed FY26 budget for the Department of Public Utilities is $410,518,007, representing a
$149,643,376 or 26.71% decrease from the amended FY25 budget. The decrease is primarily driven by a
52.54% reduction ($162,654,324) in the department’s total capital projects and a 21.08% ($72,846,199)
reduction in the department’s bond/loan proceeds compared to FY25. An increase of 22% ($50,059,367) is
expected in total utility rate revenue compared to FY25.
The Department consists of four utilities: Water, Sewer, Stormwater, and Street Lighting. Each utility operates
as separate enterprise funds, generating revenue through user fees to fund separately allocated staffing,
materials budgets, and capital improvement programs. Each fund is responsible for extensive capital asset
networks, with the three water-related utilities largely regulated by state and federal requirements. The
department funds and implements infrastructure maintenance and upgrades to comply with current federal
regulations and mandates for reliable customer service.
Public Utilities is one of the oldest and largest water utility systems west of the Mississippi River. Its total
service area covers 141 square miles, covering Salt Lake City and the eastern side of Salt Lake Valley to the
mouth of Little Cottonwood Canyon. This includes water service to portions of Millcreek, Cottonwood Heights,
Holladay, Murray, Midvale, and South Salt Lake.
The Department of Public Utilities identified the following budget insights for FY26:
Project Timeline:
Set Date & 1st Briefing: April 15, 2025
2nd Briefing: May 20, 2025
Public Hearings: May 20 and June 3, 2025
Potential Action: June 10, or later date TBD
Page | 3
1.) Assessment and replacement of aging infrastructure,
2.) Federal and state regulatory obligations,
3.) Inflationary pressures,
4.) Implementation of the 2024 Water, Sewer, and Stormwater Rate Study, and
5.) Alignment of the Department of Public Utilities with the Mayor’s priorities for resiliency and
operational efficiency.
These budget insights are explained on page 4 of Public Utilities FY26 proposed budget (Attachment 1).
In FY25, a temporary rate stabilization fee was implemented on water and sewer utility accounts. The
stabilization fee has been eliminated in the FY26 budget and the proposed budget includes new rate
structures for the water, sewer, and stormwater utilities based on a 2024 rate study, which ensures utility
pricing structures remain appropriate and provide necessary and reliable revenues.
POLICY QUESTIONS
1.Customer Communication and Rate Impact Outreach: The Council may wish to ask the
Department to expand on its communication and outreach plan to inform customers across all classes
about the proposed rate changes. Additionally, the Council could ask how Public Utilities has
coordinated with other City departments, like Public Lands, about how the proposed rates may affect
their proposed operational budgets.
2.Water Usage Trends and Revenue Projections: Given that actual water sales were below
projections in previous years due to decreased usage, the Council may wish to ask the Department to
explain how the new rate design will generate the necessary revenue without requiring mid-year
adjustments or the reintroduction of a stabilization fee.
3.Streetlighting Rate Study Timeline and Implementation: The Council may wish to ask Public
Utilities about the current status of the streetlighting rate study, including the anticipated timeline for
completion. The Council could also ask if the Department anticipates the study being presented to the
Council and implemented in the FY27 budget. Lastly, the Council may ask if the study will address the
ongoing challenges of copper wire theft and the associated costs challenging that utility's budget.
4.Infrastructure Replacement Prioritization: With aging infrastructure identified as a key budget
insight, the Council may wish to ask the Department to expand on how it prioritizes replacement
projects and forecasts future years across all four utilities. How are factors such as asset condition,
service reliability risk, regulatory compliance, and coordination with other city capital projects weighted
in these decisions?
5.Water Reclamation Facility Status: As the Water Reclamation Facility approaches its anticipated
completion in July 2026, the Council may request if the Department anticipates additional cost
increases due to the current state of the markets and federal tariffs.
6.Climate Resilience Planning: The Council could ask the Department how climate change
considerations, particularly related to drought conditions and storm intensification, are incorporated
into infrastructure planning across all four utilities.
IMPLEMENTATION OF THE 2024 RATE STUDY
In 2024, the Department of Public Utilities conducted a comprehensive utility rate study with FCS Group, a
consulting firm specializing in municipal rate and fee setting. The study continues Public Utilities' practice of
conducting rate evaluations every five to six years, which is a necessary review in order to ensure the structure
meets the Department’s revenue needs, and adjusts based on projected capital and operating increases. Last
year, the Department applied a stabilization fee to water and sewer accounts, because the cost of providing
Page | 3
water and sewer service had outpaced the rate revenue. This year, the study and proposed new rate structure
means the stabilization fee is eliminated and the new rate structure will account for the needed revenues. The
impact across the board to customers who paid the stabilization fee will vary – when compared to utility bills
this past year, some customers will see a decrease, and others will either remain flat or see an increase. Water
and sewer utility bills will be affected by the amount of water used in any given billing cycle.
Utility FY25 Utility
Monthly Cost
Proposed FY26
Utility Monthly
Cost
Estimated
Monthly Change
in Cost
Estimated
Annual Change
in Cost
$41.13 $47.15 $6.02 $72.25
$35.46 $37.94 $2.48 $29.76
$8.33 $8.75 $0.42 $5.04
$6.86 $7.89 $1.03 $12.30
Total $91.78 $101.73 $9.95 $119.35
OPERATING BUDGET SUMMARY
$177,326,052, representing a 17.07% increase from the
FY25 budget. The increase is driven by several key factors: additional compensation and benefits to support 15
new employees; payments to other departments for IMS charges, administrative service fees, payment in lieu of
taxes, and risk management; a $927,121 increase in payments to the Metropolitan Water District of Salt Lake
and Sandy for water purchased, then conveyed through the Salt Lake City water system.
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Figure 1 - Copied from page 7 of Public Utilities FY26 Proposed Budget Book
Public Utilities proposes adding 15 full-time equivalent (FTE) employees in the proposed budget to support
operational and regulatory requirements for the water, sewer, and stormwater utility systems. Public Utilities
currently has a total of 484 FTEs, including seasonal and part-time employees. The 15 proposed new employees,
described more below, would bring the total number of FTEs to 499.
BUDGET HIGHLIGHTS BY UTILITY
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A. Water Utility
The FY26 proposed water budget is $216,611,815, an increase of $4,882,815 or 2.31% from FY25. The
increased budget is driven a new rate and design structure, as recommended by the 2024 rate study. The
revenue budget proposes using debt and a grant to finance major infrastructure projects such as the City
Creek Water Treatment Plant, lead service line replacements, and other regulatory-driven capital
projects. A bond issuance of $24,000,000 is anticipated during FY26.
WATER UTILITY
Revenue
AMENDED FY25 PROPOSED FY26 PERCENT CHANGE
Water Rates Revenue $119,655,560 $143,182,162 19.66%
Interest $4 63,989 $468,629 1.00%
Interfund Charges 2,325,645 $2,325,645 4.02%
Other Revenues $2,000,000 $2,000,000 unchanged
Impact Fees $70,401,000 $32,220,653 unchanged
Contributions $38,770,000 $15,075,000 -61.12%
Bond Proceeds $100,558,000 $24,134,000 -75.99
From (To) Reserves ($56,682,698)$24,601,383 -143.40%
Total Revenue $211,729,000 $216,611,815 2.31%
Expenditures
Personal Services $35,599,948 $42,125,279 18.33%
Materials & Supplies $7,182,025 $7,662,206 6.69%
Charges for Services $57,938,676 $61,954,227 6.93%
Debt Service $17,114,227 $17,596,432 2.82%
Capital Outlay $7,731,124 $6,923,671 -10.44%
Capital Improvements $86,163,000 $80,350,000 -6.75%
Total Expenditures $211,729,000 $216,611,815 2.31%
In previous years, actual water sales were below projections due largely to decreased water usage. This,
in combination with the implementation of large aging infrastructure capital projects resulted in a
temporary rate stabilization fee in FY25, which has been eliminated in FY26. Based on the new rate
design and cost of service, water sales in FY26 are expected to be 19.66% higher than in FY25.
Public Utilities plans to transfer $24,601,383 from its reserve funds to pay for capital improvements.
The expenditure budget for the water utility is proposed to increase by $4,882,815, or 2.31%, from
FY25. The expenses for the Water Fund in FY26 are driven by increased personnel costs, including the
addition of 7.90 FTEs; increased supply and chemical costs; a 2.82% increase in debt service to comply
with current bond issues and anticipation of the Series 2026 debt; and various capital outlay
expenditures (watershed purchases, land purchases, vehicles, equipment, etc.); and capital
improvement expenditures.
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Figure 2 - Copied from page 12 of Public Utilities FY26 Proposed Budget Book
B. Sewer Utility
The FY26 proposed Sewer budget is $159,022,034, a significant decrease from FY25 by $153,426,791,
or a 49.10% decrease most notably due to the capital budget. $48,865,324 of the Sewer Fund’s
$73,230,324 capital improvement budget, is designated for the new Water Reclamation Facility (WRF),
and approximately $2 million will be used on the existing WRF. The WRF is the City’s largest public
works project, and it is anticipated to be complete in July 2026. The total cost for the project is now
nearly $940 million.
Sewer service fees (those paid by customers) are expected to increase by $22,714,368, or 25.84%, for a
total budget of $110,630,000.
SEWER UTILITY
Revenue
AMENDED FY25 PROPOSED FY26 PERCENT CHANGE
Sewer Rates Revenue $87,915,632 $110,630,000 25.84%
Interest $784,650 $900,556 14.77%
Permits $267,500 $267,500 unchanged
Other Revenues $1,132,002 $1,132,002 unchanged
Bond / Loan Proceeds $240,009,000 $242,580,801 1.07%
Impact Fees $1,650,000 $1,650,000 unchanged
From (To) Reserves ($19,309,959)($198,138,825)926.10%
Total Revenue 312,448,825 159,022,034 -49.10%
Expenditures
Personal Services $16,576,744 $20,005,102 20.68%
Materials & Supplies $4,155,306 $5,051,957 21.58%
Charges for Services $13,405,363 $21,394,753 59.60%
Debt Service $33,150,579 $36,809,653 11.04%
Capital Outlay $2,462,500 $2,530,245 2.75%
Capital Improvements $242,698,333 $73,230,324 -69.83%
Total Expenditures $312,448,825 $159,022,034 -49.10%
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The sewer expenditure budget in FY26 is driven by increased personnel costs, including the addition of
3.60 FTEs; increased materials and supplies; a $3.6 million increase in debt service to comply with
existing debt and interest payments for the Series 2026 debt; various vehicle and equipment purchases
and billing software costs; and capital improvement expenditures. Some of the increases are due to the
operation of the existing WRF concurrently with the new WRF when it is complete.
Figure 3 - Copied from page 13 of Public Utilities FY26 Proposed Budget Book
C. Stormwater Utility
The FY26 proposed Stormwater budget is $26,465,800, a decrease from FY25 by $2,740,995, or a
9.38% decrease. Due to the new rate structure, revenue is expected to increase by about 20.53% from
FY25.
STORMWATER UTILITY
Revenue
AMENDED FY25 PROPOSED FY26 PERCENT CHANGE
Stormwater Rates Revenue $14,909,297 $17,970,000 20.53%
Interest $266,901 $3 01,904 13.11%
Other Revenues $63,000 $72,065 14.39%
Impact Fees $750,000 $825,000 10.00%
Contributions $2,000,000 $125,000 -93.75%
Bond Proceeds $5,028,000 $6,034,000 -20.01%
From (To) Reserves $6,189,597 $1,137,831 -81.62%
Total Revenue 29,206,795 26,465,800 -9.38%
Expenditures
Personal Services $5,707,591 $7,186,214 25.91%
Materials & Supplies $664,497 $710,250 6.89%
Charges for Services $6,125,631 $6,873,850 12.21%
Debt Service $1,673,376 $1,726,499 3.17%
Capital Outlay $2,429,500 $2,334,987 -3.89%
Capital Improvements $12,606,200 $7,634,000 -39.44%
Total Expenditures 29,206,795 26,465,800 -9.38%
In 1993, the City completed a Drainage Master Plan, and the FY26 budget includes an update which will
incorporate considerations for water quality and account for the anticipated impacts of climate change,
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such as storm intensification, in addition to traditional conveyance methods. The FY26 Stormwater
budget also proposes the addition of 3.50 full-time equivalent positions (FTEs)
An issuance of $6 million of revenue bonds is anticipated in FY26.
$7.6 million is proposed for Stormwater’s Capital Improvement Program to renovate portions of the
stormwater collection system. This is a decrease of about $4.9 million from FY25’s Stormwater Capital
Improvement Program. The projects listed below are anticipated to be covered by these dollars:
Figure 4 - Copied from page 19 of Public Utilities FY26 Proposed Budget Book
D. Streetlighting Utility
The FY26 proposed Streetlighting budget is $8,418,358, an increase from FY25 by $1,641,595, or a
24.22% increase. Streetlighting fees are proposed to increase by 15% to keep up with increased costs
and to continue implementing the street lighting master plan. The Administration is embarking on a
streetlighting rate study, which will inform revenue requirements and streetlighting fees in future
budgets.
STREETLIGHTING UTILITY
Revenue
AMENDED FY25 PROPOSED FY26 PERCENT CHANGE
Streetlighting Rates Revenue $5,051,294 $5,808,988 15.00%
Interest $42,594 $45,652 7.18%
Other Revenues $100 $240 140.00%
General Fund Contributions $20,000 $20,000 unchanged
From (To) Reserves $1,662,775 $2,543,478 52.97%
Total Revenue $6,776,763 $8,418,358 24.22%
Expenditures
Personal Services $446,120 $421,410 -5.54%
Materials & Supplies $6,994 $9,994 42.89%
Charges for Services $3,640,121 $3,930,810 7.99%
Debt Service $193,528 $193,528 unchanged
Capital Outlay $1,250,000 $2,422,616 93.81%
Capital Improvements $1,240,000 $1,440,000 16.13%
Total Expenditures $6,776,763 $8,418,358 24.22%
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One of the unique challenges the Streetlighting utility faces compared to other utilities, is the theft of
copper wire, which leads to significant damage to the infrastructure. The FY26 budget proposes
$1,000,000 for system repairs due to theft-related damages. Public Utilities continues to explore ways
to mitigate wire theft.
Public Utilities proposes a $20,000 transfer from the General Fund for the private lights program in
FY26. $1,440,000 is anticipated for Streetlight’s Capital Improvement Program.
Figure 5 - Copied from page 12 of Public Utilities FY26 Proposed Budget Book
ADDITIONAL & BACKGROUND INFORMATION
Public Utilities Debt Service Schedule & Metro Water Assessment
This chart from the department’s budget book shows the timing of debt service (payments) on bonds and loans.
The revenue generated from the bonds is used to fund capital programs in the utilities.
Total debt service will increase this fiscal year and in subsequent years. The timing of these infrastructure costs
is partially determined by state and federal government regulatory requirements. It is also determined by
opportunities to coordinate projects with the City’s other capital programs, such as road reconstruction.
Figure 6 - Copied from page 90 of Public Utilities FY26 Proposed Budget Book
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Declining Water Delivery Volumes
The chart below shows the ongoing decline in projected water delivery volumes for Fiscal Years 2025 and 2026.
The decline in the estimated millions of gallons delivered reflects ongoing conservation efforts and changing
consumption patterns.
Despite the fewer budgeted gallons, the implementation of changes from the 2024 Rate Study and its
recommended rate adjustments aim to ensure the department will receive sufficient revenue to maintain critical
infrastructure and service delivery.
Figure 7- Copied from page 91 of Public Utilities FY26 Proposed Budget Book
CCF – Centum Cubic Feet (one hundred cubic feet of water)
FTE – Full Time Equivalent
FY – Fiscal Year
IMS – Information Management Services Department
WRF – Water Reclamation Facility
1.Fiscal Year 2025-26 Public Utilities budget book
Salt Lake City Public Utilities Rate Changes FY 2025-2026
Salt Lake City Council Work SessionMay 20, 2025
Table of Contents
1.Water Rates
2.Sewer Rates
3.Stormwater Rates
4.Streetlighting Rates
5.Understanding Rate Impacts
Water Rate Changes
1.Monthly Water Charge
2.Residential Usage Rates
3.Non-Residential Usage Rates
4.Example Impacts of Rate Changes
SALT LAKE CITY
Monthly Water Charge
o Monthly charge is a fixed fee based
on meter size.
o New charge better reflects the
fixed costs of utility operations and
infrastructure costs.
o Applies to residential and non-
residential customers.
o Rate stabilization is removed,
resulting in a decreased monthly
charge.
SALT LAKE CITY
Residential Water Usage Rates
o Maintain inclining block rate
structure from existing rates.
o Block rates apply year-round rather
than summer only.
o Less water usage in each block.
o Increase in CCF charge in each
block.
SALT LAKE CITY
Non-Residential and Multi-Family Usage Rates
o Block rates no longer apply
to non-residential and multi-
family customers.
o Uniform rate structure, with a
higher uniform rate in the
summer.
SALT LAKE CITY
Example Monthly Water Rate Change Impacts
o Minimum and low residential
use usually reflects indoor
household consumption.
o Medium and high residential
use usually reflects both
indoor and outdoor water
consumption.
o Non-residential uses vary
greatly depending on how
the water is being consumed.
Sewer Rate Changes
1.Monthly Sewer Charge
2.Usage/Flow Rates
3.Water Quality – High Strength Charges
4.Example Impacts of Rate Changes
SALT LAKE CITY
Monthly Sewer Charge
o Monthly sewer charge is a fixed fee
and is based on dwelling unit
(residential) and equivalent
residential unit (non-residential).
o New charge better reflects the
fixed costs of utility operations and
infrastructure costs.
o Rate stabilization is removed,
resulting in a decreased monthly
sewer charge.
o One ERU = 4 ccf for non-
residential.
SALT LAKE CITY
Sewer Usage/Flow Rates
o Structural change from a
waste-strength class rate to
uniform usage/flow rates.
o Rate for residential is based on
annual monthly winter
consumption for December,
January, and February.
o Rate for multi-family and
commercial is based on 70% of
actual water used.
o One ERU for commercial use is
4 CCF of water use.
SALT LAKE CITY
Water Quality Rates for High-Strength Dischargers
o Waste-strength class structure
changing to per unit cost per
pollutant.
o Addition of Ammonia and Total
Phosphorus, per regulation.
o Pollutant rates are in addition
to flow charge rate.
o These customers are typically
industrial.
2025 Structure 2026 Structure
SALT LAKE CITY
Example Monthly Sewer Rate Change Impacts (Residential)
Stormwater and Streetlighting Rate Changes
1.Stormwater Monthly Charges
2.Streetlighting Monthly Charges
SALT LAKE CITY
Monthly Stormwater Charge
o No structural change to
stormwater charge.
o 5% increase in monthly charge.
o Stormwater credit maximum
changed to 25%.
o New stormwater credit applied to
all new developments. Phased
approach to reduce stormwater
credit for existing over 25%.
o Reduction in stormwater credit will
reduce future rate impacts to
customers as cost of service is
more fairly distributed.
SALT LAKE CITY
Monthly Streetlighting Charge
o No structural change to
streetlighting charge.
o 15% increase in monthly charge.
o One ERU is one single-family
residence or 75 feet of street
frontage for non-residential
properties.
Understanding Rate Impacts
o Website Resources:
https://www.slc.gov/utilities/2025-2026-budget-information/
Rate Calculator
Customer Portal
o Customer Service
THANK YOU
Engagement
o Ensure accessibility to rate information
o Raise awareness about proposed changes
o Explain why rate changes are necessary
o Show how rates support vital services
o Ensure Council and Mayor’s Office staff are
prepared to answer constituent questions
Print Outreach
Postcards
•USPS mailing to all customers – 73,923 total
•One version for City + one version for County
Flyers
•Distributed by partners, including: SLC Economic Development; SL County Adult & Aging Services; Cities of Millcreek, Holladay, Cottonwood Heights
Bill Stuffers/eStatements
•Flyers inserted in all USPS mailed bills during the month of June – 66,000 total
•eStatements –will total over 100,000 (March, April, May, June)
Digital Engagement
www.SLC.Gov/UtilityRates: info about rates, budget, and impacts
Set up phone line for feedback and questions (67 calls)
Website
Engagement
Phone Line
Banner on login to online account where people can click to website Account Banner
Comment-based Q&A session hosted on FacebookVirtual Town Hall
Budget and Community Reinvestment posts scheduled throughout budget process - 18 Social Media/website
o 27 media mentions
o Total TV Audience - 312,196
o Total Online & Print Audience - 2,211,698
o Total YouTube Audience -306,000
Local Media Coverage
o Ongoing meetings with non-residential customers
o Individual meetings with cities
o Responding to all customer inquiries
o Presentations to the public and community groups
One-on-One/Group Meetings
Engagement Summary Report
Public Utilities Rate Change 2025
1
EXECUTIVE SUMMARY
To support proposed utility rate changes that go into effect on July 1, 2025, Salt Lake City Department
of Public Utilities (SLCDPU) launched a comprehensive public engagement effort to inform customers,
gather feedback, and build transparency around the rate-setting process. This engagement was part of a
nine-month rate study led by FCS Group and guided by a community-based Rate Advisory Committee
(RAC) representing residents, businesses, advocacy groups, and regional partners.
The engagement strategy prioritized awareness, equity, and accessibility, using a tailored, multi-channel
approach to reach residential, commercial, institutional, and industrial customers within Salt Lake City
and neighboring communities. Outreach included direct mail, utility bill inserts, in-person and virtual
meetings, social media, multilingual print and digital materials, and de-escalation training for frontline
staff.
SLCDPU conducted briefings and presentations beginning in late 2024 and continues to meet with the
community, including meetings with the Salt Lake City Council, community councils, business
associations, HOAs, school districts, advocacy organizations, and large commercial customers. A
dedicated rate change website and social media campaign provides educational videos, FAQs, and
interactive content to support customer understanding.
Feedback emphasized the need for clarity, affordability, and continued reinvestment over the next
decade in aging critical water infrastructure. Insights from the RAC and the public directly informed the
final rate design, which balances long-term financial needs with fairness, affordability, water
conservation goals, and customer support tools.
This engagement reflects SLCDPU’s commitment to transparency, fiscal responsibility, and community -
informed decision-making.
BACKGROUND
Salt Lake City’s Department of Public Utilities manages four separate utility services: water, sewer
(wastewater), stormwater, and streetlighting. These services are funded through customer fees—not
taxes—and are managed separately from each other and from the City’s general budget. While most of
these services are for Salt Lake City residents, the water utility also serves parts of neighboring cit ies
like Millcreek, Holladay, Cottonwood Heights, Murray, Midvale, and South Salt Lake.
These utility services support essential daily needs and rely on complex infrastructure—pipes, pumps,
treatment facilities, and more—that must meet local, state, and federal requirements. Many of these
systems are aging and need upgrades or replacements. To keep services running safely and reliably, the
City needs a long-term financial plan. Utility rates are a major part of that plan.
To make sure rates remain fair and effective, Salt Lake City reviews and updates its utility rate structure
approximately every five years. Salt Lake City also reviews and recommends changes to the rates each
year to ensure they are aligned with long-range revenue needs. These long-range revenue needs are
carefully developed alongside the City’s financial advisors to account for current and future
infrastructure plans and to meet debt repayments associated with revenue bonds that are used to fund
large generational aging infrastructure projects such as treatment plants. The financial planning and
infrastructure prioritization is based on best practices and regulatory requirements in the water sector.
2
This helps the City keep up with changes in infrastructure costs to continue to provide water-related
services now and in the future.
In 2024, the City hired a consulting firm, FCS Group, to complete a detailed rate study. This study sets
out proposed rate changes beginning in Fiscal Year 2026, with projections through Fiscal Year 2029.
The study looked at three major areas for each of the water-related utilities:
1. How much revenue is needed to cover day-to-day operations, maintenance, and long-term
infrastructure investments.
2. How those costs are shared between different customer groups (like homes, businesses, and
schools), based on how much service they use.
3. How rates should be structured, for example, using flat fees, usage-based rates, or tiered
pricing—to recover costs in a way that is fair, clear, and encourages conservation.
The rate study found that higher revenues will be needed in coming years, mostly due to the cost of
maintaining and replacing aging infrastructure. It also recommended some changes in how costs are
divided among customer groups to better match actual usage and service costs.
Importantly, the rate study was guided by feedback from a community -based Rate Advisory
Committee (RAC). This group helped review options and provide input on fairness, affordability,
conservation goals, and other community priorities.
ENGAGEMENT OBJECTIVES
1. Increase Public Awareness: Ensure residents and businesses understand why utility rate
changes are being proposed, how the process works, and what services are supported by utility
fees.
2. Gather Meaningful Community Input: Provide multiple opportunities for community
members, including residential, commercial, and institutional customers —to share feedback,
concerns, and preferences about the proposed rate changes.
3. Promoting Transparency and Trust: Build public trust by openly sharing information about
rate-setting methods, infrastructure needs, and financial planning, including how input will be
used in decision-making.
4. Support Informed Decision-Making: Equip City leaders and the Rate Advisory Committee
with community insights and priorities to guide policy decisions that reflect public values and
fiscal responsibility.
ENGAGEMENT APPROACH
Public Utilities provides service to a wide variety of users as such there has been a tailored approach to
the engagement. This effort to inform and educate users as well as our internal and other municipal
partners has utilized broad approaches and mediums.
Stakeholders
3
EXTERNAL (PUBLIC)
Customers
Residential properties
• Single-family
• Duplex and triplex
• Multi-family
Non-residential properties
• Commercial
• Industrial
• Institutional
INTERNAL (WITHIN SLC CORP)
Customer Service
Teams
Direct Response Departments:
• Public Utilities
• Economic Development
Related Departments:
• Public Services
• Sustainability
• Public Lands
City Advocates
Mayor’s & City Council Office Liaisons
City Communicators
*Communications PIOs, Engagement Specialists, and
Social Media Managers
City FYI Elected SLC Officials
City Leadership
KEY MESSAGES
New rates for drinking water, wastewater, stormwater, and street light services have been proposed to
begin July 1, 2025
The new rate structure will pay for :
• Major investment in the City’s aging water infrastructure, especially treatment plants.
• Repair and replacement of aging water pipes, sewer lines, and storm drains
• Ongoing costs for regulatory compliance.
Rate changes help the City adapt to evolving conditions and continue providing high-quality water,
sewer, and stormwater services.
Your payments are directly reinvested into the community to:
• Provide clean drinking water
• Safely treat sewage
• Control stormwater to prevent flooding. Keep local bodies of water clean and protect
surrounding areas from contamination
4
• Light our streets and neighborhoods
• Manage water supply for future generations
You can save money with our tips and tools that help you reduce water usage and extend our local water
supply
SUMMARY OF FEEDBACK
What have we heard?
• On March 27, the Public Utilities Advisory Committee (PUAC) unanimously recommended
approval of the proposed 2026 budget, including rates, operations, personnel changes, and the
capital program. PUAC Chair Kathryn Floor formally expressed the committee’s support by
signing the Public Utilities budget book, indicating the PUAC's concurrence with and
endorsement of the proposed budget. As of May 13, 2025, the SLCDPU engagement team has
received around 70 emails and voicemail messages from primarily residential customers. This
input provided valuable insight into public concerns, suggestions, and areas of support related to
the proposed rate adjustments. The following themes emerged:
Affordability and Fixed Incomes
• Many residents, particularly seniors, expressed difficulty managing increasing utility costs on
fixed incomes.
• Customers felt discouraged that water conservation efforts were not being reflected in lower
bills.
Rate Stabilization Fee
• There was significant concern about the temporary stabilization fee, especially its application to
multi-unit properties and fire lines.
• Customers were surprised by the fee's impact during low -use seasons.
Municipal Watering Practices
• Several respondents noted city parks and facilities watering during rainstorms or over-spraying
onto sidewalks, raising concerns about public sector efficiency.
• Calls were made for improved irrigation practices and smart controller use on public lands.
Equity in Rate Structure
• Some customers questioned whether the current structure ensures equitable contributions based
on actual use and impact on the system.
• Support was expressed for tiered pricing and conservation-based rate models.
Conservation and Landscaping
• Many customers described proactive steps to reduce water use, such as replacing turf and
updating irrigation systems.
• There is strong support for SLCDPU's water-saving programs like SLCTurf.
5
Assistance and Alternatives
• Residents asked about alternatives to using treated drinking water for irrigation.
• There was interest in Project Water Assist and other financial support for vulnerable households.
SUMMARY OF PARTICIPATION / TIMELINE
• May 2024: Rate Advisory Committee (RAC) is formed with representatives from the following
groups:
o Salt Lake City Resident Members
o SLC Mayor’s Office
o Industrial customers
o Commercial customers
o SLC School District
o Low-income Advocacy Groups
o Senior Citizen Advocacy Groups
o Mayor’s Office for Access and Belonging
o Public Utilities Advisory Committee
o Metropolitan Water District of Salt Lake & Sandy
o Utah Rivers Council
o Western Resource Advocates
o Utah League of Women Voters
o SLC Chamber
o The Cities of Millcreek, Cottonwood Heights, and Holladay
• November 19: Laura Briefer meets with Councilmember Darin Mano
• December 4: Laura Briefer meets with Councilmembers Petro, Puy, and Dugan
• December 9: Laura Briefer meets with Councilmember Chris Wharton
• Jan-April: ongoing meetings held with non-residential customers to discuss changes and receive
feedback
1. SLC School District
2. Northpoint HOA
3. Harvard Park HOA
4. SLC HOA
5. SLC Public Lands
6. Cottonwood Heights HOA
7. Belmont Downtown Condominiums Association
8. SLC Public Services
9. University of Utah
10. Sweets Candy
11. Meadow Gold Dairy
12. Utah State Fair Park
13. Uintah Brewery
14. Fisher Brewery
15. SLC Golf
16. SLC Parks & Rec
• January 7, 2025: Laura Briefer meets with Councilmember Sarah Young
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• January 7, 2025: Public Utilities/FCS Group update City Council – covered by KSL.com, Salt
Lake Tribune, KUTV
• January 23: SLCDPU’s Communications & Engagement Manager, Chloe Morroni presents
engagement strategy to Public Utilities Advisory Committee (PUAC)
• February 18: Chloe Morroni reaches out to the cities of Millcreek, Holladay, and Cottonwood
Heights to inform them of the new rate structure.
• March 27: Laura Briefer presents budget to PUAC.
• March 31: Laura Briefer sends email to all SLCDPU staff RE: Budget proposal status and
information on new rates
• April 1: “Talking About Rates” info session #1 with Customer Service (de-escalation training)
• April 1: Laura Briefer presents budget to Mayor Mendenhall
• April 2: SLCDPU engagement team shares rate change info packet via email with SLC Mayor’s
Office; Council Office; SLC Econ Development
• April 2: Laura Briefer does an interview with Ben Winslow/Fox13
• SLCDPU engagement team turns FOX13 interview into nine educational videos- posted on
webpage/social
• April 3: “Talking About Rates” info session #2 with Customer Service (de-escalation training)
• April 7: bi-weekly rate strategy meeting SCLDPU staff (non-residential customer
communications)
• April 8: rate change website goes-live
• April 10: Citywide comms meeting – Jesse Killinger presented on the new rates, emailed all City
PIOs rate information packet
• April 11: “Talking About Rates” info session #3 with Customer Service
• April 11: SLCDPU & Economic Development collaborative social media post #1
o Economic Development Ambassadors handing out rate flyers
• April 15: SLCDPU budget briefing to SLC Council
• April 15: news release RE: Laura’s Council presentation – covered by KSL.com, KUTV,
Telemundo, ABC4
• April 16: SLCDPU rates social post
• April 17: SLCDPU Virtual Townhall on Facebook – shared by Mayor’s Office and Council
• April 21: bi-weekly rate meeting SLCDPU staff (non-residential customer communications)
• Week of April 21: SLCDPU reinvestment social post #1 (videos showing where money goes)
• April 21: first rate strategy meeting with Council and Mayor’s Office liaisons and Citywide
comms team
• April 24: engagement team provides update to PUAC
• Week of April 28: postcards mailed to all City & County customers (2 versions – Spanish
translation)
• April 28: start “Rate changes coming soon…” banner for online accounts added
• Week of April 28: SLCDPU reinvestment social post #2
7
• Week of April 28: Holly Lopez follows up with Millcreek, Cottonwood Heights, Holladay; and
SL County and provides an information packet
• April 30: rate post cards hit mailboxes
• Week of May 5: flyer distribution begins for Economic Development; SL County; Millcreek,
Cottonwood Heights, Holladay; all SLC Community Councils; other organizations – Spanish
translation
• Week of May 5: SLCDPU reinvestment social post #3
• Week of May 12: SLCDPU reinvestment social post #4
• May 14: Laura Briefer presents to Economic Dev elopment Business Advisory Board
• May14: Laura Briefer talks rates at Councilmember Dugan’s town hall
• May 15: Laura Briefer presents to Salt Lake Community Network
• May 19: SLCDPU rates social post
• May 20: Laura Briefer presents at Council work session
• May 20: SLC Council public hearing #1
• Week of May 26: SLCDPU reinvestment social post #5
• June 1-30: bill insert about rate changes in all USPS bills and e-statements - Spanish translation
• June 2: SLCDPU rates social post
• June 3: SLC Council possible public hearing #3 (Tentative based on City Council scheduling)
• Week of June 9: SLCDPU reinvestment social post #6
• June 12: Deputy Director Jesse Stewart presents to Yalecrest Neighborhood Council
• Week of June 16: SLCDPU reinvestment social post #7
• July 1: new rates take effect
• July: follow up RE: “Talking About New Rates” info session
• TBD: post professionally produced video explaining rate changes
• TBD: post SLCTV produced video with Laura Briefer talking about rates on website
As part of Salt Lake City’s annual budget process, we’ve proposed
new rates to make sure they are fair, affordable, fund our generational
infrastructure projects, and support Salt Lake City’s needs.
Public Utility bill payments are directly
reinvested in our community to:
Provide clean drinking water for your home,
school, or business.
Treat Salt Lake City’s sewage safely.
Control stormwater to prevent flooding and
keep our local water bodies clean.
Maintain and repair water pipes, sewer lines,
and storm drains.
Protect the land where our drinking water
comes from.
Light our streets safely and responsibly.
Manage water supply for future generations.
You can participate in Salt Lake City’s
annual budget process or share your
feedback about proposed public
utility rate changes:
04/2025
Why Are Rates Changing?
To fund generational infrastructure improvements,
meet regulatory requirements, and ensure reliable
service for you.
What Should I Expect?
Starting July 1, 2025, your water, sewer, stormwater,
and street lighting rates will be changing.
Learn more & provide feedback
Scan the QR code or visit:
www.SLC.Gov/UtilityRates
Leave us a voicemail 385-518-2728
Send us an email SLCDPUEngagement@slc.gov
Visit https://tinyurl.com/SLCFY26 to learn how to
participate in the budget process
SCAN ME
Upcoming Changes to
Your Public Utility Rates
Próximos ajustes en las tarifas
de los servicios públicos
Como parte del proceso presupuestario anual de Salt Lake City, propusimos
nuevas tarifas para garantizar que sean justas, accesibles, financien proyectos
de infraestructura a largo plazo y cubran las necesidades de la Ciudad.
Los pagos de las facturas de los servicios
públicos se reinvierten directamente en
nuestra comunidad para:
Garantizar el suministro de agua potable para su
hogar, escuela o negocio.
Tratar las aguas residuales de Salt Lake City de
forma segura.
Controlar las aguas pluviales para prevenir
inundaciones y mantener limpias nuestras fuentes
de agua locales.
Realizar el mantenimiento y la reparación de líneas de
agua, alcantarillado y desagües pluviales.
Preservar las tierras de donde proviene el agua potable.
Iluminar las calles de forma segura y responsable.
Gestionar el suministro de agua para las
generaciones futuras.
Puede participar en el proceso
presupuestario anual de Salt Lake
City o expresar su opinión sobre
los ajustes propuestos en las tarifas
de los servicios públicos:
04/2025
¿Por qué se ajustarán las tarifas?
Para financiar mejoras en la infraestructura a
largo plazo, cumplir con los requisitos normativos
y garantizarle un servicio confiable.
¿Qué esperar?
A partir del 1 de julio de 2025, sus tarifas de
agua, alcantarillado, aguas pluviales y alumbrado
público se ajustarán.
Más información y comentarios
Escanee el código QR o visite:
www.SLC.Gov/UtilityRates
Déjenos un mensaje de voz 385-518-2728
Envíenos un correo electrónico a
SLCDPUEngagement@slc.gov
Visite https://tinyurl.com/SLCFY26 para saber cómo
participar en el proceso presupuestario anual
ESCANEAR
As part of Salt Lake City’s annual budget
process, we’ve proposed new rates to make sure
they are fair, affordable, fund our generational
infrastructure projects, and support our needs.
Como parte del proceso presupuestario anual
de Salt Lake City, propusimos nuevas tarifas
para garantizar que sean justas, asequibles,
financien nuestros proyectos de infraestructura
generacional y satisfagan nuestras necesidades.
Your public utility bill payments are directly
reinvested in our community to provide clean
drinking water for your home, school, or business
and to manage water supply for future generations.
Sus pagos de facturas de servicios públicos se
reinvierten directamente en nuestra comunidad para
proporcionar agua potable para su hogar, escuela o
negocio y para administrar el suministro de agua para
las generaciones futuras.
You can participate in Salt Lake City’s annual
budget process or share your feedback
about proposed public utility rate changes:
Puede participar en el proceso
presupuestario anual de Salt Lake City
o expresar su opinión sobre los
ajustes propuestos en las tarifas de los
servicios públicos:
04/2025
Why Are Rates Changing?
¿Por qué se ajustarán las tarifas?
To fund generational infrastructure improvements,
meet regulatory requirements, and ensure reliable
service for you.
Para financiar mejoras en la infraestructura a largo
plazo, cumplir con los requisitos normativos y
garantizarle un servicio confiable.
Leave us a voicemail Déjenos un mensaje de voz
385-518-2728
Send us an email Envíenos un correo electrónico a
SLCDPUEngagement@slc.gov
Visit https://tinyurl.com/SLCFY26 to learn how to
participate in the budget process
Visite https://tinyurl.com/SLCFY26 para saber cómo
participar en el proceso presupuestario anual
Upcoming Changes to
Your Public Utility Rates
Learn more &
provide feedback
Más información y
comentarios
Scan the QR code or visit:
Escanee el código QR o visite:
www.SLC.Gov/UtilityRates
SCAN ME
ESCANEAR
Próximos ajustes en las tarifas
de los servicios públicos
What Should I Expect?
¿Qué esperar?
Starting July 1, 2025, your water rates will
be changing.
A partir del 1 de julio de 2025, sus tarifas de
agua se ajustarán.
Upcoming Changes to Your Public Utility Rates
Próximos ajustes en las tarifas de los servicios públicos
As part of Salt Lake City’s annual budget process, we’ve proposed new rates to make sure they are
fair, affordable, fund our generational infrastructure projects, and support Salt Lake City’s needs.
Your Public Utility bill payments are
directly reinvested in our community to:
• Provide clean drinking water.
• Treat sewage safely.
• Control stormwater to prevent flooding
and keep our local water bodies clean.
• Maintain and repair water pipes, sewer
drains, and storm drains.
• Protect the land where our drinking water
comes from.
• Light our streets safely and responsibly.
• Manage future water supplies.
Participate in the City’s budget
process by giving feedback
on the proposed rate changes:
Why Are Rates Changing?
To fund improvements, meet regulatory
requirements, and ensure reliable service for you.
What Should I Expect?
Starting July 1, 2025 your water, sewer, stormwater,
and street lighting rates will be changing.
Learn More
Más información y comentarios
Scan the QR code or visit:
www.slc.gov/utilityrates
Leave us a voicemail 385-518-2728
Send us an email SLCDPUEngagement@slc.gov
Visit https://tinyurl.com/SLCFY26
Salt Lake City Department
of Public Utilities
1530 S. West Temple Street
Salt Lake City, UT 84115
PRSRT STD
US POSTAGE
PAID
SALT LAKE CITY UT
PERMIT No 571
We are planning public
utility rate changes to
begin July 1, 2025.
Estamos planeando cambios
en las tarifas de servicios
públicos que comenzarán el
1 de julio de 2025.
To learn more, flip
this card, scan the QR
code, or visit:
www.slc.gov/utilityrates
Traducción disponible en línea.
Upcoming Changes to Your Public Utility Rates
Próximos ajustes en las tarifas de los servicios públicos
As part of Salt Lake City’s annual
budget process, we’ve proposed
new rates to make sure they are
fair, affordable, fund our
generational infrastructure
projects, and support our needs.
Your public utility bill payments are
directly reinvested in our community to
provide clean drinking water for your
home, school, or business and to manage
water supply for future generations.
Participate in the City’s budget
process by giving feedback on
the proposed rate changes:
Why Are Rates Changing?
To fund improvements, meet regulatory
requirements, and ensure reliable service for you.
What Should I Expect?
Starting July 1, 2025, your water rates
will be changing.
Learn More
Más información y comentarios
Scan the QR code or visit:
www.slc.gov/utilityrates
Leave us a voicemail 385-518-2728
Send us an email SLCDPUEngagement@slc.gov
Visit https://tinyurl.com/SLCFY26
Salt Lake City Department
of Public Utilities
1530 S. West Temple Street
Salt Lake City, UT 84115
PRSRT STD
US POSTAGE PAID
SALT LAKE CITY UT
PERMIT No 571
We are planning public
utility rate changes
to begin July 1, 2025.
Estamos planeando cambios
en las tarifas de servicios
públicos que comenzarán el
1 de julio de 2025.
To learn more, flip
this card, scan the QR
code, or visit:
www.slc.gov/utilityrates
Traducción disponible en línea.
CITY COUNCIL OF SALT LAKE CITY
451 SOUTH STATE STREET, ROOM 304
P.O. BOX 145476, SALT LAKE CITY, UTAH 84114-5476
SLCCOUNCIL.COM
TEL 801-535-7600 FAX 801-535-7651
COUNCIL BUDGET
STAFF REPORT
CITY COUNCIL of SALT LAKE CITY
TO:City Council Members
FROM:Lehua Weaver
Deputy Director
DATE:May 20, 2025
RE: FY2026 BUDGET - JUSTICE COURT
WRITTEN BRIEFING
Budget Book Pages:
Key Changes: pages 51 to 52
Department Summary: pgs 211 to
215
Staffing Document: 300 to 301
ISSUE AT-A-GLANCE
The Justice Court handles misdemeanor criminal citations, small claims, traffic citations, and traffic
school for moving violations. The Fiscal Year (FY) 2026 budget proposes a total budget of $6,287,214
and 44 full-time employees, one of which is funded by Funding Our Future dollars. There is an
increase of $329,104 or 5.5% as compared to the FY 2025 Adopted budget.
This budget review will be held as a “written briefing” because the proposed budget does not include
any major requests, and no new programs or services. However, because of the inter-related nature of
the Justice Court, the Prosecutor’s Office (in the Attorney’s Department Budget), and the Legal
Defenders contract (in the Non-Departmental Budget), the topic of caseload and resource needs may
come back as a follow-up discussion with the Council. More info below.
BUDGET HIGHLIGHTS
The primary increases to the budget include:
Personnel and compensation items
The following personnel cost changes are for both the 43 general fund employees and 1 outreach
coordinator who is funded with Funding Our Future dollars.
$143,866 Salary Proposal increase
($4,503) Pension/401K decrease
($10,000) Health Savings Account decrease
Page | 2
($38,419) Insurance Rate decrease to match actual usage
$121,183 Special Projects Manager – due to a reduction to the amount received by the City from
the mitigation grant, this position is being moved into the General Fund.
$50,000 Increase for Interpreter Services – transfer from the Language Access fund in the
Mayor’s Office to help with increased usage and inflation.
Community Outreach Case Manager position - continued to support efforts to assist individuals
who are unhoused. This position is entirely funded from the Funding Our Future budget.
Security - During Budget Amendment No. 1, the Council approved an increase to the Justice Court
budget to provide additional security resources. This is continued in the annual budget for $200,000.
ADDITIONAL INFORMATION
Increased Caseload in the City’s Court System
Council Members and staff have heard that there are significant increases to case filings and hearings
in the Court system. This impacts the Justice Court, the Prosecutor’s Office (in the Attorney’s
Department Budget), and the Legal Defenders (LDA) contract (in the Non-Departmental Budget).
Adjustments to address the increased workload are needed holistically, and additions to one office
would require additions to the other two parts of the system. It is staff’s understanding that this will be
reviewed more closely with the stakeholders over the coming year for consideration in the FY27
budget, or potentially mid-year if the need is determined to be more urgent in nature.
Key considerations when evaluating the impact to the Court system:
From the Justice Court’s perspective, case filings and the number of hearings have sharply
increased. Each case filing will require a varying number of staff hours based on the unique
characteristics of the case, number of hearings before a judge, and decision.
Changes in ‘outside factors’ directly affect the Court System, for example citations issued by
the Police Department, zoning enforcement cases, prosecutorial discretion, and human
behavior.
The Court also reports seeing lingering effects from the pandemic, notably in closure rates. In
response to a staff question, Kate Fairchild, the Court Administrator provided the following
information:
o Time to Disposition - 95% of criminal case dispositions should meet established
guidelines for Time to Disposition (6 months).
The Justice Court’s time to disposition for 2024 was 76%. The time to
disposition rate was affected by the pandemic and has been steadily
increasing since, with a rate of 58% in 2022.
o Criminal Case Clearance Rate - A Clearance Rate of 100% means the court has
disposed of as many cases as were filed, i.e., the court is keeping up with its incoming
caseload.
The Justice Court has historically always met its goal of 100% case clearance
rate. However, in 2024 the clearance rate sat at 77%.
As each part of the system is overwhelmed, hearings in the Justice Court require more time to
administer effective justice. For example, if the prosecutor’s office and/or LDA are over-
burdened, then a case may not be ready to be heard by a judge and will be rescheduled.
Page | 3
The Court continues to offer outreach events to expand the ability of the Court to meet the
needs of the public. However, it should be noted that outreach events are typically conducted
in addition to the normal hearing calendars and reduces staff availability at the Court building
As the Administration evaluates this information in preparation for fiscal year 2027, the Court
will be obtaining national comparative data for staffing standards, caseload tracking from the
Utah State Administrative Office of the Courts, and other metrics.
Comparing January thru April annually:
Page | 4
Remote Hearings vs. In-Person Hearings
Based on information provided by the Justice Court, approximately 70% of hearings are conducted
remotely.
Justice Court Background
The Salt Lake City Justice Court is the largest municipal Court in the State of Utah with a very high
volume of misdemeanor cases. The Court is a limited jurisdiction Court under the umbrella of the
Utah State Court system.
The Justice Court is responsible for and processes Class B and C misdemeanor, infractions and small
claims cases, jury trials, appeals and expungements, video hearings, prisoner transports, and daily
interaction with jails throughout the State of Utah. The Court monitors and tracks probation,
warrants, community service, and restitution, collections of monetary penalties, appeals,
expungements, and plea in-abeyance cases. The Court also provides traffic school, coordination of
interpreter services, and any ADA needs that arise.
The Justice Court judiciary, employees, and security team describe their environment as “dedicated to
open and transparent access to the Court, bringing justice for all, and providing a safe and civil
environment for dispute resolution”.
Budget FY 25 -26
Presented by Kate Fairchild & Valeta Hitchcock
OVERVIEW OF CHANGES
Insights Description
1 Interpreter Funding
Current Proposed Total
$6,237,214 $50,000 $6,287,214
FTEs: 45 / PTE: 0 FTE: 0 / PTE: 0 FTE: 45 / PTE: 0
JUSTICE COURT
Justice Court Interpreters
Item Cost Type
Interpreter Funding
*This new ongoing funding for interpreters is budget
neutral for the General Fund because it will be
transferred from the existing budget for the Language
Access Fund in the Mayor’s Office budget.
$50,000 Ongoing
Total $50,000
#45
JUSTICE COURT
Justice Court Interpreters
Due to inflation, competing pay, and a
recent change in the dynamic of court
cases, we anticipate a minimum increase
of 19% in interpreter requests in the
coming year.
We are requesting $50,000 to help
support this demand.
JUSTICE COURT
Future Funding
Due to historical and ever-changing
dynamics of court cases and hearings, the
Justice Court has seen a significant
increase in the number of filings and
hearings over the last ten years. This trend
is expected to continue into the
foreseeable future. Following this trend, it
is anticipated that the court will require
additional staff to continue to provide the
public with fair access to the justice
system.
Priority of needs are as follows:❖Management❖Judicial❖Support Staff
JUSTICE COURT
*Chart shows approximate 27% increase in hearings since 2015
Justice Court Arraignment Hearing Trends
JUSTICE COURT
The Salt Lake City
Justice Court began with
four full-time judges and
one part-time judge. Over
the course of about
twenty years, the Court
has only increased its
judicial capacity by
increasing the part-time
position to a full-time
position, totaling five full-
time judges.
THANK YOU
For questions contact the Justice Court
katief@utcourts.gov
valetah@utcourts.gov
Item G6-G20
CITY COUNCIL OF SALT LAKE CITY
451 SOUTH STATE STREET, ROOM 304
P.O. BOX 145476, SALT LAKE CITY, UTAH 84114-5476
SLCCOUNCIL.COM
TEL 801-535-7600 FAX 801-535-7651
MOTION SHEET
CITY COUNCIL of SALT LAKE CITY
https://tinyurl.com/SLCFY26
TO:City Council Members
FROM: Council Staff
DATE:May 20, 2025
RE: MOTION SHEET – Ordinances for Salt Lake City and Library Budgets for FY 2025-26.
MOTION:
I move that the Council close the public hearing for items G6-G20 and refer them to a new
public hearing on June 3, 2025.
Staff note: The Council may close a public hearing and refer an item to another public hearing
which allows an individual to provide comment on the proposed annual budget twice. This allows
individuals to respond to new information and proposals as the Council's annual budget
deliberations continue.
SALT LAKE CITY TRANSMITTAL
To:
Salt Lake City Council Chair
Submission Date:
04/17/2025
Date Sent to Council:
04/21/2025
From:
Department *
Public Utilities
Employee Name:
Briefer, Laura
E-mail
Laura.Briefer@slc.gov
Department Director Signature
Director Signed Date
04/17/2025
Chief Administrator Officer's Signature
Chief Administrator Officer's Signed Date
04/21/2025
Subject:
Ordinance Updates to Title 17 to Comply with Rate Study and Regulatory Requirements
New transmittal or
Revision
New transmittal
Revision
Revision Updates:
Adding clean and legislative ordinance changes with signed attorney form approved.
Additional Staff Contact:
Lisa Tarufelli, Public Utilities Finance Administrator: lisa.tarufelli@slc.govJamey West, Public Utilities Water Reclamation Facility Administrator: jamey.west@slc.gov
Presenters/Staff Table
Laura Briefer, laura.briefer@slc.govLisa Tarufelli, lisa.tarufelli@slc.govJamey West, jamey.west@slc.govTerry Price, terrence.price@slc.gov
Document Type
Ordinance
Budget Impact?
Yes
No
Recommendation:
Recommendation to adopt proposed Title 17 ordinance updates to comply with the City's updated water, sewer, and stormwater rate structures, and to comply with regulatory requirements.
Background/Discussion
Salt Lake City Department of Public Utilities is requesting ordinance updates to align with recommendations identified in the 2024 Water, Wastewater, and Stormwater Rate Study (Rate Study). These changes amend Title 17 of Salt Lake City’s ordinance and will need to be enacted upon adoption of the Fiscal Year 2025-2026 Consolidated Fee Schedule and the SLCDPU Fiscal Year 2025-2026 Budget. The Council received a copy of the Rate Study via a separate transmittal and was briefed regarding the Rate Study on January 7, 2025. The Council was briefed regarding the SLCDPU FY 2025-2026 Budget on April 15, 2025.
As part of this transmittal, SLCDPU is additionally requesting changes to Title 17 that are required by the Utah Department of Environmental Quality, Division of Water Quality (DWQ) in the 2023 SLCDPU Pretreatment Program Legal Authority Audit. These changes are not related to
the Rate Study or FY 2025-2026 Budget, but are a regulatory requirement from the DWQ, in their enforcement role of the City’s Pretreatment Program
Will there need to be a public hearing for this item?*
Yes
No
Public Process
The City has included an extensive public process associated with the development of its updated Rate Study, the implementation of new rates and updated rate structures, and its Fiscal Year 2025-2026 Budget.
This page has intentionally been left blank
Enclosure 1
PRETREATMENT
AUDIT REPORT
SALT LAKE CITY
Prepared by:
Utah Division of Water Quality
Pretreatment Program
195 North 1950 West
PO Box 144870
Salt Lake City, Utah 84114
2 of 42
TABLE OF CONTENTS
Page Number
1. INTRODUCTION ................................................................................................................... 5
2. POTW INFORMATION ......................................................................................................... 6
3. PRETREATMENT PROGRAM and OPERATING PROCEDURES ................................... 8
4. SIU FILE REVIEW ............................................................................................................... 12
5. SIU PERMITS ....................................................................................................................... 20
6. REPORTING and REPORT SUBMITTALS........................................................................ 24
7. MONITORING ..................................................................................................................... 25
8. INDUSTRIAL USER CHARACTERIZATION and INSPECTIONS ................................. 27
9. ENFORCEMENT .................................................................................................................. 28
10. DOCUMENT REVIEW ........................................................................................................ 29
11. SUMMARY........................................................................................................................... 30
ENDNOTES ................................................................................................................................. 32
Acronyms/Abbreviations
Program Approved POTW Pretreatment
Program i, ii
BOD5 Biochemical Oxygen Demand
for five days
CA Control Authority
CFR Code of Federal Regulations
CIU Categorical Industrial User
CN Cyanide
CROMERR Cross-media electronic
reporting rule
DMR Discharge Monitoring Report
DWQ Utah Division of Water Quality
ECHO Enforcement and Compliance
History Online
ELG Effluent limit guideline
EPA Environmental Protection
Agency
ERP Enforcement Response Plan
FTE Full-time employee
FOG Fats, oils and grease
FOGS Fats, oils, grease and sand
IU Industrial User
IUFRF Industrial User File Review
Form
IWS Industrial Waste Survey
MAHL Maximum Allowable Headworks
Loading
MGD Million Gallons a Day
MS4 Municipal Separate Storm Sewer
System
netDMR The web-based system for the
submittal of DMRs
NOV Notice of Violation
PCI Pretreatment Compliance Inspection
POTW Publicly Owned Treatment Works
SIU Significant Industrial User
SMP Solvent Management Plan
SNC Significant Noncompliance
SWPPP Stormwater Pollution Prevention
Plan
TDS Total Dissolved Solids
TOMP Toxic Organic Management Plan
TSS Total Suspended Solids
TTOs Total Toxic Organics
UPDES Utah Pollution Discharge
Elimination System
UST Underground Storage Tank
WRF Water Reclamation Facility
3 of 42
PRETREATMENT AUDIT
SALT LAKE CITY
IF AN EXTENSION IS NEEDED FOR ANY RECOMMENDATION STATED IN THE
REPORT, A VERBAL OR EMAIL REQUEST SHOULD BE PROVIDED BY THE CA
WITHIN 5 DAYS OF RECEIVING THIS REPORT TO DWQ. FOR A
RECOMMENDATION THAT HAS A TIME FRAME OF MORE THAN 45 DAYS, A
WRITTEN JUSTIFICATION FOR THE EXTENSION SHOULD BE PROVIDED
WITHIN 15 DAYS OF RECEIVING THIS REPORT. FOR TIME FRAMES LESS THAN
45 DAYS, A WRITTEN JUSTIFICATION FOR AN EXTENSION SHOULD BE
PROVIDED WITHIN 5 DAYS. WRITTEN APPROVAL FOR AN EXTENSION WILL BE
PROVIDED BY DWQ IF GRANTED. EXTENSION REQUESTS SHOULD BE
SUBMITTED TO THE DWQ PRETREATMENT COORDINATOR.
Information submitted for this report can be emailed if the document is a draft or to request
an extension. Any final changes to the Program should be submitted per 40 CFR 403.18iii
and mailed to DWQ.
ALL RECOMMENDATIONS SHOULD BE ADDRESSED AS SOON AS POSSIBLE.
RECOMMENDATIONS SHOULD BE IMPLEMENTED BY THE CA IN ALL
APPLICABLE AREAS OF THE PRETREATMENT PROGRAM. IF A
RECOMMENDATION IS FOR A SPECIFIC PERMITTEE, THE RECOMMENDATION
SHOULD BE ADDRESSED AND IMPLEMENTED IN ALL APPLICABLE AREAS OF
THE PRETREATMENT PROGRAM. IF A RECOMMENDATION IS NOT
COMPLETED OR IMPLEMENTED IN ALL APPLICABLE AREAS OF THE
PRETREATMENT PROGRAM, FURTHER ACTION BY DWQ MAY OCCUR,
INCLUDING ENFORCEMENT.
Sections 2 and 3 of the report are information based on the Statement of Basis/Fact Sheet for
the UPDES Permit, the UPDES Permit issued to the CA, the Program, the information
provided by the CA in the Pretreatment Annual Reports, or information stated by the CA
during the inspection.
Section 4 of the report summarizes the information from the file review. The industrial user
file review form (IUFRF) is used to gather the information for the file review. The
information in the IUFRF assists in determining compliance with the pretreatment
regulations for the files reviewed as part of the audit or PCI. Data from the file review is
generally reviewed for the last twelve to twenty-four months. Guidance states, in the Control
Authority Pretreatment Audit Checklist and Instructions from February 2010, “the auditor
should review a representative number of SIU files.” Therefore, files were selected based on
the compliance history or when DWQ last reviewed the file.
Information in Sections 5.1, 6.1, 7.1, 8.1 and 9.1 is based on the Program implemented by the
CA or information gathered during the inspection. The recommendations in Sections 2, 3
and 5 through 9 are based on the information found in Section 4 or information collected
based on the Program, the information provided by the CA in the Pretreatment Annual
4 of 42
Reports, the file reviews or inspections at the SIUs. The Program developed and
implemented by the CA, EPA Guidance and the Code of Federal Regulations were utilized
to determine if a time frame should be provided for the CA to complete or submit the
recommendation to DWQ.
Sections 10 and 11 are summary sections. Section 10 summarizes the documents reviewed
for the report and received documentation from the permittee.
Section 11 summarizes some of the recommendations stated in this report. It is recommended
that the table in Section 11 be used to document when information is provided to DWQ.
Although some information may not need to be sent to DWQ, the CA should implement the
recommendations, which state a time frame for completing the recommendation. The CA
should review the report thoroughly to ensure all recommendations are addressed, as some
may not be included in Section 11. DWQ may follow up on all recommendations in the
report. Documentation should be submitted to DWQ for any pretreatment documents that
are changed due to the recommendations (e.g., forms, inspection reports, permits, etc.)
modified as a result of this report; the documents should be submitted per 40 CFR 403.18 iii.
Time frames for completing recommendations are stated as the days following receiving the
report. This is interpreted as calendar days, including the weekend. If the time frame ends
on the weekend or a state of Utah observed holiday, the recommendation should be
submitted to DWQ on the next working day. Receipt of this report is either when the
documents for the report are signed for by the CA if sent via the US Postal Service or when
the email is sent from the DWQ to the CA.
A request for an extension beyond what is stated above should be made in writing with
justification to DWQ at least 30 days before the due date indicated in the report. Failure to
request an extension or complete a recommendation within the time frame stated for
completing the recommendation could result in further action by DWQ.
The recommendations should be reviewed and modified based on the recommendation if
SLC determines they are necessary. If a recommendation is not implemented, it is
recommended that justification be documented as to why it was not implemented. The
documentation does not need to be submitted to DWQ unless stated in the recommendation.
If a modification or notification is required, it should occur within a year of receiving this
report unless another time frame for completing the recommendation is stated.
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PRETREATMENT AUDIT
REPORT
1. INTRODUCTION
The Utah Division of Water Quality (DWQ) conducted a pretreatment audit of the Approved
POTW Pretreatment Program (Program)i, ii implemented by Salt Lake City (SLC). The audit
began on 26 July 2023 at 08:15 until 09:30 on 2 August 2023. The participants in the audit
included:
Terrence Price Regulatory Compliance Manager
Salt Lake City
Lindsay Cowles Pretreatment Program Coordinator
Salt Lake City
Kelly Curtin Senior Permit Writer
Salt Lake City
Austin White Senior Permit Writer
Salt Lake City
Conner Hansen Permit Writer/Inspector
Salt Lake City
Mahonou Gaunou Sampler/Inspector
Salt Lake City
Chad Stratton FOG Program Manager
Salt Lake City
Dallin Stettler FOG Sampler
Salt Lake City
Jennifer Robinson Pretreatment Program Coordinator
Division of Water Quality
Jennifer Berjikian Environmental Scientist
Division of Water Quality
The purpose of the audit was to evaluate the Program. The audit consisted of discussions with
the SLC Pretreatment Personnel, the examination of pretreatment records, and a closeout
discussion. A file review and inspection were completed at: Fisher Brewery Company LLC,
Actavis Laboratories, American Diamond Tool, Blackrock Microsystems, Cintas, Dominion
Energy – Questar Gas Company, Graphic Ink Company, High West Holdings LLC, Meadow
Gold Dairies, Passey & Son Jewelry LLC, Sportsman’s Warehouse, Star Foundry and
Machine, SLCDA – Deicing Fluid Reclamation Plant, Sweet Candy Company, Varex Imaging
Corp and Welfare Square Cannery.
Information for this report was gathered from the following: the Program implemented by
SLC, the UPDES Permit issued to SLC by DWQ, discussions, information regarding the SIU
inspections and file reviews, EPA Guidance, categorical standards listed in 40 CFR and 40
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CFR 403. A review of the following occurred: legal authorityiv, the procedures v, the
enforcement response plan vi, the industrial waste surveyvii, the resources and funding,viii and
the SLC Local Limit ix Development Document. Additional information regarding the review
and discussions regarding these components of the SLC Program are provided in this report.
2. POTW INFORMATION, UPDES PERMIT and PERMIT REQUIREMENTS
2.1. POTW Basic Information
SLC owns, operates, and maintains the SLC Water Reclamation Facility (WRF) and the
collection system. The POTW treats wastewater from residential, commercial, and
Industrial Users within the city limits of Salt Lake City. The WRF is located at 1365
West 2300 North in Salt Lake City, Utah. The pretreatment personnel, offices, and files
are located near the WRF at 2020 North Redwood Road in Salt Lake City, which is also
the mailing address for the Program.
The City is modifying the WRF. The modification is due to more stringent effluent
standards in the UPDES Permit. The modification is to a biological nutrient removal
system (BNR).
2.2. Water Reclamation Facility (WRF) Information
The WRF has a design capacity of 56.0 MGD. It is a trickling filter system with chlorine
disinfection. The Oil Drain Canal is the receiving stream for the effluent. The WRF was
not inspected as part of the audit.
2.3. UPDES Permit Information
DWQ has issued an UPDES Permit to SLC, permit number UT0021725. The UPDES
Permit became effective on 1 January 2021 and will expire on 31 December 2024.
Provisions for the Program are included in Part II of the UPDES Permit. This includes
requirements for implementing the Program per 40 CFR 403 and R317-8-8. SLC must
provide information to DWQ regarding Industrial Users discharging to the POTW,
providing any modification to the Program to DWQ per 40 CFR 403.18iii, monitoring the
influent and effluent for the priority pollutants, providing the annual report yearly by
March 28th and reviewing and updating Local Limits, as needed. The permit also allows
DWQ to take action to ensure enforcement of the Program is occurring.
2.3.1. POTW Compliance Information
Since the last pretreatment inspection and before the audit, no violations of the
UPDES effluent limits have occurred. A WET test failure occurred for a chronic
WET test in January 2020. Although, the permit requires chronic WET testing as
an indicator only; therefore, the failure was not a violation of the UPDES Permit.
This was also noted in the 2020 PCI Report.
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2.3.2. Sampling, UPDES Part II H
The UPDES Permit requires influent and effluent samples to be analyzed every
other month/six times yearly for metals and cyanide and twice yearly for toxic
organics. Analysis for the metals listed in the permit must meet the sampling
requirements stated in Part II H of the UPDES Permit.
DWQ reviewed the metals and cyanide data in Part II H of the permit for
compliance with the permit, utilizing the EPA Enforcement and Compliance
History Online (ECHO) website. The following link is to the ECHO data:
https://echo.epa.gov/effluent-charts#UT0021725
Based on the data review, SLC is sampling per the requirements of Part II H.
2.3.3. Reporting Requirements
Salt Lake City must report loads greater than the maximum allowable headworks
loading (MAHL) for pollutants listed in Part II H. SLC has not reported
information regarding this criterion in the permit to DWQ.
The permit requires SLC to submit an annual report yearly. The SLC submitted
the pretreatment annual report for 2023 per the requirement of Part II C.
2.4. Recommendation
Documentation regarding whether SLC implements the recommendation should be
available to DWQ for review during future inspections. If SLC does not implement
the recommendation, outreach may occur regarding the need to implement the
recommendation.
If the analysis for a pollutant of concern is non-detect, it is recommended that if a method
with a lower detection is available, the lower detection method be utilized. This will
assist with developing local limits; see EPA Local Limit Guidance (LLG) Section 4.6
for additional information on this topic.
It is recommended that the most sensitive method be used to analyze the parameters for
which Local Limits have been developed. This ensures that data for Local Limit
development is based on analysis from the POTW rather than literature values. Based on
the data review in ECHO, this seems to be occurring for most of the parameters.
However, this is not occurring for mercury. Since a local limit has been developed for
mercury, it is recommended that a method with a lower detection limit be utilized to
ensure that the data for the development of the limit is based on data from the SLC WRF
rather than literature values. As stated in the EPA LLG page 9-5:
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…the most accurate and technically defensible limits are the result of using site-
specific data, rather than “generic” removal efficiency data derived from average,
national-level treatment works “literature” data.
3. PRETREATMENT PROGRAM and OPERATING PROCEDURES
3.1. Pretreatment Program General Information
EPA approved the Program in 1982. Modifications and changes have been made to the
Program and submitted to DWQ. However, discussions have occurred regarding
modifications to Program documents, which have been modified due to wording. Some
of these may not have been submitted to DWQ. However, if the modification was not
submitted, this was communicated to DWQ, and DWQ agreed that the wording was
similar; therefore, it did not need to be submitted per 40 CFR 403.18 (d)iii.
3.2. Legal Authority iv
The legal authority was reviewed as part of the audit. The review checklist for the legal
authority is attached to this report.
The legal authority has been updated to include the requirements for streamlining. DWQ
last approved the legal authority for the SLC Program on 30 March 2022. The public
comment period for the legal authority occurred from 30 January 2022 until 10 March
2022. During the public comment period, no comments were received, and no changes
occurred of the legal authority; therefore, an additional public notice did not occur.
The legal authority has some optional provisions from 40 CFR 403 per the modifications
that occurred in October 2005. The following optional streamlining provisions are
incorporated into the legal authority:
• Equivalent mass limits, EPA Fact Sheet 3.0,
• Equivalent concentration based limits, EPA Fact Sheet 4.0,
• Equivalent limitations for average and maximum equivalent limitation;
• Non-Significant Categorical Industrial User, EPA Fact Sheet 5.0;
• Middle tier CIU, EPA Fact Sheet 5.0;
• Pollutants not present, EPA Fact Sheet 6.0; and
• BMPs x as Local Limits, EPA Fact Sheet 7.0.
Also included in the SLC Rules and Regulations are the following provisions:
• Determining that an SIU that does not violate a Pretreatment Standard xi is
an IU;
• Affirmative Defense for general prohibitions;
• Affirmative Defense for Upset xii; and
• Affirmative Defense for Bypass xiii.
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SLC must ensure that the abovementioned provisions are appropriately implemented per
the requirements of the SLC Ordinance, 40 CFR 403 and R317-8-8. Also, per 40 CFR
403.8 (f)(2)v, procedures must be developed to ensure the conditions are consistently
implemented.
3.3. Procedures v
DWQ reviewed some of the SLC procedures for implementing the Program. Sections
related to the information based on the review of the SLC Standard Operating
Instructions (SOI) for the Program may cover additional comments, information, and
recommendations.
SLC must ensure updated procedures are submitted to DWQ per 40 CFR 403.18iii.
However, as stated in the SLC SOI PT-PER-01, grammar corrections may not need to be
submitted.
3.4. Funding and Resources viii
The budget for the Program has increased from $1,191,621.99 in 2023, an increase of
about 9% from the previous budget year. SLC has not increased the staffing of the
Program. Currently, nine members of the SLC staff administer the Program.
Adequate equipment seems to be provided to the pretreatment personnel to complete the
requirements of the SLC Program. Technical documents are also available to implement
the program.
Pretreatment personnel stay informed about current and developing regulations by
attending workshops and receiving information from the EPA, the Water Environment
Association of Utah (WEAU) and the Region 8 Pretreatment Association (R8PA).
Based on the budget and staffing, SLC appears to be providing adequate resources to the
Program. DWQ will continue to review the resources during future audits.
3.5. Local Limits ix
SLC has developed Local Limits, which DWQ approved on 19 September 2017. A
technical evaluation of the Local Limits occurred per the permit requirements. Based on
the review of the documents submitted to DWQ on 26 May 2021, it was determined that
the Local Limits were protective, and a revision was not necessary at that time. The
UPDES Permit will be renewed soon; a new technical review must be submitted per the
permit requirements.
3.6. Recommendations
Documentation regarding whether SLC implements the recommendation should be
available to DWQ for review during future inspections. If SLC does not implement
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the recommendation, outreach may occur regarding the need to implement the
recommendation.
If a recommendation in this section results in a change to the SLC Program, it
should be submitted to the DWQ Pretreatment Coordinator within a year.
3.6.1. The Program cannot go beyond the scope of the mailing requirements allowed by
Region VIII for DWQ. This is implemented by the following means:
• If the submittal is being sent to DWQ by the US Postal Service, the
postmark by the US Postal Service is the received date.
• If another carrier is used, the date DWQ receives the submittal is when it
was received.
Procedures that allow other carriers to be covered as of the date the carrier
receives the document should be modified. This was found on page 7 of the SLC
ERP.
3.6.2. New pretreatment staff should be provided with additional training opportunities.
Since the audit, a new pretreatment coordinator and permit writers have been
hired. Additional training of these staff members will ensure the Program is
implemented per the requirements of the SLC Ordinance, the SLC Program
Procedures and 40 CFR 403.8 (f). Additional training opportunities are available
on the EPA website at the following links.
https://www.epa.gov/npdes/national-pretreatment-program-training-and-
webinars
https://www.epa.gov/npdes/national-pretreatment-program-events
https://www.epa.gov/npdes/npdes-recorded-training-and-webinars
3.6.3. It is recommended that if the SLC Development Review Division finds that a
facility does not need a permit, however, it is determined that a permit is
necessary by the SLC Pretreatment Staff that additional outreach be provided to
the SLC Development Review Division. This ensures that if an inconsistency
occurs, it is corrected or referred to the SLC Pretreatment Staff as needing
additional review by the SLC Development Review Division. This
recommendation is based on the information in the SOI PT-IWS Section 5.2 as
follows:
…Informing Development Review Division if a User (identified on the
Master IU List) requires a Wastewater Discharge Permit;
If/when not specifically requested by the Development Review Division,
the Pretreatment Program is responsible for requesting the IU to complete
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an Industrial & Commercial User Questionnaire (i.e., IWS Survey form)
and/or a Wastewater Discharge Permit Application…
3.6.4. The staffing and funding of the Program seem adequate. However, it is
recommended that staff in management, the collection system, the treatment plant
and the SLC Development Review Division receive training regarding
pretreatment to ensure communication is provided to the SLC Pretreatment
Personnel and management regarding issues within the POTW. This could be
provided by attending local pretreatment training or having staff watch the
pretreatment webinars hosted by the EPA. The following link is to the
pretreatment webinars that the EPA has recorded:
https://www.epa.gov/npdes/national-pretreatment-program-training-and-
webinars
3.7. Recommendations
Documentation regarding whether SLC implements the recommendation should be
available to DWQ for review during future inspections. If SLC does not address the
recommendation, the information regarding the recommendation needing to be
addressed may be referred to the DWQ Compliance and Enforcement Section.
3.7.1. Review the summary of the legal authority for the SLC Rules and Regulations.
Based on the review, notify the DWQ Pretreatment Coordinator of any
modifications to the legal authority that will occur. This should be submitted to
the DWQ Pretreatment Coordinator within 30 days of receiving this report. The
notification should include the timeframe for submitting a draft of the legal
authority to the DWQ Pretreatment Coordinator.
3.7.2. The legal authority allows the postmark date to be the date of receipt for any
postal carrier. EPA and DWQ have historically allowed for the postmark of the
U.S. Postal Service as the receipt date per the air quality rule for the receipt of
payment. In Utah, this allowance is based on the Air Quality Rule R305-4-10
(11).
Modify the SLC Ordinance regarding report receipt. This is recommended
because the provision goes beyond what has been allowed per the Air Quality
Rule by EPA and DWQ. This modification and any other recommended
modifications based on the attached ordinance review should be completed within
a year of receiving this report.
3.7.3. The following statement is in the SOI PT-PER-01:
Any substantive changes (i.e., anything more than administrative and
grammar corrections) to the Permit Application/BMR must be submitted to
the State prior to implementation in accordance with UAC R317-8-8.
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SLC has discussed administrative and grammar corrections to the procedures in
the past with DWQ; this should continue. This has ensured that DWQ and SLC
agreed that the changes did not need to be submitted before changes were
implemented. The changes not submitted and discussed with DWQ included title
changes and minor wordsmithing of the procedures.
4. SIU FILE REVIEW
4.1. General File Review Findings
The fact sheet provides justification for the permit. It includes information regarding the
facility and the requirements the permittee must meet. Also included is information for
the Local Limit parameters, with justification regarding why a parameter was included
or not included as a limitation in the permit and information regarding the permittee's
compliance history.
The files that were reviewed contained inspection reports that met the requirements of
the IUFRF. Based on the review, the Program reviews previous inspections before the
inspection. The program also sends a certified letter to the permittee regarding the
inspection and, if necessary, any issues that need to be addressed.
The permits clearly state the requirements for the permittee regarding the development
and implementation of a slug control plan. Information is included in the permit, which
is not supported by 17.36.150. A discussion occurred regarding this, and SLC is of the
opinion that with information in the ordinance, the information in the permit is supported
by the ordinance.
The files documented enforcement actions well. The file contained information regarding
the action taken against the permittee. If the action was a verbal warning, information
was documented regarding the conversation with the permittee.
Reports are required to be submitted on the 28th day following the end of the reporting
period. A table in the permit indicates when the permittee must submit the reports to
SLC.
4.2. Specific Permit Findings
4.2.1. A. Fisher Brewery Company, LLC
A. Fisher Brewery Company, LLC is a beer manufacturing facility. The facility
is being permitted as an SIU.
The permittee developed a slug control plan, which was submitted on 13
December 2022. Based on the review, information was included for the
requirements in 40 CFR 403.8 (f)(2)(vi)(A)-(C)v and met the file review
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requirements. Documentation regarding the review by SLC was found in the file.
The review indicated that SLC found the plan to meet the permit requirements.
Four reports were reviewed, with information being received per the requirements
of the permit. However, SLC noted a few minor compliance issues, which were
followed up on with the permittee. The sample taken by the Program complied
with the permit requirements. No additional compliance issues were found as part
of the review by DWQ.
4.2.2. Actavis Laboratories
Actavis Laboratories is a pharmaceutical facility. It manufactures transdermal
patches and topical gels, which are also packaged at the facility. The facility is
permitted as a CIU with limitations based on 40 CFR 439.40 and local limits.
Based on the information in the file, the permittee has been properly categorized,
and appropriate limitations are included in the permit.
The permit stated the date the permittee began operation. This provided the
information needed to ensure the correct standard was used for the categorical
limitations. Based on this information, the facility is an existing source subject to
the standards in 40 CFR 439.46.
The facility developed a slug control plan, which was submitted on 5 October
2017. Based on the review, information was included for the requirements in 40
CFR 403.8 (f)(2)(vi)(A)-(C)v and met the file review requirements.
Documentation regarding the review by SLC was found in the file. The review
indicated that SLC found the plan to meet the permit requirements.
4.2.3. American Diamond Tool
American Diamond Tool manufactures diamond drill bits and downhole tooling
for the drilling industry. If the facility discharged to the POTW, the facility would
be required to meet the categorical standards found in 40 CFR 464. However, the
facility does not discharge, so a zero-discharge permit has been issued.
The permittee was not required to develop a slug control plan. However, the
permit does include language that a plan must be developed and submitted for
approval if required. The inspection report provided information regarding the
review for a slug control plan and supported the continuation of not requiring a
plan to be submitted for approval.
Three zero-discharge reports were reviewed. The reports were received per the
requirements of the permit. However, one was not signed by the signatory
authority. SLC included information regarding this issue in the file. The
information included the updated signatory authority, with the report being
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resubmitted by the permittee. No additional compliance issues were found as part
of the review by DWQ.
4.2.4. Blackrock Microsystems
Blackrock Microsystems develops and manufactures medical devices used in
neuro-technology research. The facility is permitted as a CIU with limitations
based on 40 CFR 469.
The permit stated the date the permittee began operation. This provided the
information needed to ensure the correct standard was used for the categorical
limitations. Based on this information, the facility is a new source subject to the
standards in 40 CFR 469.18.
A sample was taken on 12 August 2021 for the POTW sample. The following
sample was taken on 18 August 2022.
The facility developed a slug control plan, which was submitted on 13 September
2022. Based on the review, information was included for the requirements in 40
CFR 403.8 (f)(2)(vi)(A)-(C)v and met the file review requirements. The file also
included information regarding the review of the plan by SLC. The review
indicated that SLC found the plan to meet the permit requirements.
The facility was responsible for a spill discharged to the POTW. The spill
occurred on 23 May 2023. A verbal warning was noted in the file, which was
conveyed during a phone call when the spill was reported on 24 May 2023. The
report regarding the spill was received on 26 May 2023.
The facility submitted a TOMP that met 40 CFR 469. The reporting requirements
were provided for the TOMP per the requirements of 40 CFR 469 and the permit.
These were submitted as part of the self-monitoring reports.
Two reports were reviewed. SLC provided notes regarding the review of the
reports. A report was submitted late, so SLC issued an NOV to the permittee. It
seems that the permittee addressed the issue of the report being submitted late.
4.2.5. Cintas
Cintas is an industrial laundry that rents garments, mats, mops, linen and shop
towels. The facility also includes delivery and collection to customers. The
facility is being permitted as an SIU.
The permittee developed a slug control plan, which was submitted on 22 July
2021. Based on the review, information was included for the requirements in 40
CFR 403.8 (f)(2)(vi)(A)-(C)v and met the file review requirements.
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Documentation regarding the review by SLC was found in the file. The review
indicated that SLC found the plan to meet the permit requirements.
The facility is allowed to sample utilizing timed composite sampling techniques.
Little was found in the file regarding the justification for the timed sampling other
than the facility having a flow meter. The permit states that a minimum of 12
aliquots should be taken for the composite sample. It does not state the time
between aliquots.
A sample was taken on 2 June 2022 for the POTW sample. The following sample
was taken on 6 June 2023.
Four reports were reviewed, with information being received per the requirements
of the permit. Notes regarding flags on the lab reports were noted. The sample
taken by the Program complied with the permit requirements.
4.2.6. Dominion Energy – Questar Gas Company
Dominion Energy —Questar Gas Company distributes natural gas to customers.
The facility discharges to the POTW from groundwater extraction wells, an
oil/water separator and an air stripper. It has not discharged into the POTW since
October 2017.
The information in the file indicates that a slug control plan is not required at this
time. However, it will be required if the permittee resumes groundwater
remediations. The permit states that a slug control plan is required.
An inspection occurred on 10 May 2022. The following inspection occurred on
16 May 2023.
The facility has not discharged into the POTW, so the permittee and SLC have
not taken samples since 2017. The permittee submitted reports indicating that the
facility was not discharging to the POTW. Five reports were reviewed, which
were received per the permit requirements. SLC noted on the reviews of the report
that there were no violations.
4.2.7. Graphic Ink Company
Graphic Ink Company manufactures oil, acrylate and water inks for printing. This
is done at the facility by mixing and milling raw materials. The tanks used in the
process are cleaned using solvents. The facility is covered by the categorical
standard found in 40 CFR 447, which indicates that the facility cannot discharge
process wastewater into a POTW. SLC has issued the facility a zero-discharge
permit as required by 40 CFR 447.
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The permittee was not required to develop a slug control plan. However, the
permit does include language that a plan must be developed and submitted for
approval if required. The inspection report provided information regarding the
review for a slug control plan and supported the continuation of not requiring a
plan to be submitted for approval.
Three zero-discharge reports were reviewed. The reports were received per the
requirements of the permit. The reviews by SLC noted compliance issues. No
additional compliance issues were found as part of the review by DWQ.
4.2.8. High West Holdings LLC
High West Holdings, LLC (HWH) is a whiskey distillery. The facility stores,
matures and bottles the whisky. HWH is a new permittee and is being permitted
as an SIU.
The permittee developed a slug control plan, which was submitted on 2
September 2022. Based on the review, information was included for the
requirements in 40 CFR 403.8 (f)(2)(vi)(A)-(C) and met the file review
requirements. Documentation regarding the review by SLC was found in the file.
The review indicated that SLC found the plan to meet the permit requirements.
DWQ reviewed the reporting information, which was received per the permit
requirements. SLC noted issues with the reports and followed up with the
permittee. No additional compliance issues were found as part of the review by
DWQ.
4.2.9. Meadow Gold Dairies
Meadow Gold Dairies processes and packages dairy and other products. The
products manufactured at the facility include the following: eggnog, sour cream,
buttermilk, juices, other beverages and 1%, 2% skim, whole, chocolate and
strawberry milk. The facility is being permitted as an SIU.
A spill plan was submitted. The plan included detailed information regarding the
discharge from each area of the facility, including actions to take if there is an
issue in the area that could impact the POTW. However, information regarding
the description of discharge into the POTW was not provided per 40 CFR 403.8
(f)(2)(vi)(A)v. Information regarding 40 CFR (f)(2)(vi)(B) and (C) was included,
and the information from D seemed to be included too. The facility has been
responsible for a spill/slug to the POTW, and information regarding the historic
spill was included in the plan.
Four reports were reviewed. SLC noted issues with the reports, which resulted in
an NOV being issued to the permittee. The sample taken by SLC complied with
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the permit requirements. No additional compliance issues were found as part of
the review by DWQ.
4.2.10. Passey & Son Jewelry, LLC
Passey & Son Jewelry, LLC repairs and cleans jewelry for customers. If the
facility discharged to the POTW, it would be required to meet the categorical
standards found in 40 CFR 433 and subject to the new source standards. However,
the facility does not discharge, so a zero-discharge permit has been issued.
The permittee was not required to develop a slug control plan. However, the
permit does include language that a plan must be developed and submitted for
approval if required. The inspection report provided information regarding the
review for a slug control plan and supported the continuation of not requiring a
plan to be submitted for approval.
Three zero-discharge reports were reviewed. The reports were received per the
requirements of the permit. The file included information regarding the SLC
review of the reports. SLC did not find any issues or violations of the reports. No
additional compliance issues were found as part of the review by DWQ.
4.2.11. Sportsman’s Warehouse
Sportsman’s Warehouse repairs and refinishes firearms. The firearms are
recoated using a bluing solution as part of the refinishing. The rinse water is
evaporated. If the facility discharged to the POTW, the facility would be required
to meet the categorical standards found in 40 CFR 433. However, the facility does
not discharge, so a zero-discharge permit has been issued.
The permittee was not required to develop a slug control plan. However, the
permit does include language that a plan must be developed and submitted for
approval if required. The inspection report provided information regarding the
review for a slug control plan and supported the continuation of not requiring a
plan to be submitted for approval.
Three zero-discharge reports were reviewed. One report was received late. The
following reports were received per the requirements of the permit. No additional
compliance issues were found as part of the review by DWQ.
4.2.12. Star Foundry and Machine
Star Foundry and Machine manufactures components and parts, which are cast
and machined at the facility. These operations include melting, molding pattern
making, grinding, welding, heat treating and machining the components. If the
facility discharged to the POTW, it would be required to meet the categorical
standards found in 40 CFR 464 and subject to the existing source standards.
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However, the facility does not discharge, so a zero-discharge permit has been
issued.
The permittee was not required to develop a slug control plan. However, the
permit does include language that a plan must be developed and submitted for
approval if required. The inspection report provided information regarding the
review for a slug control plan and supported the continuation of not requiring a
plan to be submitted for approval.
Three zero-discharge reports were reviewed. One report was received late.
Information was indicated in the file that the permittee was given a verbal
warning regarding the late report. No additional compliance issues were found as
part of the review by DWQ.
4.2.13. SLCDA – Deicing Fluid Reclamation Plant
SLCDA – Deicing Fluid Reclamation Plant recycles propylene glycol from spent
aircraft deicing fluid. The spent deicing fluid comes from activities at the SLC
airport. The facility has not discharged into the POTW since 2014; however, it
has requested that the permit stay in effect. This ensures the facility has an active
permit in case a discharge needs to occur.
The facility developed a slug control plan, which was submitted on 3 November
2021. Based on the review, information was included for the requirements in 40
CFR 403.8 (f)(2)(vi)(A)-(C)v and met the file review requirements. The file also
included information regarding the review of the plan by SLC. The review
indicated that SLC found the plan to meet the permit requirements.
The facility has not discharged into the POTW since 2014, so the permittee and
SLC have not taken samples. The permittee has submitted letters indicating that
the facility is not discharging into the POTW, which included the certification
statement. Three letters and certification statements were reviewed; these met the
permit requirements for the reporting requirements. SLC noted no violations, and
none were found as part of the DWQ review of the file.
4.2.14. Sweet Candy Company
Sweet Candy Company manufactures and packages candy. The facility is being
permitted as an SIU.
The facility developed a slug control plan, which was submitted on 22 July 2021.
Based on the review, information was included for the requirements in 40 CFR
403.8 (f)(2)(vi)(A)-(C)v and met the file review requirements. Documentation
regarding the review by SLC was found in the file. The review indicated that
SLC found the plan to meet the permit requirements.
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DWQ reviewed four reports. SLC noted issues with the reports, which the
permittee addressed. The sample taken by SLC complied with the permit
requirements.
A sample was taken on 20 August 2021 for the POTW sample. The following
sample was taken on 11 August 2022.
4.2.15. Varex Imaging Corp
Varex Imaging Corp manufactures X-ray tubes, flat panel detectors and other
imaging components. It also conducts research, development, sales and servicing
for these devices. The facility has been permitted as a categorical Industrial User
covered by the standard found in 40 CFR 433.
The permittee submitted a spill plan. Based on the review, information was
included for the requirements in 40 CFR 403.8 (f)(2)(vi)(A)-(C)v and met the file
review requirements.
Reports were reviewed as part of the file review. One of the reports was submitted
late, and SLC sent a letter to the permittee regarding the late report. Information
was included in the file regarding the facility being in SNC and failing to report
a violation within 24 hours. The facility was published for SNC on 28 March
2023. No additional compliance issues were found as part of the review by DWQ.
4.2.16. Welfare Square Cannery
Welfare Square Cannery is a food processing plant. The facility is a cannery that
includes distribution to the Bishop’s Storehouse for the Church of Jesus Christ.
The facility is being permitted as an SIU.
The facility developed a slug control plan, which was submitted on 9 November
2021. Based on the review, information was included for the requirements in 40
CFR 403.8 (f)(2)(vi)(A)-(C)v and met the file review requirements.
Documentation regarding the review by SLC was found in the file. The review
indicated that SLC found the plan to meet the permit requirements.
Five reports were reviewed, with information being received per the requirements
of the permit. Notes were noted regarding a pH violation. The sample taken by
the Program complied with the permit requirements.
An inspection occurred on 9 September 2021. The following inspection was on
13 September 2022.
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5. SIU PERMITS
5.1. General Information
SLC has permitted 106 SIUs. Forty-eight SIUs are permitted as CIUs, and seventeen
have been permitted as zero-discharging SIUs.
SLC utilizes a permit as its control mechanism. Permits are issued to SIUs for a maximum
term of five years. However, most of the permits were issued for about 4.5 to 4 years, as
recommended in Section 16.2 of the SLC SOI PT-PER-01.
Section 16.2 suggests that new permittees be issued permits for one to two years. This
shortened permit cycle is suggested for permittees that might be subject to reduced
reporting requirements once sampling has been completed.
The SLC has procedures for permitting IUs, provided in SLC SOI PT-PER-01. The
methods include reviewing the application and ensuring it is complete. If the application
is incomplete, it is returned to the permittee with information regarding its deficiencies.
Note: Section 9.1 states the following:
If the Pretreatment Program finds that an IU meeting either of the first two
criteria described above has no reasonable potential for adversely affecting
the POTW's operation or for violating any Pretreatment Standard or
Requirement, the Pretreatment Program may, on its own initiative or in
response to a petition from an IU, determine that such User should NOT be
considered a Non- Categorical SIU and should NOT be required to apply
for and be issued with a Permit.
If this occurs, these SIUs should be noted on the list of industrial users meeting the
criteria in 40 CFR 403.3 (v)(1)xiv and indicate that the Program has decided per 40
CFR 403.3 (v)(2) or (3) that such IU should not be considered an SIU. The changes
to the IU from being classified as an SIU to an IU should be reported to DWQ as a
non-substantial modification.
Note: Section 9.2 states the following:
The inclusion of the streamlining regulations in 40 CFR 403 has increased
the required oversight of Categorical Industrial Users (CIUs) by
Pretreatment Programs. Prior to this inclusion, all CIUs subject to
Categorical Pretreatment Standards under 40 CFR 403.6 and 40 CFR
Chapter I Subchapter N were considered to be SIUs subject to permitting.
Under the new regulations, a Pretreatment Program must now recognize
three oversight scenarios for CIUs.
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This is not a requirement, and the Program does not have to oversee the three
scenarios for CIUs. These are options that SLC has decided to implement as part of
the Program.
Most of the changes to 40 CFR 403.6 did not increase the oversight of CIUs. EPA
provided flexibility for Programs to permit and regulate CIUs if the options met the
needs of the Program. The modification to 40 CFR 403.6 allows Programs to
choose some optional provisions previously not allowed for CIUs. However,
Programs do not have to implement these provisions if they feel the provision does
not meet the needs for permitting or regulating CIUs within the service area of the
Program. The provisions in 40 CFR 403.6 allow for additional flexibility for
implementing the Pretreatment Standards and Requirements for the CIUs. If SLC
feels this is a burden, the ordinance can be changed to remove these optional
provisions.
It is recommended that the wording “must” and “are not required” be changed to
“may” and “may not be required” regarding permitting NSCIUs or “Middle Tier”
CIUs.
Note: Section 16.5.4 states the following:
A TOMP may be approved by the City to exclude one, several or all 40
CFR-required parameters depending on the nature of the IU’s discharge). If
the IU discharges some TTO parameters, but does not discharge the
remaining TTO parameters required to be monitored, then the IU may
certify for those parameters not present in their discharge but cannot certify
for parameters present in the discharge (and must monitor and report for
these parameters). Once the TOMP is approved, the facility may limit the
TTOs for which they have to sample (or eliminate TTO monitoring
altogether) and must certify that they have operated in accordance with the
approved TOMP.
Guidance on implementing a BMP may not support the above information. When
implementing a BMP/TOMP/SMP, the plan is implemented, and sampling is no
longer required. However, the Program should continue to sample for the TTOs.
This is to ensure that the TOMP or SMP is being implemented. If the TTO being
sampled by the Program violates the limitation in the categorical standard, the
Program should evaluate the need to implement the TTO sampling or have the
permittee revise the TOMP or SMP. For more information regarding implementing
the TTO Pretreatment Standards, see the EPA Guidance Manual for Implementing
TTO Pretreatment Standards, September 1985.
Note: Section 16.5.5 states the following:
The minimum number of required aliquot samples used to make up a
composite sample should be included in the Permit. For composite
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sampling, the Pretreatment Program uses time-proportional composite
sampling techniques or a series of grab samples that are ultimately mixed
together to form the final composite (with the exception of Volatile
Organics and Total Oil and Grease, in which 40 CFR Part 136 requires
individual grab samples to be collected and the individual results analyzed
and then the results averaged and reported). The specific sampling method
required should be indicated for each pollutant in the Permit.
Sampling for grab or time-proportional compliance sampling techniques rather than
flow-proportional compliance sampling techniques must meet the requirements of
40 CFR 403.12 (g)(3)xv. The following is the information from 40 CFR 403.13
(g)(3) regarding these requirements:
…For all other pollutants, 24-hour composite samples must be obtained
through flow-proportional composite sampling techniques, unless time-
proportional composite sampling or grab sampling is authorized by the
Control Authority. Where time-proportional composite sampling or grab
sampling is authorized by the Control Authority, the samples must be
representative of the Discharge and the decision to allow the alternative
sampling must be documented in the Industrial User file for that facility or
facilities…
SLC must ensure that justification is included in the permit file indicating that the
method authorized for the sampling is representative of the discharge. This includes
the method SLC is using to collect the samples. For more information regarding
sampling, see the EPA Webinar, Sampling: Dos and Don’ts, on 27 January 2021.
5.2. Recommendations
Documentation regarding whether SLC implements the recommendation should be
available to DWQ for review during future inspections. If SLC does not implement
the recommendation, outreach may occur regarding the need to implement the
recommendation.
If a recommendation in this section results in a change to an SLC Program
Document, it should be submitted to the DWQ Pretreatment Coordinator within a
year.
5.2.1. The permitting procedure, SOI PT-PER-01, indicated the following:
By State of Utah policy, the Permit may have to be public noticed depending
upon the specific monitoring requirements.
By State of Utah Policy, the Permit may have to be Public Noticed if it
contains BMPs.
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DWQ has advised Programs that if requirements in the permit are not supported
by the legal authority, Local Limits or include additional requirements beyond
what DWQ and the governing body have approved for implementation by the
Program, then the permit should be public noticed. However, the Program must
determine whether documents that may deviate from those approved by DWQ
and the SLC Council for implementing the Program need to be public noticed.
If a BMP has not been public noticed or approved by the SLC Council or DWQ,
it is advised that the permit or document requiring a permittee to implement a
BMP be public noticed. This is to ensure the public, permittee, DWQ and other
interested parties have the opportunity to comment on the requirements.
If documents deviate from those approved by the SLC Council, it is
recommended that they be public notice. If this occurs, SLC should provide a
copy of the public notice to DWQ.
If a BMP is developed requiring IUs to meet requirements, it should be submitted
to DWQ during the public notice. This includes documents that will be
implemented as sector control programs not covered by the Program.
5.2.2. It is recommended that “sampling” be removed from the SOI PT-PER-01 zero-
discharge section on page 36 of 40. Instead, it should state “the alternative legal
method(s) of disposal of the process wastewater implemented by the industry.”
5.2.3. The SOI PT-PER-01 Section 19 stated “Water Reclamation Manger” rather than
“Water Reclamation Manager.” Because this is a typo, it does not need to be
submitted to DWQ per 40 CFR 403.18.
5.3. Recommendation
Documentation regarding whether SLC implements the recommendation should be
available to DWQ for review during future inspections. If SLC does not address the
recommendation, the information regarding the recommendation needing to be
addressed may be referred to the DWQ Compliance and Enforcement Section.
5.3.1. The application should include the priority pollutants list. The current permit
applications in Part 10 A.1 and 2. have information regarding the sampling
completed by the permittee based on the process or the data for the Local Limit
parameters. This limits the permittee to only those parameters listed. It is
recommended that the application be modified to require the permittee to note if
a parameter is present, suspected present or absent. This allows the permittee to
provide better information on the potential parameters of concern that may need
to be limited by the permit. See the EPA Industrial User Permitting Guidance
Manual 833-R-12-001 A September 2012 Appendix C Section F.
5.3.2. Section 22 of the SOI PT-PER-01 states the following:
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The Permittee does not need to complete the “BMR” portions of the Permit
Application/BMR form when completing the form as a part of Permit
renewal.
When renewing the permit, permittees should complete all of the information on
the application/BMR. This ensures the permit writer understands the parameters
of concern. The permittee should also provide information regarding the priority
pollutants and the monitoring that has occurred since the facility submitted the
last application. Also, the EPA Industrial User Permitting Guidance Manual,
September 2012, Sections 2.11 and 4.1, supports submitting a complete
application.
Also, the permittee should update this information with each permit renewal. The
current application in Part 10 A. states that this is for new permittees. The
permittees should provide this data with each renewal. This will ensure that
sampling information not previously submitted is provided to the Program in the
renewal application.
This recommendation should be implemented within 120 days of receiving this
report.
6. REPORTING and REPORT SUBMITTALS
6.1. General Information
Permittees submitted reports per the permit requirements. SLC reviews the reports to
ensure the information submitted is complete. If information was missing from the
report, the reviews provide detailed information, including the action taken to correct the
information.
6.2. Requirements
Documentation regarding whether SLC implements the recommendation should be
available to DWQ for review during future inspections. If SLC does not address the
recommendation, the information regarding the recommendation needing to be
addressed may be referred to the DWQ Compliance and Enforcement Section.
6.2.1. The Meadow Gold slug control plan was found without information regarding the
description of discharge into the POTW per 40 CFR 403.8 (f)(2)(vi)(A). The plan
included detailed information regarding the discharge from each facility area. The
Meadow Gold slug control plan should be reviewed if information is included in
the plan per 40 CFR 403.8 (f)(2)(vi)(A); no further requirement is necessary for
the recommendation. However, if information is not in the plan regarding
discharging into the POTW, Meadow Gold should be required to resubmit the
plan per the requirement of the SLC procedure regarding the resubmittal of slug
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control plans. This recommendation should be completed within 120 days of
receiving this report.
6.2.2. The Dominion Energy permit requires the permittee to have a slug control plan.
The permit should be modified to not require the plan or a plan must be submitted
per the permit requirements. This recommendation should be completed within
120 days of receiving this report.
7. MONITORING
7.1. General Information
SLC evaluates non-discharging facilities that are permitted as zero dischargers. This is
completed during inspections to ensure permittees are not discharging per the permit
requirements or the requirements of the categorical standard.
SLC has established protocols that include sampling procedures. All samples are
collected and analyzed in conformance with 40 CFR 136.
7.2. Recommendations
Documentation regarding whether SLC implements the recommendation should be
available to DWQ for review during future inspections. If SLC does not implement
the recommendation, outreach may occur regarding the need to implement the
recommendation.
If a recommendation in this section results in a change to the SLC Program
Document, it should be submitted to the DWQ Pretreatment Coordinator within a
year.
7.2.1. The following from SOI PT-INSP-01 Section 5.1 is an inaccurate statement:
Considering the USEPA and Utah Department of Water Quality (UDWQ)
monitor the number of permitted SIU’s in Significant Noncompliance
(SNC), and the City’s Pretreatment Program can be in regulatory
noncompliance if an excessive number (20 percent (%)) of permitted SIUs
are in SNC in any annual reporting year, the focus if each inspection should
be assessing user compliance with program requirements and educating the
IU/User of these requirements in an effort to prevent future violations.
SNC could occur for a Program if it does not adequately address SNC or public
notice an IU for SNC. Also, there is a criterion for failure to enforce standards,
local limits or reporting requirements. However, this is evaluated as the Program
failing to do this for 15% of the SNC SIUs and not for having 20% of the
permitted SIUs in SNC.
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DWQ is basing this not being an accurate statement per the criteria for SNC in
the EPA database known as ICIS (Integrated Compliance Information System).
If there is a document that SLC is aware of that supports the information cited in
the SOI PT-INSP-01, please provide the document to DWQ.
7.2.2. It is recommended that unannounced inspections be incorporated into the
program based on the Permit Writer’s understanding of the facility. SOI PT-
INSP-01 Section 5.2.2 states that the pretreatment program manager should
approve an unannounced inspection.
As stated in the EPA Industrial User Inspection and Sampling Manual for POTWs
Section 2.7.4:
…During unannounced inspections the inspector may have the opportunity
to observe things that the facility has not had the chance to clean up or hide
(e.g., improperly stored chemicals, inadequate treatment), and to observe
the facility operating under normal conditions. When determining
compliance with pretreatment standards during both announced and
unannounced inspections, the inspector must ensure that the industrial user
is operating under normal circumstances at the time of the on-site inspection
in order to ensure any samples taken will be representative.
7.2.3. It is recommended that the bullet point on page 9 of 20 of the SOI PT-INSP-01
include “POTW Staff and the public.” The following is the information from the
bullet point on page 9:
IPP Program and related Permit requirements are intended to minimize
IU’s discharge from impacting the City’s collection system, Reclamation
Plant Processes and City’s compliance with UPDES Permit.
7.3. Recommendations
Documentation regarding whether SLC implements the recommendation should be
available to DWQ for review during future inspections. If SLC does not address the
recommendation, the information regarding the recommendation needing to be
addressed may be referred to the DWQ Compliance and Enforcement Section.
7.3.1. Some facilities are allowed to sample using timed composite sampling
techniques. Little was found in the file regarding the justification for the timed
sampling. The permit states that a minimum of 12 aliquots should be taken for
the composite sample. It does not state the time between aliquots. Information in
the file must justify utilizing timed composite sampling techniques per 40 CFR
403.12 (g)(3).
SLC must ensure that justification is included in the permit file indicating that the
method authorized for the sampling is representative of the discharge. This
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includes the method SLC is using to collect the samples per the sampling Program
requirements, as well as the sampling being conducted by the permittee.
Additional aliquots are recommended to ensure that the sampling technique is
representative of the discharge. For more information regarding sampling, see the
EPA Webinar, Sampling: Dos and Don’ts, on 27 January 2021. In the webinar,
EPA stated that if the flow from the treatment system is in a steady state and timed
sampling is done with an aliquot taken every 15 minutes, it is consistent with
flow-proportional composite sampling.
7.3.2. Two facilities were not sampled within 365 days of the prior sampling event,
which must occur per the EPA requirements regarding yearly sampling. Based on
the review criteria, this was determined not to be SNC; however, SLC must
ensure that sampling events are completed within 365 days of the previous
sampling event.
8. INDUSTRIAL USER CHARACTERIZATION AND INSPECTIONS
8.1. General Information
The inspection reports that were reviewed were detailed. The reports provided
information on the pre-inspection, post-inspection and inspection information. The post-
inspection information included sending a letter to the facility regarding the observations
during the inspection and noting if any deficiencies needed to be addressed. If
deficiencies were noted, information was provided in the report indicating the time frame
for the permittee to address the issue.
8.2. Recommendations
Documentation regarding whether SLC implements these recommendations should
be available to DWQ for review during future inspections. If SLC does not
implement these recommendations, outreach may occur regarding the need to
implement the recommendation.
If a recommendation in this section results in a change to the SLC Program
Document, it should be submitted to the DWQ Pretreatment Coordinator within a
year.
The SOI PT-IWS does not include IUs that could potentially harm POTW workers. It is
recommended that another criterion be added to the list in section 4.2 D, which would be
“viii. The potential to discharge pollutants that could harm POTW workers or the public.”
8.3. Recommendations
Documentation regarding whether SLC implements the recommendation should be
available to DWQ for review during future inspections. If SLC does not address the
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recommendation, the information regarding the recommendation needing to be
addressed may be referred to the DWQ Compliance and Enforcement Section.
Two facilities of the sixteen files that were reviewed were determined not to meet the
EPA requirement that inspections be completed within 365 days of the previous
inspection. Based on the review criteria, this was determined not to be SNC; however,
SLC must ensure that inspections are completed within 365 days.
It is recommended that the inspection information that is reviewed for the upcoming
inspections is gathered a month in advance rather than the 3rd Thursday before the
upcoming month. The following is stated on page 3 of 4 in the SOI PT-INSP-02:
By the 3rd Thursday of the month, a monthly inspection list report shall be
generated in Linko for the next month should be created by the Pretreatment
Program Staff from review of the “Events” Module, considering the Department
expectation to complete the inspection two weeks prior to the regulatory
mandated date.
9. ENFORCEMENT
9.1. General Information
The files included details regarding the actions taken to resolve compliance issues. This
included notes, calls and written correspondence regarding compliance and enforcement
actions taken by SLC.
9.2. Recommendations
Documentation regarding whether SLC implements the recommendation should be
available to DWQ for review during future inspections. If SLC does not implement
the recommendation, outreach may occur regarding the need to implement the
recommendation.
If a recommendation in this section results in a change to the SLC Program
Document, it should be submitted to the DWQ Pretreatment Coordinator within a
year.
Based on a review of the SLC ERP, information regarding Pass Through or Interference
is not stated in the ERP section starting on page 20. It is recommended that information
be included in the ERP for Pass Through and Interference as separate enforcement
actions in the section starting on page 20 of the ERP. Pass Through is only being
addressed as part of a noncompliance action regarding bypass. Interference is not
included in this section of the ERP as a noncompliance action.
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10. DOCUMENT REVIEW
Documents reviewed for the Audit Document Information
UPDES Permit NA
Public Notice for Ordinance DWQ-2022-001579
Approval of the SLC Ordinance by DWQ DWQ-2022-004334
SLC ERP Sent by SLC via email
SOI PT-PER-01 Sent by SLC via email
SOI PT-INSP-01 Sent by SLC via email
SOI PT-INSP-02 Sent by SLC via email
SOI PT-IWS Sent by SLC via email
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11. SUMMARY
The Summary of Actions Table summarizes the requirements and recommendations in the 2023 Audit Report. SLC should use the table
as a reference when transmitting information to DWQ. This will assist SLC in ensuring that information is provided to DWQ per the
2023 Audit Report. If stated as NR, this information is not required to be submitted to DWQ; however, if any Program documents are
changed due to the recommendation, the information should be submitted to DWQ per 40 CFR 403.18.
Summary of Actions
Table
Section Summary of Recommendation Update Time
Frame Documentation for Review by was submitted to
Recommendation
3.7.1 Review legal authority 30 days 30 days Yes
3.7.2 Update legal authority 1 year 1 year Yes
Recommendation
5.3.1
Include the priority pollutants in the
application 120 days 120 days Yes
Recommendation
5.3.2
Ensure permittees complete all of
the information in the application,
including the priority pollutants in
the future.
120 days NR NR NR
Recommendation
6.2.1
Ensure slug control plans meet the
requirements of 40 CFR 403.8
(f)(2)(vi)
120 days NR NR NR
Recommendations
6.2.2
Update the permit or require a slug
control plan to be submitted. 120 days NR NR NR
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DWQ-2024-005741
Letter DWQ-2024-005740
LA Review DWQ-2024-005742
Summary of Actions
Table
Section Summary of Recommendation Update Time
Frame Documentation for Review by was submitted to
Recommendation
7.3.1
Review permit files to ensure
permits and documentation are
provided regarding sampling
requirements per 40 CFR 403.12
(g)(3).
1 year NR NR NR
Recommendation
7.3.2
Ensure sampling events do not
exceed 365 days 5 Days NR NR NR
Recommendation
8.3
Ensure inspections do not exceed
365 days 5 Days NR NR NR
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i 40 CFR 403.3 (d) The term Approved POTW Pretreatment Program or Program or POTW
Pretreatment Program means a program administered by a POTW that meets the criteria
established in this regulation (§§ 403.8 and 403.9) and which has been approved by a
Regional Administrator or State Director in accordance with § 403.11 of this regulation.
ii 40 CFR 403.8 (a) POTWs required to develop a pretreatment program. Any POTW (or
combination of POTWs operated by the same authority) with a total design flow greater
than 5 million gallons per day (mgd) and receiving from Industrial Users pollutants which
Pass Through or Interfere with the operation of the POTW or are otherwise subject to
Pretreatment Standards will be required to establish a POTW Pretreatment Program unless
the NPDES State exercises its option to assume local responsibilities as provided for in §
403.10(e). The Regional Administrator or Director may require that a POTW with a design
flow of 5 mgd or less develop a POTW Pretreatment Program if he or she finds that the
nature or volume of the industrial influent, treatment process upsets, violations of POTW
effluent limitations, contamination of municipal sludge, or other circumstances warrant in
order to prevent Interference with the POTW or Pass Through.
40 CFR 403.8 (f) POTW pretreatment requirements. A POTW pretreatment program must be
based on the following legal authority and include the following procedures. These
authorities and procedures shall at all times be fully and effectively exercised and
implemented.
iii 40 CFR 403.18 Modification of POTW pretreatment programs.
(a) General. Either the Approval Authority or a POTW with an approved POTW
Pretreatment Program may initiate program modification at any time to reflect changing
conditions at the POTW. Program modification is necessary whenever there is a significant
change in the operation of a POTW Pretreatment Program that differs from the information
in the POTW's submission, as approved under § 403.11.
(b) Substantial modifications defined. Substantial modifications include:
(1) Modifications that relax POTW legal authorities (as described in § 403.8(f)(1)), except
for modifications that directly reflect a revision to this part 403 or to 40 CFR chapter I,
subchapter N, and are reported pursuant to paragraph (d) of this section;
(2) Modifications that relax local limits, except for the modifications to local limits for pH
and reallocations of the Maximum Allowable Industrial Loading of a pollutant that do not
increase the total industrial loadings for the pollutant, which are reported pursuant to
paragraph (d) of this section. Maximum Allowable Industrial Loading means the total mass
of a pollutant that all Industrial Users of a POTW (or a subgroup of Industrial Users
identified by the POTW) may discharge pursuant to limits developed under § 403.5(c);
(3) Changes to the POTW's control mechanism, as described in § 403.8(f)(1)(iii);
(4) A decrease in the frequency of self-monitoring or reporting required of industrial users;
(5) A decrease in the frequency of industrial user inspections or sampling by the POTW;
(6) Changes to the POTW's confidentiality procedures; and
(7) Other modifications designated as substantial modifications by the Approval Authority
on the basis that the modification could have a significant impact on the operation of the
POTW's Pretreatment Program; could result in an increase in pollutant loadings at the
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POTW; or could result in less stringent requirements being imposed on Industrial Users of
the POTW.
(c) Approval procedures for substantial modifications.
(1) The POTW shall submit to the Approval Authority a statement of the basis for the
desired program modification, a modified program description (see § 403.9(b)), or such
other documents the Approval Authority determines to be necessary under the
circumstances.
(2) The Approval Authority shall approve or disapprove the modification based on the
requirements of § 403.8(f) and using the procedures in § 403.11(b) through (f), except as
provided in paragraphs (c) (3) and (4) of this section. The modification shall become
effective upon approval by the Approval Authority.
(3) The Approval Authority need not publish a notice of decision under § 403.11(e)
provided: The notice of request for approval under § 403.11(b)(1) states that the request
will be approved if no comments are received by a date specified in the notice; no
substantive comments are received; and the request is approved without change.
(4) Notices required by § 403.11 may be performed by the POTW provided that the
Approval Authority finds that the POTW notice otherwise satisfies the requirements of §
403.11.
(d) Approval procedures for non-substantial modifications.
(1) The POTW shall notify the Approval Authority of any non-substantial modification at
least 45 days prior to implementation by the POTW, in a statement similar to that provided
for in paragraph (c)(1) of this section.
(2) Within 45 days after the submission of the POTW's statement, the Approval Authority
shall notify the POTW of its decision to approve or disapprove the non-substantial
modification.
(3) If the Approval Authority does not notify the POTW within 45 days of its decision to
approve or deny the modification, or to treat the modification as substantial under
paragraph (b)(7) of this section, the POTW may implement the modification.
(e) Incorporation in permit. All modifications shall be incorporated into the POTW's
NPDES permit upon approval. The permit will be modified to incorporate the approved
modification in accordance with 40 CFR 122.63(g).
iv 40 CFR 403.8 (f)(1) Legal authority. The POTW shall operate pursuant to legal authority
enforceable in Federal, State or local courts, which authorizes or enables the POTW to
apply and to enforce the requirements of sections 307 (b) and (c), and 402(b)(8) of the Act
and any regulations implementing those sections. Such authority may be contained in a
statute, ordinance, or series of contracts or joint powers agreements which the POTW is
authorized to enact, enter into or implement, and which are authorized by State law. At a
minimum, this legal authority shall enable the POTW to:
(i) Deny or condition new or increased contributions of pollutants, or changes in the nature
of pollutants, to the POTW by Industrial Users where such contributions do not meet
applicable Pretreatment Standards and Requirements or where such contributions would
cause the POTW to violate its NPDES permit;
(ii) Require compliance with applicable Pretreatment Standards and Requirements by
Industrial Users;
(iii) Control through Permit, order, or similar means, the contribution to the POTW by each
Industrial User to ensure compliance with applicable Pretreatment Standards and
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Requirements. In the case of Industrial Users identified as significant under § 403.3(v), this
control shall be achieved through individual permits or equivalent individual control
mechanisms issued to each such User except as follows.
(A)
(1) At the discretion of the POTW, this control may include use of general control
mechanisms if the following conditions are met. All of the facilities to be covered must:
(i) Involve the same or substantially similar types of operations;
(ii) Discharge the same types of wastes;
(iii) Require the same effluent limitations;
(iv) Require the same or similar monitoring; and
(v) In the opinion of the POTW, are more appropriately controlled under a general control
mechanism than under individual control mechanisms.
(2) To be covered by the general control mechanism, the Significant Industrial User must
file a written request for coverage that identifies its contact information, production
processes, the types of wastes generated, the location for monitoring all wastes covered by
the general control mechanism, any requests in accordance with § 403.12(e)(2) for a
monitoring waiver for a pollutant neither present nor expected to be present in the
Discharge, and any other information the POTW deems appropriate. A monitoring waiver
for a pollutant neither present nor expected to be present in the Discharge is not effective
in the general control mechanism until after the POTW has provided written notice to the
Significant Industrial User that such a waiver request has been granted in accordance with
§ 403.12(e)(2). The POTW must retain a copy of the general control mechanism,
documentation to support the POTW's determination that a specific Significant Industrial
User meets the criteria in paragraphs (f)(1)(iii)(A)(1) through (5) of this section, and a copy
of the User's written request for coverage for 3 years after the expiration of the general
control mechanism. A POTW may not control a Significant Industrial User through a
general control mechanism where the facility is subject to production-based categorical
Pretreatment Standards or categorical Pretreatment Standards expressed as mass of
pollutant discharged per day or for Industrial Users whose limits are based on the
Combined Wastestream Formula or Net/Gross calculations (§§ 403.6(e) and 403.15).
(B) Both individual and general control mechanisms must be enforceable and contain, at a
minimum, the following conditions:
(1) Statement of duration (in no case more than five years);
(2) Statement of non-transferability without, at a minimum, prior notification to the POTW
and provision of a copy of the existing control mechanism to the new owner or operator;
(3) Effluent limits, including Best Management Practices, based on applicable general
Pretreatment Standards in part 403 of this chapter, categorical Pretreatment Standards,
Local Limits, and State and local law;
(4) Self-monitoring, sampling, reporting, notification and recordkeeping requirements,
including an identification of the pollutants to be monitored (including the process for
seeking a waiver for a pollutant neither present nor expected to be present in the Discharge
in accordance with § 403.12(e)(2), or a specific waived pollutant in the case of an
individual control mechanism), sampling location, sampling frequency, and sample type,
based on the applicable general Pretreatment Standards in part 403 of this chapter,
categorical Pretreatment Standards, Local Limits, and State and local law;
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(5) Statement of applicable civil and criminal penalties for violation of Pretreatment
Standards and requirements, and any applicable compliance schedule. Such schedules may
not extend the compliance date beyond applicable federal deadlines;
(6) Requirements to control Slug Discharges, if determined by the POTW to be necessary.
(iv) Require
(A) the development of a compliance schedule by each Industrial User for the installation
of technology required to meet applicable Pretreatment Standards and Requirements and
(B) the submission of all notices and self-monitoring reports from Industrial Users as are
necessary to assess and assure compliance by Industrial Users with Pretreatment Standards
and Requirements, including but not limited to the reports required in § 403.12.
(v) Carry out all inspection, surveillance and monitoring procedures necessary to
determine, independent of information supplied by Industrial Users, compliance or
noncompliance with applicable Pretreatment Standards and Requirements by Industrial
Users. Representatives of the POTW shall be authorized to enter any premises of any
Industrial User in which a Discharge source or treatment system is located or in which
records are required to be kept under § 403.12(o) to assure compliance with Pretreatment
Standards. Such authority shall be at least as extensive as the authority provided under
section 308 of the Act;
(vi)
(A) Obtain remedies for noncompliance by any Industrial User with any Pretreatment
Standard and Requirement. All POTW's shall be able to seek injunctive relief for
noncompliance by Industrial Users with Pretreatment Standards and Requirements. All
POTWs shall also have authority to seek or assess civil or criminal penalties in at least the
amount of $1,000 a day for each violation by Industrial Users of Pretreatment Standards
and Requirements.
(B) Pretreatment requirements which will be enforced through the remedies set forth in
paragraph (f)(1)(vi)(A) of this section, will include but not be limited to, the duty to allow
or carry out inspections, entry, or monitoring activities; any rules, regulations, or orders
issued by the POTW; any requirements set forth in control mechanisms issued by the
POTW; or any reporting requirements imposed by the POTW or these regulations in this
part. The POTW shall have authority and procedures (after informal notice to the
discharger) immediately and effectively to halt or prevent any discharge of pollutants to
the POTW which reasonably appears to present an imminent endangerment to the health
or welfare of persons. The POTW shall also have authority and procedures (which shall
include notice to the affected industrial users and an opportunity to respond) to halt or
prevent any discharge to the POTW which presents or may present an endangerment to the
environment or which threatens to interfere with the operation of the POTW. The Approval
Authority shall have authority to seek judicial relief and may also use administrative
penalty authority when the POTW has sought a monetary penalty which the Approval
Authority believes to be insufficient.
(vii) Comply with the confidentiality requirements set forth in § 403.14.
v 40 CFR 403.8 (f)(2) Procedures.
The POTW shall develop and implement procedures to ensure compliance with the
requirements of a Pretreatment Program. At a minimum, these procedures shall enable the
POTW to:
36 of 42
(i) Identify and locate all possible Industrial Users which might be subject to the POTW
Pretreatment Program. Any compilation, index or inventory of Industrial Users made under
this paragraph shall be made available to the Regional Administrator or Director upon
request;
(ii) Identify the character and volume of pollutants contributed to the POTW by the
Industrial Users identified under paragraph (f)(2)(i) of this section. This information shall
be made available to the Regional Administrator or Director upon request;
(iii) Notify Industrial Users identified under paragraph (f)(2)(i) of this section, of applicable
Pretreatment Standards and any applicable requirements under sections 204(b) and 405 of
the Act and subtitles C and D of the Resource Conservation and Recovery Act. Within 30
days of approval pursuant to 40 CFR 403.8(f)(6), of a list of significant industrial users,
notify each significant industrial user of its status as such and of all requirements applicable
to it as a result of such status.
(iv) Receive and analyze self-monitoring reports and other notices submitted by Industrial
Users in accordance with the self-monitoring requirements in § 403.12;
(v) Randomly sample and analyze the effluent from Industrial Users and conduct
surveillance activities in order to identify, independent of information supplied by
Industrial Users, occasional and continuing noncompliance with Pretreatment Standards.
Inspect and sample the effluent from each Significant Industrial User at least once a year,
except as otherwise specified below:
(A) Where the POTW has authorized the Industrial User subject to a categorical
Pretreatment Standard to forego sampling of a pollutant regulated by a categorical
Pretreatment Standard in accordance with § 403.12(e)(3), the POTW must sample for the
waived pollutant(s) at least once during the term of the Categorical Industrial User's control
mechanism. In the event that the POTW subsequently determines that a waived pollutant
is present or is expected to be present in the Industrial User's wastewater based on changes
that occur in the User's operations, the POTW must immediately begin at least annual
effluent monitoring of the User's Discharge and inspection.
(B) Where the POTW has determined that an Industrial User meets the criteria for
classification as a Non-Significant Categorical Industrial User, the POTW must evaluate,
at least once per year, whether an Industrial User continues to meet the criteria in §
403.3(v)(2).
(C) In the case of Industrial Users subject to reduced reporting requirements under §
403.12(e)(3), the POTW must randomly sample and analyze the effluent from Industrial
Users and conduct inspections at least once every two years. If the Industrial User no longer
meets the conditions for reduced reporting in § 403.12(e)(3), the POTW must immediately
begin sampling and inspecting the Industrial User at least once a year.
(vi) Evaluate whether each such Significant Industrial User needs a plan or other action to
control Slug Discharges. For Industrial Users identified as significant prior to November
14, 2005, this evaluation must have been conducted at least once by October 14, 2006;
additional Significant Industrial Users must be evaluated within 1 year of being designated
a Significant Industrial User. For purposes of this subsection, a Slug Discharge is any
Discharge of a non-routine, episodic nature, including but not limited to an accidental spill
or a non-customary batch Discharge, which has a reasonable potential to cause Interference
or Pass Through, or in any other way violate the POTW's regulations, Local Limits or
Permit conditions. The results of such activities shall be available to the Approval
37 of 42
Authority upon request. Significant Industrial Users are required to notify the POTW
immediately of any changes at its facility affecting potential for a Slug Discharge. If the
POTW decides that a slug control plan is needed, the plan shall contain, at a minimum, the
following elements:
(A) Description of discharge practices, including non-routine batch Discharges;
(B) Description of stored chemicals;
(C) Procedures for immediately notifying the POTW of Slug Discharges, including any
Discharge that would violate a prohibition under § 403.5(b) with procedures for follow-up
written notification within five days;
(D) If necessary, procedures to prevent adverse impact from accidental spills, including
inspection and maintenance of storage areas, handling and transfer of materials, loading
and unloading operations, control of plant site run-off, worker training, building of
containment structures or equipment, measures for containing toxic organic pollutants
(including solvents), and/or measures and equipment for emergency response;
(vii) Investigate instances of noncompliance with Pretreatment Standards and
Requirements, as indicated in the reports and notices required under § 403.12, or indicated
by analysis, inspection, and surveillance activities described in paragraph (f)(2)(v) of this
section. Sample taking and analysis and the collection of other information shall be
performed with sufficient care to produce evidence admissible in enforcement proceedings
or in judicial actions; and
(viii) Comply with the public participation requirements of 40 CFR part 25 in the
enforcement of National Pretreatment Standards. These procedures shall include provision
for at least annual public notification in a newspaper(s) of general circulation that provides
meaningful public notice within the jurisdiction(s) served by the POTW of Industrial Users
which, at any time during the previous 12 months, were in significant noncompliance with
applicable Pretreatment requirements. For the purposes of this provision, a Significant
Industrial User (or any Industrial User which violates paragraphs (f)(2)(viii)(C), (D), or
(H) of this section) is in significant noncompliance if its violation meets one or more of the
following criteria:
(A) Chronic violations of wastewater Discharge limits, defined here as those in which 66
percent or more of all of the measurements taken for the same pollutant parameter during
a 6-month period exceed (by any magnitude) a numeric Pretreatment Standard or
Requirement, including instantaneous limits, as defined by 40 CFR 403.3(l);
(B) Technical Review Criteria (TRC) violations, defined here as those in which 33 percent
or more of all of the measurements taken for the same pollutant parameter during a 6-month
period equal or exceed the product of the numeric Pretreatment Standard or Requirement
including instantaneous limits, as defined by 40 CFR 403.3(l) multiplied by the applicable
TRC (TRC = 1.4 for BOD, TSS, fats, oil, and grease, and 1.2 for all other pollutants except
pH);
(C) Any other violation of a Pretreatment Standard or Requirement as defined by 40 CFR
403.3(l) (daily maximum, long-term average, instantaneous limit, or narrative Standard)
that the POTW determines has caused, alone or in combination with other Discharges,
Interference or Pass Through (including endangering the health of POTW personnel or the
general public);
38 of 42
(D) Any discharge of a pollutant that has caused imminent endangerment to human health,
welfare or to the environment or has resulted in the POTW's exercise of its emergency
authority under paragraph (f)(1)(vi)(B) of this section to halt or prevent such a discharge;
(E) Failure to meet, within 90 days after the schedule date, a compliance schedule
milestone contained in a local control mechanism or enforcement order for starting
construction, completing construction, or attaining final compliance;
(F) Failure to provide, within 45 days after the due date, required reports such as baseline
monitoring reports, 90-day compliance reports, periodic self-monitoring reports, and
reports on compliance with compliance schedules;
(G) Failure to accurately report noncompliance;
(H) Any other violation or group of violations, which may include a violation of Best
Management Practices, which the POTW determines will adversely affect the operation or
implementation of the local Pretreatment program.
vi 40 CFR 403.8 (f)(5) The POTW shall develop and implement an enforcement response plan.
This plan shall contain detailed procedures indicating how a POTW will investigate and
respond to instances of industrial user noncompliance. The plan shall, at a minimum:
(i) Describe how the POTW will investigate instances of noncompliance;
(ii) Describe the types of escalating enforcement responses the POTW will take in response
to all anticipated types of industrial user violations and the time periods within which
responses will take place;
(iii) Identify (by title) the official(s) responsible for each type of response;
(iv) Adequately reflect the POTW's primary responsibility to enforce all applicable
pretreatment requirements and standards, as detailed in 40 CFR 403.8 (f)(1) and (f)(2).
vii 40 CFR 403.8 (f)(6) The POTW shall prepare and maintain a list of its Industrial Users meeting
the criteria in § 403.3(v)(1). The list shall identify the criteria in § 403.3(v)(1) applicable
to each Industrial User and, where applicable, shall also indicate whether the POTW has
made a determination pursuant to § 403.3(v)(2) that such Industrial User should not be
considered a Significant Industrial User. The initial list shall be submitted to the Approval
Authority pursuant to § 403.9 or as a non-substantial modification pursuant to § 403.18(d).
Modifications to the list shall be submitted to the Approval Authority pursuant to §
403.12(i)(1).
viii 40 CFR 403.8(f)(3) Funding.
The POTW shall have sufficient resources and qualified personnel to carry out the
authorities and procedures described in paragraphs (f) (1) and (2) of this section. In some
limited circumstances, funding and personnel may be delayed where
(i) the POTW has adequate legal authority and procedures to carry out the Pretreatment
Program requirements described in this section, and
(ii) a limited aspect of the Program does not need to be implemented immediately (see §
403.9(b)).
ix 40 CFR 403.8 (f)(4) Local Limits. The POTW shall develop Local Limits as required in §
403.5(c)(1), or demonstrate that they are not necessary.
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x 40 CFR 403.3 (e)
The term Best Management Practices or BMPs means schedules of activities, prohibitions
of practices, maintenance procedures, and other management practices to implement the
prohibitions listed in § 403.5(a)(1) and (b). BMPs also include treatment requirements,
operating procedures, and practices to control plant site runoff, spillage or leaks, sludge or
waste disposal, or drainage from raw materials storage.
40 CFR 403.5(c)(4)
POTWs may develop Best Management Practices (BMPs) to implement paragraphs (c)(1)
and (c)(2) of this section. Such BMPs shall be considered local limits and Pretreatment
Standards for the purposes of this part and section 307(d) of the Act.
xi 40 CFR 403.3 (v)(3)
Upon a finding that an Industrial User meeting the criteria in paragraph (v)(1)(ii) of this
section has no reasonable potential for adversely affecting the POTW's operation or for
violating any Pretreatment Standards or requirement, the Control Authority may at any
time, on its own initiative or in response to a petition received from an Industrial User or
POTW, and in accordance with 40 CFR 403.8(f)(6), determine that such Industrial User is
not a Significant Industrial User.
40 CFR 403.8 (f)(6)
The POTW shall prepare and maintain a list of its Industrial Users meeting the criteria in
§ 403.3(v)(1). The list shall identify the criteria in § 403.3(v)(1) applicable to each
Industrial User and, where applicable, shall also indicate whether the POTW has made a
determination pursuant to § 403.3(v)(2) that such Industrial User should not be considered
a Significant Industrial User. The initial list shall be submitted to the Approval Authority
pursuant to § 403.9 or as a non-substantial modification pursuant to § 403.18(d).
Modifications to the list shall be submitted to the Approval Authority pursuant to §
403.12(i)(1).
xii 403.16 Upset provision.
(a) Definition. For the purposes of this section, Upset means an exceptional incident in
which there is unintentional and temporary noncompliance with categorical Pretreatment
Standards because of factors beyond the reasonable control of the Industrial User. An Upset
does not include noncompliance to the extent caused by operational error, improperly
designed treatment facilities, inadequate treatment facilities, lack of preventive
maintenance, or careless or improper operation.
(b) Effect of an upset. An Upset shall constitute an affirmative defense to an action brought
for noncompliance with categorical Pretreatment Standards if the requirements of
paragraph (c) are met.
(c) Conditions necessary for a demonstration of upset. An Industrial User who wishes to
establish the affirmative defense of Upset shall demonstrate, through properly signed,
contemporaneous operating logs, or other relevant evidence that:
(1) An Upset occurred and the Industrial User can identify the cause(s) of the Upset;
(2) The facility was at the time being operated in a prudent and workman-like manner and
in compliance with applicable operation and maintenance procedures;
40 of 42
(3) The Industrial User has submitted the following information to the POTW and Control
Authority within 24 hours of becoming aware of the Upset (if this information is provided
orally, a written submission must be provided within five days):
(i) A description of the Indirect Discharge and cause of noncompliance;
(ii) The period of noncompliance, including exact dates and times or, if not corrected, the
anticipated time the noncompliance is expected to continue;
(iii) Steps being taken and/or planned to reduce, eliminate and prevent recurrence of the
noncompliance.
(d) Burden of proof. In any enforcement proceeding the Industrial User seeking to establish
the occurrence of an Upset shall have the burden of proof.
(e) Reviewability of agency consideration of claims of upset. In the usual exercise of
prosecutorial discretion, Agency enforcement personnel should review any claims that
non-compliance was caused by an Upset. No determinations made in the course of the
review constitute final Agency action subject to judicial review. Industrial Users will have
the opportunity for a judicial determination on any claim of Upset only in an enforcement
action brought for noncompliance with categorical Pretreatment Standards.
(f) User responsibility in case of upset. The Industrial User shall control production or all
Discharges to the extent necessary to maintain compliance with categorical Pretreatment
Standards upon reduction, loss, or failure of its treatment facility until the facility is
restored or an alternative method of treatment is provided. This requirement applies in the
situation where, among other things, the primary source of power of the treatment facility
is reduced, lost or fails.
xiii § 403.17 Bypass.
(a) Definitions.
(1) Bypass means the intentional diversion of wastestreams from any portion of an
Industrial User's treatment facility.
(2) Severe property damage means substantial physical damage to property, damage to the
treatment facilities which causes them to become inoperable, or substantial and permanent
loss of natural resources which can reasonably be expected to occur in the absence of a
bypass. Severe property damage does not mean economic loss caused by delays in
production.
(b) Bypass not violating applicable Pretreatment Standards or Requirements. An Industrial
User may allow any bypass to occur which does not cause Pretreatment Standards or
Requirements to be violated, but only if it also is for essential maintenance to assure
efficient operation. These bypasses are not subject to the provision of paragraphs (c) and
(d) of this section.
(c) Notice.
(1) If an Industrial User knows in advance of the need for a bypass, it shall submit prior
notice to the Control Authority, if possible at least ten days before the date of the bypass.
(2) An Industrial User shall submit oral notice of an unanticipated bypass that exceeds
applicable Pretreatment Standards to the Control Authority within 24 hours from the time
the Industrial User becomes aware of the bypass. A written submission shall also be
provided within 5 days of the time the Industrial User becomes aware of the bypass. The
written submission shall contain a description of the bypass and its cause; the duration of
the bypass, including exact dates and times, and, if the bypass has not been corrected, the
41 of 42
anticipated time it is expected to continue; and steps taken or planned to reduce, eliminate,
and prevent reoccurrence of the bypass. The Control Authority may waive the written
report on a case-by-case basis if the oral report has been received within 24 hours.
(d) Prohibition of bypass.
(1) Bypass is prohibited, and the Control Authority may take enforcement action against
an Industrial User for a bypass, unless;
(i) Bypass was unavoidable to prevent loss of life, personal injury, or severe property
damage;
(ii) There were no feasible alternatives to the bypass, such as the use of auxiliary treatment
facilities, retention of untreated wastes, or maintenance during normal periods of
equipment downtime. This condition is not satisfied if adequate back-up equipment should
have been installed in the exercise of reasonable engineering judgment to prevent a bypass
which occurred during normal periods of equipment downtime or preventative
maintenance; and
(iii) The Industrial User submitted notices as required under paragraph (c) of this section.
(2) The Control Authority may approve an anticipated bypass, after considering its adverse
effects, if the Control Authority determines that it will meet the three conditions listed in
paragraph (d)(1) of this section.
xiv 40 CFR 403.3 (v)(1) Except as provided in paragraphs (v)(2) and (v)(3) of this section, the
term Significant Industrial User means:
(i) All Industrial Users subject to Categorical Pretreatment Standards under 40 CFR
403.6 and 40 CFR chapter I, subchapter N; and
(ii) Any other Industrial User that: discharges an average of 25,000 gallons per day or
more of process wastewater to the POTW (excluding sanitary, noncontact cooling and
boiler blowdown wastewater); contributes a process wastestream which makes up 5
percent or more of the average dry weather hydraulic or organic capacity of the POTW
Treatment plant; or is designated as such by the Control Authority on the basis that the
Industrial User has a reasonable potential for adversely affecting the POTW's operation
or for violating any Pretreatment Standard or requirement (in accordance with 40 CFR
403.8(f)(6)).
xv 40 CFR 403.12 (g)(3) The reports required in paragraphs (b), (d), (e) and (h) of this section must
be based upon data obtained through appropriate sampling and analysis performed during
the period covered by the report, which data are representative of conditions occurring
during the reporting period. The Control Authority shall require that frequency of
monitoring necessary to assess and assure compliance by Industrial Users with applicable
Pretreatment Standards and Requirements. Grab samples must be used for pH, cyanide,
total phenols, oil and grease, sulfide, and volatile organic compounds. For all other
pollutants, 24-hour composite samples must be obtained through flow-proportional
composite sampling techniques, unless time-proportional composite sampling or grab
sampling is authorized by the Control Authority. Where time-proportional composite
sampling or grab sampling is authorized by the Control Authority, the samples must be
representative of the Discharge and the decision to allow the alternative sampling must be
documented in the Industrial User file for that facility or facilities. Using protocols
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(including appropriate preservation) specified in 40 CFR part 136 and appropriate EPA
guidance, multiple grab samples collected during a 24-hour period may be composited
prior to the analysis as follows: For cyanide, total phenols, and sulfides the samples may
be composited in the laboratory or in the field; for volatile organics and oil & grease the
samples may be composited in the laboratory. Composite samples for other parameters
unaffected by the compositing procedures as documented in approved EPA methodologies
may be authorized by the Control Authority, as appropriate.
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1
SLCWRF RESPONSES TO THE DWQ 2023 PRETREATMENT PROGRAM LEGAL AUTHORITY REVIEW
The information below provides a summary of the Utah Division of Water Quality (DWQ) required or requested updated to the Salt Lake City Wastewater Control and Sewer System Ordinances (City Code) and the Salt Lake City Water Reclamation Facility (SLCWRF) responses and/or requirements. Note, Section 3.7.1 and the Summary of Actions Table in the 2024 DWQ issued Pretreatment Audit Report provides for the submittal of proposed updates to the DWQ within 30 days and updates completion within one year. The response were revised on 11/18/2024, after discussion with DWQ about the required revisions.
NONE = No revision necessary REQ = Require Revision REC = Recommend Revision
Part 403 Citation
EPA Model Sewer Use Ordinance (SUO) Section
POTW Ordinance DWQ Comments / Notes SLCWRF Response to DWQ Comments / Notes
NONE REQ REC A. Definitions [403.3 & 403.8(f)(2)]
X 17.32.080
X 17.32.090
be add from the MSUO “BMPs shall be considered local limits and Pretreatment Standards for the purposes of this [ordinance] and Section 307(d) of the Act, 40 CFR 403.5(c)(4) and R317-8-8”
SUO and 40 Code of Federal Regulations (CFR) 403.3(e) and R317-8.2(3). Moreover, Ordinance 17.36.090.E generally matches the wording in 40 CFR 403.5(c)(4) and R317-8.5(7), stating that BMPs may be developed to implement local limits and the requirements of the Ordinance. No changes made.
X 17.32.130
X 17.32.370 information being included in 17.36.060 both the EPA model SUO and the Region 8 example ordinance. Both of these example documents include a reference to 40 CFR
Pretreatment Standard or Standard X 17.32.490 ordinance rather than 403 403.3(l), the EPA model SUO, the Region 8 example ordinance, and R317-8-8.2(8). The SCLWRF is currently reviewing the recommendation and the specific wording used in the Ordinance and are in active dialogue with internal City stakeholders If a revision to the Ordinance is justified the proposed modification
shall be submitted to DWQ.
17.32.500
17.32.410
17.32.430
2
Part 403 Citation
EPA Model Sewer Use Ordinance (SUO) Section
POTW Ordinance DWQ Comments / Notes SLCWRF Response to DWQ Comments / Notes
NONE REQ REC
17.32.470
17.32.480
17.32.520
[NOTE: §1.4 GG(3) is an optional streamlining
provision for Non-Significant Categorical
403.3(v) § 1.4 KK X
17.32.570
403.8(f)(2)(viii )(A)-(H)
information in 40 CFR refers to the Pretreatment Standard and not information regarding instantaneous limits.
403.8(f)(2)(viii)(A-H) and/or the EPA model SUO. The DWQ requirement to reference Section 2 in the EPA SUO is not appropriate with respect to the Ordinance organization and references. The SLCWRF and DWQ discussed this requirement on 11/15/2024, and agreed that a revision to the Ordinance is not required.
403.8(f)(2)(vi)
Part 403 Citation
EPA Model Sewer Use Ordinance (SUO)
Ordinance Section
DWQ Comments / Notes SLCWRF Response to DWQ Comments / Notes NONE REQ REC
23. Waters of the State § 1.4 SS
X 17.32.730
thereof, except that bodies of
water confined to and retained within the limits of private
property, and which do not develop into or constitute a nuisance, or a public health hazard, or a menace to fish and wildlife, shall not be considered to be "waters of the state" under
model SUO provided by DWQ could not be located.
No change was made.
3
Compatible Pollutant https://www.
owp.csus.edu /glossary/co
mpatible- pollutants.php
X 17.32.180 normally removed by the POTW treatment system. Biochemical
oxygen demand (BOD), suspended solids (SS), and
ammonia are considered compatible pollutants.”
program offered by Sacramento State College of Engineering. The program has strict academic honesty and copyright rules.
Use of this DWQ recommended definition would likely violate said copyright. Moreover, the use of a definition not provided or
referenced by EPA or other regulatory agencies could be open to scrutiny and less defensible.
No change was made.
owp.csus.edu /glossary/poll utant.php
impairment (reduction) of water
quality to a degree that has an adverse effect on any beneficial
use of the water. Pollutants may include dredged spoil, solid
waste, incinerator residue, sewage, garbage, sewage sludge, munitions, chemical wastes, biological materials, radioactive materials, heat, wrecked or discarded equipment, rock, sand, cellar dirt, and industrial, municipal, and agricultural
401.11(f), the EPA model SUO, and R317-8-1.5(35). Moreover,
the website cited or referenced by DWQ is a wastewater training program offered by Sacramento State College of Engineering.
The program has strict academic honesty and copyright rules. Use of this DWQ recommended definition would likely violate
said copyright. The use of a definition not provided or referenced by EPA or other regulatory agency could be open to scrutiny and less defensible. No change was made.
Part 403 Citation
EPA Model Sewer Use Ordinance
POTW Ordinance Section DWQ Comments / Notes SLCWRF Response to DWQ Comments / Notes
Pollution https://www. owp.csus.edu /glossary/poll ution.php
X 17.32.460
water quality by agricultural, domestic, or industrial wastes (including thermal and radioactive wastes) to a degree that the natural water quality is changed to hinder any beneficial use of the water or render it offensive to the senses of sight, taste, or smell or when sufficient amounts of wastes create or pose a potential threat to human health or the environment.”
generally that in R317-8-1.5(36). Moreover, the website cited or referenced by DWQ is a wastewater training program offered by Sacramento State College of Engineering. The program has strict academic honesty and copyright rules. Use of this DWQ recommended definition would likely violate said copyright. The use of a definition not provided or referenced by EPA or other regulatory agency could be open to scrutiny and less defensible. No change was made.
4
Sewage https://www.o wp.csus.edu/gl ossary/sewage. php X 17.32.550
water-carried solids that flow in wastewater collection systems to
a wastewater treatment plant. The preferred term is
wastewater.”
the Clean Water Act, and the EPA model SUO. Moreover, the website cited or referenced by DWQ is a wastewater training
program offered by Sacramento State College of Engineering. The program has strict academic honesty and copyright rules.
Use of this DWQ recommended definition would likely violate said copyright. The use of a definition not provided or referenced
by EPA or other regulatory agency could be open to scrutiny and less defensible.
No change was made.
owp.csus.edu /glossary/tox
ic- pollutant.php
combinations of pollutants, including disease-causing
agents, that cause death, disease, behavioral abnormalities, cancer, genetic mutations, physiological malfunctions (including malfunctions in reproduction), or physical deformations.”
1(56). Moreover, the website cited or referenced by DWQ is a wastewater training program offered by Sacramento State College
of Engineering. The program has strict academic honesty and copyright rules. Use of this DWQ recommended definition would
likely violate said copyright. The use of a definition not provided or referenced by EPA or other regulatory agency could be open to
scrutiny and less defensible.
5
Part 403 Citation
EPA Model Sewer Use Ordinance
REVISIONS
POTW Ordinance Section DWQ Comments / Notes SLCWRF Response to DWQ Comments / Notes
NONE REQ REC
Wastewater discharge permits are issued to those industrial users who meet the definition of SIU as provided in Ordinance 17.32.570.
X 17.32.620 groundwater or treated groundwater allowed by an UPDES General Permit” rather
specific wording used in the Ordinance and are in active dialogue with internal City stakeholders If a revision to the Ordinance is justified the proposed modification shall be submitted to DWQ.
owp.csus.edu /glossary/vis
cosity.php
A property of water, or any other fluid, that resists efforts to change its shape or flow.
program offered by Sacramento State College of Engineering. The program has strict academic honesty and copyright rules. Use of this DWQ recommended definition would likely violate said copyright. Moreover, the use of a definition not provided or referenced by EPA or other regulatory agency could be open to
NONE = No revision necessary REQ = Require Revision REC = Recommend Revision
Part 403 Model SUO POTW Ordinance DWQ Comments / Notes SLCWRF Response to DWQ Comments / Notes NONE REQ REC
B. National Pretreatment Standards – Prohibited Discharges
X 17.36.060 B.2
X 17.36.060 B.6.a
X 17.36.060 B.12
X 17.36.060 B.14
[NOTE: POTWs may develop Best Management Practices (BMPs) to implement the prohibitions listed in 40 CFR 403.5(a)(1). Such BMPs shall be
403.5(c) & (d) § 2.4
X 17.36.090
X 17.36.110
[NOTE: Optional streamlining provision.] X 17.36.090E
X 17.52.160 A.2.c
NONE = No revision necessary REQ = Require Revision REC = Recommend Revision
Part 403 Citation
Model SUO REVISIONS POTW Ordinance DWQ Comments / Notes SLCWRF Response to DWQ Comments / Notes
NONE REQ REC C. Control Discharges to POTW System
1. Deny/Condition New or Increased Contributions
X 17.36.100
“The director will evaluate the data furnished by the IU SIU and may require additional information. Within one hundred twenty (120) days of receipt of a complete permit application, the director will determine whether to issue a wastewater discharge permit. The director may conditionally approve or deny any application for a wastewater discharge permit.”
X 17.52.080 B.10 however a timeframe is stated
to ensure compliance Permit Content X 17.52.010 Adding “if required” to 17.52.010 A. see MSUO The wording in Ordinance 17.52.010.A 4.2 of the EPA model SUO. No change made.
(1)
X 17.52.080A.2
X 17.52.080A.3
[Note: This is a required streamlining provision for CIUs with BMP requirements as part of its Categorical Standards. But if BMPs are being
applied to other CIUs or noncategorical SIUs without categorical BMP requirements, then this provision would be optional and is only required if
the POTW has incorporated the use of BMPs (§ 2.4
403.8(f)(1)(B) (3)
X 17.52.080A.3
Pollutants Not Present or Expected to be Present
[NOTE: Optional streamlining provision. Required only if the POTW has incorporated §
403.8(f)(1)(B) (4) & 403.12(e) (2)
NONE = No revision necessary REQ = Require Revision REC = Recommend Revision
Part 403 SUO Ordinance DWQ Comments / Notes SLCWRF Response to DWQ Comments / Notes NONE REQ REC
Criminal Penalties
403.8(f)(1)(B) (5)
necessary) [NOTE: Required streamlining change. Where the POTW has determined that slug
controls are necessary, the ordinance must provide authority for the POTW to include
such requirements in IU
403.8(f)(1)(B) (6)
X 17.52.080A.7
[NOTE: Optional streamlining provision. Required only if the POTW has incorporated §
403.8(f)(1)(B) (4) X 17.52.080A.8
Requirements
[Note: Optional permit provision]
X 17.52.090
17.52.030A
[Note: Optional permit provision] § 5.4 X 17.52.100 No change made
[Note: Optional permit provision]
NONE = No revision necessary REQ = Require Revision REC = Recommend Revision
Part 403 SUO Ordinance DWQ Comments / Notes SLCWRF Response to DWQ Comments / Notes NONE REQ REC
[Note: Optional permit provision]X 17.36.120
[Note: Optional permit provision] X 17.68.070
forms with monitoring data [Note: Optional permit provision]
X 17.52.200
Control Plan A)-(D) X 17.36.150 States that the director may
develop a slug plan.
compliance
[NOTE: Optional streamlining provision. Required only if the POTW has incorporated the use of General Permits (§ 4.6 of the Model SUO).] - Permit Content
403.8(f)(1)(iii) (A)
This option is not included
(1)
[Note: This is a required streamlining provision for CIUs with BMP requirements as part of its Categorical Standards. But if BMPs are being applied to other CIUs or noncategorical SIUs without categorical BMP requirements, then this provision would be optional and is only required if
the POTW has incorporated the use of BMPs (§
403.8(f)(1)(B) (3)
f. Reporting & Notification Requirements
g. Recordkeeping Requirements
h. Process for Seeking a Waiver for Pollutants Not Present or Expected to be
Present [Note: Required only if POTW has
incorporated the use of Pollutants Not Present
403.8(f)(1)(B) (4) & 403.12(e) (2)
Model SUO.] i. Statement of Applicable Civil and Criminal Penalties
403.8(f)(1)(B) (5) § 5.2A(7)
NONE = No revision necessary REQ = Require Revision REC = Recommend Revision
Part 403 Citation SUO Section Ordinance Section
DWQ Comments / SLCWRF Response to DWQ Comments / Notes NONE REQ REC
c. Effluent Limits 403.8(f)(1)(B) § 5.2A(3)
(3)
d. Best Management Practices
[Note: This is a required streamlining provision for CIUs with BMP requirements as part of its Categorical Standards. But if BMPs are being applied to other CIUs or noncategorical SIUs
without categorical BMP requirements, then this provision would be optional and is only required if the POTW has incorporated the use of BMPs (§
403.8(f)(1)(B) (3)
This option is not included
Pollutants Not Present or Expected to be (4) & 403.12(e) (2)
[Note: Required only if POTW has incorporated
the use of Pollutants Not Present and § 6.4 of the Model SUO.]
(5)
NONE = No revision necessary REQ = Require Revision REC = Recommend Revision
Part 403 SUO Ordinance
DWQ Comments / Notes SLCWRF Response to DWQ Comments / Notes NONE REQ REC
necessary) [NOTE: Required streamlining change. The ordinance should indicate that a user is required to develop a slug discharge control plan if
403.8(f)(1)(B) (6)
This option is not included No change made
Requirements [Note: Optional permit provision]
[Note: Optional permit provision]
[Note: Optional permit provision]
§ 5.6
§ 10.8
n. Proper Operation and Maintenance § 3.1
o. Duty of Halt/Reduce § 10.7
p. Requirement to submit Chain-of-Custody forms with monitoring data
[Note: Optional permit provision]
q. Accidental Discharge/Slug Discharge Control Plan
403.8(f)(2)(vi)( A)-(D)
D. Required Reports
of technology
No change made
NONE = No revision necessary REQ = Require Revision REC = Recommend Revision
Part 403 SUO Ordinance DWQ Comments / Notes SLCWRF Response to DWQ Comments / Notes NONE REQ REC
Types of Reports
X 17.52.030A.1. “authorized representative duly authorized” in 17.52.030 A.1.b The name of an authorized representative or duly authorized to act on .”
X 17.52.030A.3
X 17.52.160A.1
X 17.52.160B compliance proposal is beyond
X 17.52.160C
X 17.52.160D.1
X 17.52.160F
NONE = No revision necessary REQ = Require Revision REC = Recommend Revision
Part 403 SUO Ordinance Comments / Notes SLCWRF Response to DWQ Comments / Notes
f. Notification of changes affecting potential for a slug discharge [NOTE: Required streamlining revision]
403.8(f)(2)(vi) § 6.5 X 17.52.160E regarding slug discharge. Ordinance 17.52.160.F describes Reports of Potential Problems and includes provisions for slug discharge reporting and is consistent with
X 17.52.160F.4
[NOTE: Required streamlining revision.] X 17.52.160H
X 17.52.160D.5
403.8(f)(2)(iii) X 17.52.160I
Other Reporting Requirements
& 403.12(l)
longer) X 17.52.200 Five years No change made
with Best Management Practices [NOTE: Required streamlining provision.]
X 17.52.200
[NOTE: Required streamlining revision] X 17.52.160D.6
categorical Industrial Users
[Note: Optional provision, required only if the POTW has incorporated §1.4GG(3) of the Model SUO.]
403.3(v)(2) § 4.7C X 17.52.050C No change made
§ 6.14B X 17.52.210B during the reporting period never discharged untreated concentrated wastewater”
-significant CIUs. The certification statement wording .12(q) and Section 6.14B of the EPA SUO. references 40 CFR
criteria for a determination that a facility is a -significant CIU and not directly relevant to the certification statement
Therefore, the SLCWRF respectfully requests DWQ
The SLCWRF and DWQ discussed this requirement on 11/15/2024 and
agreed that a revision to the Ordinance is not required.
NONE = No revision necessary REQ = Require Revision REC = Recommend Revision
Part 403 SUO Ordinance Comments / Notes SLCWRF Response to DWQ Comments / Notes NONE REQ REC
[NOTE: Optional provision, required only if the POTW has incorporated § 6.4 B of the Model
403.12(e)(2)(v) § 6.14C
X 17.52.210C
E. Test Procedures [40 CFR Part 136 & 403.12(g)]
[NOTE: Required streamlining provisions]
403.12(g) § 6.10 X 17.52.170
[NOTE: Required streamlining provisions] X 17.52.180
monitoring
F. Inspection and Monitoring Procedures [403.8(f)]
X 17.52.230
403.8(f)(2)(v) & X 17.52.220
X 17.52.220
G. Remedies for Non-compliance (Enforcement) [403.8(f)(1)(vi)]
X 17.68.100
NONE = No revision necessary REQ = Require Revision REC = Recommend Revision
Part 403 SUO Ordinance DWQ Comments / Notes SLCWRF Response to DWQ Comments / Notes NONE REQ REC
(B) X 17.68.070
X 17.68.170
H. Public Participation
Noncompliance [NOTE: Required streamlining revision] X 17.52.260
I. Optional Provisions
[streamlining provision]
[streamlining provision] X 17.36.070D
[streamlining provision] X 17.36.070E
[streamlining provision] X 17.52.160D.2
[streamlining provision] X 17.52.160D.3
(excluding wavier of National Categorical
NONE = No revision necessary REQ = Require Revision REC = Recommend Revision
Part 403 SUO Ordinance DWQ Comments / Notes SLCWRF Response to DWQ Comments / Notes NONE REQ REC
X 17.68.010
X 17.68.040
X 17.68.110
as noted in the POTW’s enforcement 17.68.120 to 160
J. Other Provisions
“The POTW shall be supervised and directed by the director, or their duly .”
2. 414,419,455 X 17.36.070 E
17.52.040
5. Accidental discharge to slug discharge X 17.52.080 B.4 slug discharge plans and the management/prevention of accidental, unanticipated, or nonroutine discharges into the sewer system (i.e., slug loads). Ordinance 17.52.080.A.7. details the requirements to control slug discharges. Holistically these two provisions, and others, allow for and slug discharges. Therefore, the SLCWRF respectfully requests DWQ reevaluate this “required” change.
The SLCWRF and DWQ discussed this requirement on 11/15/2024 and agreed that a revision to the Ordinance is not required.
6. Date of Receipt of reports § 6.12 X 17.52.190
allowed by Region VIII and being implemented by DWQ,
which is utilizing the air quality rule regarding receiving
payment. Use the language in the MSUO
Written reports that are mailed through a mail facility serviced by the
For written reports that are shipped using
If a postmark or pick up/ship date is not
For reports, which United
NONE = No revision necessary REQ = Require Revision REC = Recommend Revision
n.”
DWQ-2024-005742 DWQ-2024-005740 Letter DWQ-2024-005741 Audit Report
This page has intentionally been left blank
SALT LAKE CITY ORDINANCE
No. ______ of 2025
(Amending Salt Lake City Code Chapter 17 regarding Salt Lake City’s Water System,
Wastewater Control and Sewer System, and Stormwater Sewer System)
An ordinance adopting new Sections 17.16.655, 17.32.061, and 17.32.451; repealing
Section 17.16.345; and amending Sections 17.16.020, 17.16.100, 17.16.220, 17.16.345,
17.16.400, 17.16.670, 17.16.685, 17.16.790, 17.32.650, 17.36.010, 17.52.030, 17.52.060,
17.52.190, 17.64.030, 17.72.030, and 17.81.200.
WHEREAS, Salt Lake City Department of Public Utilities completed a Water, Sewer,
and Stormwater Rate Study in 2024; and
WHEREAS, the 2024 Water, Sewer, and Stormwater Rate Study recommends changes to
the structure of water, sewer, and stormwater rates to meet the objectives of revenue sufficiency,
fairness and equity, economic efficiency, sustainability and predictability, clarity, cost allocation,
and affordability; and
WHEREAS, the Salt Lake City Consolidated Fee Schedule is proposed to be amended to
incorporate new water, sewer, and stormwater structures in coordination with the approval of the
Public Utilities’ Fiscal Year 2025-2026 budget; and
WHEREAS, Salt Lake City Department of Public Utilities underwent a Public Utilities
Pretreatment Program Legal Authority Audit in 2023 conducted by the Utah Department of
Water Quality; and
WHEREAS, the Department of Water Quality requires changes to Salt Lake City Code
Chapter 17 to comply with findings in the 2023 Pretreatment Program Legal Authority Audit;
and
WHEREAS, it is now proposed that Salt Lake City Code Chapter 17, Public Services be
amended to modify certain language to implement rate changes identified in the 2024 Water,
Sewer, and Stormwater Rate Study; and to implement changes identified in the 2023 Salt Lake
City Department of Public Utilities Pretreatment Program Legal Authority Audit; and
WHEREAS, the City Council finds (i) these amendments to Salt Lake City Code Chapter
17 are necessary and reasonable to implement new water, sewer, and stormwater rates; and (ii) the
City Council finds the amendments to Salt Lake City Code Chapter 17 are necessary and reasonable
to comply with regulatory requirements imposed by Department of Water Quality; and (iii)
adoption of this ordinance reasonably furthers the welfare of the citizens of Salt Lake City.
WHEREAS, the City Council of Salt Lake City, Utah, desires to adopt new Sections
17.16.655, 17.32.061, and 17.32.451; repeal Section 17.16.345; and amend Sections 17.16.020,
17.16.100, 17.16.220, 17.16.400, 17.16.670, 17.16.685, 17.16.790, 17.32.650, 17.36.010,
17.52.030, 17.52.060, 17.52.190, 17.64.030, 17.72.030, and 17.81.200.
NOW, THEREFORE, be it ordained by the City Council of Salt Lake City, Utah:
SECTION 1. Amending the text of Salt Lake City Code Chapter 17.16 Article IX. That
Chapter 17.16 Article IX of the Salt Lake City Code (Culinary Water System: Rates and
Payments) shall be, and hereby is, amended to adopt a new Section 17.16.655, which shall read
as follows:
17.16.655: ABATEMENTS:
Customers who qualify for a property tax abatement may qualify for a water, sewer, and/or
stormwater fee abatement pursuant to the city’s consolidated fee schedule.
SECTION 2. Amending the text of Salt Lake City Code Chapter 17.32 Article II. That
Chapter 17.32 Article II of the Salt Lake City Code (General Provisions and Definitions:
Definitions) shall be, and hereby is, amended to adopt a new Section 17.32.061, which shall read
as follows:
17.32.061: AMMONIA (NH3)
“Ammonia (NH3)” means nitrogen in the form of free ammonia and ionic ammonium measured
using methods set forth in 40 CFR 136 or its successor.
SECTION 3. Amending the text of Salt Lake City Code Chapter 17.32 Article II. That
Chapter 17.32 Article II of the Salt Lake City Code (General Provisions and Definitions:
Definitions) shall be, and hereby is, amended to adopt a new Section 17.32.451, which shall read
as follows:
17.32.451: Total Phosphorus (TP)
“Total Phosphorus (TP)” means all forms of phosphorus (orthophosphate, condensed phosphate,
or organic phosphorus) measured using methods set forth in 40 CFR 136 or its successor.
SECTION 4. Repealing Salt Lake City Code Section 17.16.345. That Section 17.16.345
of the Salt Lake City Code (Lot Hydrant; Fee) shall be, and hereby is, repealed in its entirety.
SECTION 5. Amending Section 17.16.020. That Section 17.16.020 of the Salt Lake City
Code (Application; Contents), shall be, and hereby is, amended to read as follows:
17.16.020: APPLICATION; CONTENTS:
The applicant shall state fully and truly the purpose for which water is required, the anticipated
daily water use, and shall agree to conform to and be governed by such ordinances, rules and
regulations as may be prescribed by the city for the control of the water supply. The applicant(s)
agrees to be responsible for and pay all bills due the city on account of costs incurred to provide
services.
SECTION 6. Amending Section 17.16.100. That Section 17.16.100 of the Salt Lake City
Code (Connections from Mains; Specifications) shall be, and hereby is, amended to read as
follows:
17.16.100: CONNECTIONS FROM MAINS; SPECIFICATIONS:
The service pipes and connections from the main to the water meter, including the meter box, a
meter yoke and valve are to be placed within the parking strip by a licensed, bonded plumber, to
city standards, and subject to city inspection and approval. In the absence of a parking strip,
service pipes and connections are to be placed in the public right of way or private right of way
as determined by the director. The meter shall be accessible to the department and remain
unobstructed at all times. The city shall install, and applicant will pay the city's costs of such
installation when so determined by the director. The plumber shall warrant the work and
facilities installed by him/her against defects in workmanship or materials for a period of one
year from date of acceptance thereof by the city.
SECTION 7. Amending Section 17.16.220. That Section 17.16.220 of the Salt Lake City
Code (Responsibility for Costs of Service) shall be, and hereby is, amended to add a new
subsection to read as follows:
17.16.220: RESPONSIBILITY FOR COSTS OF SERVICE:
A. Before water will be supplied through such service pipe, some person(s) must agree in
writing to be responsible for and pay for all water delivered through the service meter.
B. Where water is now supplied through one service to one or more houses or persons, the
public utilities director may, in his/her discretion, either refuse to furnish water until separate
services are provided, or may continue the supply, on condition that one person shall be
responsible for and pay for all water delivered through the service meter.
C. Where water is now supplied for culinary and outdoor irrigation uses, the director may, in
his/her discretion, require the installation of separate meters to account for culinary water use
separately from outdoor irrigation use.
SECTION 8. Amending Section 17.16.400. That Section 17.16.400 of the Salt Lake City
Code (Meter Maintenance Charges) shall be, and hereby is, amended to read as follows:
17.16.400: METER MAINTENANCE CHARGES:
A. After the one year guarantee of the plumber or if the city makes the installation, the city
shall maintain all water connections of three-fourths inch (3/4") and one inch (1") sizes within
the city, or as otherwise determined by written contract, fro m the point of connection with the
water main up to and including the meter, where the meter is set in the parking strip, or in the
absence of a parking strip, in the public right of way or private right of way as determined by the
director. The meter shall be accessible to the department and remain unobstructed at all times .
B. All maintenance and replacement, where necessary, on all service lines and meters above
one inch (1") in size, is to be kept at the entire expense of the consumer.
SECTION 9. Amending Section 17.16.670. That Section 17.16.670 of the Salt Lake City
Code (Minimum Charges) shall be, and hereby is, amended to read as follows:
17.16.670: MINIMUM CHARGES:
Each customer shall pay the following minimum fixed charge shown on the Salt Lake City
consolidated fee schedule, effective for all meter readings during the periods from and including
July 1, 2011, and thereafter until further amended, to cover costs incurred to provide service.
SECTION 10. Amending Section 17.16.685. That Section 17.16.685 of the Salt Lake
City Code (Urban Vegetable Garden Adjustment Program) shall be, and hereby is, amended to
read as follows:
17.16.685: URBAN VEGETABLE GARDEN ADJUSTMENT PROGRAM:
Customers who occupy property with a vegetable garden of a size between 0.10 and 0.25 of an
acre are eligible to request an adjustment related to additional allocation of water in block 2 for
the months of April through October in support of the city's loc al food production initiative. The
additional block 2 water allocation is based on 17.22 Ccf per month for each 0.1 acre of
vegetable garden between 0.1 acre and 0.25 acre. Water used in excess of the adjusted block 2
allocation will be billed at block 3 and/or block 4 rates. Applications for an urban vegetable
garden adjustment, which includes an additional block 2 water allocation, are made through the
city’s department of public utilities.
SECTION 11. Amending Section 17.16.790. That Section 17.16.790 of the Salt Lake
City Code (Delinquent Payment; Penalty) shall be, and hereby is, amended to read as follows:
17.16.790: DELINQUENT PAYMENT; PENALTY:
In case of vacancy, where service is discontinued or meter taken out, unless delinquent bills are
paid within thirty (30) days after the service has been discontinued, a penalty of ten percent
(10%) may be charged in addition to the regular bill.
SECTION 12. Amending Section 17.32.650. That Section 17.32.650 of the Salt Lake
City Code (Total Suspended Solids or Suspended Solids) shall be, and hereby is, amended to
read as follows:
17.32.650: TOTAL SUSPENDED SOLIDS (TSS) OR SUSPENDED SOLIDS (SS):
"Total suspended solids" or "suspended solids" means the total suspended matter that floats on
the surface of or is suspended in water, wastewater or other liquids, and which is removable by
laboratory filtering in accordance with methods set forth in 40 CFR 136 or its successor.
SECTION 13. Amending Section 17.36.010. That Section 17.36.010 of the Salt Lake
City Code (Supervision of POTW) shall be, and hereby is, amended to read as follows:
17.36.010: SUPERVISION OF POTW:
The POTW shall be supervised and directed by the director or his or her designee.
SECTION 14. Amending Section 17.52.030. That Section 17.52.030 of the Salt Lake
City Code (Permit; Application Contents) shall be, and hereby is, amended to read as follows:
17.52.030: PERMIT; APPLICATION CONTENTS:
A. Users required to obtain a wastewater discharge permit shall complete and file with the
POTW an application in the form prescribed by the POTW, accompanied by a fee as set forth in
section 17.52.270 of this chapter. In support of the application, the user shall submit, in units and
terms appropriate for evaluation, some or all of the following information:
1. Identifying Information:
a. Name, address, telephone number and location (if different from the address) of
applicant and owner of the premises (if different from the tenant when property is leased) from
which industrial wastes are intended to be discharged,
b. The name of an authorized or duly authorized representative to act on behalf of the
facility,
c. Description of activities, facilities, and plant production processes on the premises.
SECTION 15. Amending Section 17.52.060. That Section 17.52.060 of the Salt Lake
City Code (Permit; Decisions) shall be, and hereby is , amended to read as follows:
17.52.060: PERMIT; DECISIONS:
A. Incomplete or inaccurate applications will not be processed and will be returned to the user
for revision.
B. The director will evaluate the data furnished by the IU and may require additional
information. Within one hundred twenty (120) days of receipt of a complete permit application,
the director will determine whether to issue a wastewater discharge permit. The director may
conditionally approve or deny any application for a wastewater discharge permit.
SECTION 16. Amending Section 17.52.190. That Section 17.52.190 of the Salt Lake
City Code (Date of Receipt of Reports), shall be, and hereby is, amended to read as follows:
17.52.190: DATE OF RECEIPT OF REPORTS:
For written reports that are mailed through a mail facility serviced by the United States postal
service, such reports will be deemed to have been submitted on the date postmarked. If a
postmark or pick up/ship date is not available, the date of receipt of the report shall govern. For
reports, which are not mailed, postage prepaid, into a mail facility serviced by the United States
Postal Service, the date of receipt of the report shall govern.
SECTION 17. Amending Section 17.64.030. That Section 17.64.030 of the Salt Lake
City Code (Classification of Users) shall be, and hereby is, amended to read as follows:
17.64.030: CLASSIFICATION OF USERS:
The users of the POTW may be divided into various classifications, including, but not limited to,
single dwelling units, duplexes, multiple dwelling units, and nonresidential. Further
classifications may be established by the POTW for each user class.
SECTION 18. Amending Section 17.72.030. That Section 17.72.030 of the Salt Lake
City Code (Schedule 1; Rates and Fees) shall be, and hereby is, amended to read as follows:
17.72.030: SCHEDULE 1; RATES AND FEES:
A. Purpose: For the purpose of defraying the cost of construction, reconstruction,
maintenance and operation of the city sewer system, there are hereby imposed the charges shown
on the Salt Lake City consolidated fee schedule upon all persons and premises receiving sewer
collection and treatment services.
B. Definitions:
AVERAGE WINTER CONSUMPTION: The average monthly water usage for residential
customers for the consecutive months of December, January, and February, which is the basis for
residential sewer billings for the twelve (12)-month period beginning July 1 immediately
following such months.
CUSTOMER CLASS: The classification or classifications applicable to each customer of the
sewer system for purposes of calculating such customer's service charge under this chapter .
DUPLEX: A single building containing two (2) independent dwelling units.
DWELLING UNIT: A building or other structure or portion thereof, in which: 1) an individual
resides as a separate housekeeping unit, or 2) a collective body of persons (doing their own
cooking) resides as a separate housekeeping unit in a domestic bond bas ed upon birth, marriage,
domestic employment or other family relationship, as distinguished from a boarding house,
lodging house, club, fraternity, motel or hotel.
MONITORED CUSTOMER: Non-residential customers, designated by the director, subject to
routine sample measurements of the customer’s wastewater flow and or discharge characteristics.
MULTI-FAMILY RESIDENTIAL: Any building or other structure having four (4) or more
residential dwelling units therein, including a mobile home park.
NON-RESIDENTIAL: Buildings used for uses other than residential purposes.
RESIDENTIAL: Buildings or dwelling units used to house people or persons for residential
purposes, including single dwelling units, duplexes, and triplexes, and excluding multi -family
residential structures or buildings.
SERVICE CHARGE: The charge for sewer collection and treatment services levied on all users
of the public sewer system, as calculated pursuant to this chapter.
SERVICE TO MULTIPLE BUILDINGS: Sewer service to multiple buildings shall be governed
the same as section 17.16.200 of this title.
SINGLE DWELLING UNIT: A building containing one dwelling unit.
TRIPLEX: A single building containing three (3) independent dwelling units.
UNMONITORED CUSTOMER: Any non-residential customer not designated as monitored.
C. Sewer Charges:
1. a. Each residential sewer customer shall be charged a monthly service charge equal to the
fixed monthly charge together with the flow rate of average winter consumption as shown on the
Salt Lake City consolidated fee schedule.
b. Each monitored non-residential customer shall be charged a monthly service charge
equal to the fixed monthly charge together with the monitored wastewater flow measured during
the billing period as shown on the Salt Lake City consolidated fee schedule. The charges for
wastewater pollutants shall be billed as shown on the Salt Lake City consolidated fee schedule.
c. Each unmonitored non-residential customer and each multi-family residential customer
shall be charged a monthly service charge equal to the monthly service charge together with the
flow rate per the Salt Lake City consolidated fee schedule. The monthly water meter reading for
sewer billing purposes shall be equal to 70 percent (70%) of total water usage for the month.
d. In cases where little or no water is used during one or more of the winter months, such
that the average metered usage during such winter months cannot be reasonably assumed to
reflect typical monthly usage for an account, the director may use other co nsumptive information
specific to such account to determine the average winter consumption.
e. Meter readings for sewer billing purposes shall only include meters which measure
water entering the sewer system.
f. In the case of sewer users whose water usage is based in whole or in part on water
sources other than the city, the city may require installation of a city approved meter, at the
sewer user's expense, on the well(s) or other sources of water supply, fo r measurement by the
city during the winter months to determine the sewer user's water use during the winter months.
g. For each single-family dwelling sewer user using water other than city water and
desiring not to install a water meter as provided above, the director may waive the meter
requirement, in which event the user will be charged for sewer service as provided in subsection
E of this section.
D. Metering Of Sewage Flows:
1. Meters will be allowed in sewer lines when the user is permitted or required by the
director to have the sewage flow subject to the following requirements:
a. The charges for sewer service will be based upon the actual sewer meter readings rather
than average winter consumption or adjusted water meter readings.
b. The user will furnish, install, and maintain at user's expense a meter pursuant to the
city's standards and specifications.
E. New Sewer Accounts:
1. For new residential sewer accounts, until the data required by subsection C1a of this
section is available, the monthly sewer rates shall be based on the average winter consumption
for comparative users.
a. For monitored and unmonitored non-residential customers, new accounts shall be
treated in the same manner as established accounts under subsections C1b and C1c, respectively,
of this section.
F. Service Charge Adjustment:
1. The director may provide for adjustments as needed to ensure equitable service charges.
Such adjustments may be made where excessive quantities of culinary water pass through the
water meter but are consumed on the premises and do not enter the sewer system. In each such
instance, the user will have the burden of providing evidence of such inequities by showing that
the quantity of water not entering the sewer, but passing through the meter, exceeds thirty
percent (30%) of the total flow in order to merit such consideration by the director. Each such
adjustment proposed to be made by the director shall first be presented to the public utilities
advisory committee for review and recommendation, following which review and
recommendation the director shall make a final determination.
2. Additionally, the director may make adjustments under the following conditions due to
faulty inside plumbing. All adjustments will be determined by prior usage. When the charge is
not based on preceding usage and has not been established on average winter consumption, the
charge will be determined as outlined in this section or its successor. Only one adjustment in
total is allowed per account and under the following conditions:
a. When defective plumbing has caused the average winter water consumption to exceed
the previous year's average by twenty-five percent (25%) or more, there may be an adjustment
made based on prior usage. The customer must provide to the director evidence that plumbing
repairs were made within thirty (30) days of issuance of the bill in which the defective plumbing
caused an increase in usage. Such evidence may be in the form of a statement detailing the
repairs made and the date of completion. The adjustment shall be made following the
determination by the director that the repairs have resulted in decreased water consumption.
b. In the event of a customer's unexplainable large increase in water consumption during
the consecutive months of December, January, and February, the director may make adjustments
to any account when there has been a twenty-five percent (25%) increase or more in usage
during the winter months. Any adjustment may be made only after an in-depth review of the
account has been completed and based solely on the merits of each individual request and the
circumstances surrounding the request.
c. All adjustments will be determined by the sewer usage of the preceding year. When the
usage for the preceding year is not established on average winter consumption, the charge will be
determined by other consumptive data or comparative users.
G. Sewer Service Fees: The director shall charge, and the city shall collect the fees shown on
the Salt Lake City consolidated fee schedule.
1. Special industrial and commercial uses, including car washes, laundromats, etc., as
determined by the city's public utilities director, shall be charged the fee shown on the Salt Lake
City consolidated fee schedule per equivalent fixture unit, as specified in the uniform plumbing
code.
2. Connection fees on property with prior development:
a. When a residential building is demolished and the existing lateral is used for the same
property, there is no new sewer connection fee for the property when residential use or building
type is same as prior to demolition. After five (5) years from date of demolition no credit will be
given for prior sewer connection fees. After five (5) years from demolition the property owner
will be required to pay all connection fees.
b. When a commercial building such as a hotel, motel, industrial building, etc., is
demolished the sewer fee shall be based and charged on new additional use pursuant to the
applicable fee shown on the Salt Lake City consolidated fee schedule. A fter five (5) years from
date of demolition no credit will be given for prior sewer connection fees. After five (5) years
from demolition the property owner will be required to pay all connection fees required by the
city.
3. Temporary sewer connections may only be made by approval of the director. Temporary
connections cannot exceed twenty four (24) months. The fee for each temporary connection shall
be shown on the Salt Lake City consolidated fee schedule. All other applicable fees will be
effective for temporary connections.
4. All other fees necessary for the operations, maintenance, and services provided by the
Wastewater Control and Sewer System and shown on the Salt Lake City consolidated fee
schedule.
SECTION 19. Amending Section 17.81.200. That Section 17.81.200 of the Salt Lake
City Code (System of Rates and Charges) shall be, and hereby is, amended to read as follows:
17.81.200: SYSTEM OF RATES AND CHARGES:
A. Generally: There are hereby imposed stormwater sewer service fees, rates and charges,
effective for all billing periods after and including July 1, 2011, and thereafter until further
amended, on the owner of each developed parcel within the city, except: 1) governmentally
owned streets, and 2) parcels on which are located stormwater sewer facilities operated and
maintained by, or for, the county. The charges shall fund the administration, planning, design,
construction, water quality programming, operation, maintenance and repair of existing and
future stormwater sewer facilities.
B. Residential Service Charges: Residential service charges for use of the stormwater sewer
system shall be as shown on the Salt Lake City consolidated fee schedule.
C. Undeveloped Parcels: Undeveloped parcels shall not be assessed a stormwater service
charge.
D. Other Parcels: The charge for all other parcels shall be based upon the total square footage
of measured impervious surface, divided by two thousand five hundred (2,500) square feet, or
one ERU, and rounded to the nearest whole number. The actual total monthly service charge
shall be computed by multiplying the total ERUs for a parcel by the monthly rate shown on the
Salt Lake City consolidated fee schedule.
E. Credit For On Parcel Mitigation: Nonresidential parcels with on-site stormwater detention
or retention facilities are eligible for a service charge credit upon application to the director by
the person owning the parcel, or such person's agent. The amount of credit, if any, shall be no
more than twenty-five percent (25%) of the full stormwater charge per the Salt Lake City
consolidated fee schedule, except entities that are individually permitted under the Utah Water
Quality Act and federal Clean Water Act.
1. Mitigation credit is available only for those non-residential parcels whose stormwater
facilities meet the city's design and maintenance standards.
2. If the stormwater facilities are not properly maintained or if related structures are
modified from an approved design, the mitigation credit may be modified or terminated by the
city.
3. The director shall provide a complete on-site mitigation evaluation at the request and
expense of the person owning the parcel, or the owner's duly authorized agent.
F. Low-Income Abatement: A person who owns a single-family residential parcel and is
qualified for an abatement of the minimum monthly water charge pursuant to
section 17.16.670 of this title shall be eligible for a fifty percent (50%) reduction of the service
charge for such parcel.
G. Nonservice Abatement: A parcel which is not directly or indirectly benefited by the
stormwater sewer utility shall be entitled to an abatement of the service charge for said parcel. In
order to receive such abatement, the owner, or the owner's agent, shall apply, in writing, to the
director pursuant to section 17.81.500 of this chapter.
SECTION 20. That a copy of the amended Salt Lake Code shall be published on the
official Salt Lake City website.
SECTION 21. That this ordinance shall become effective July 1, 2025.
Passed by the City Council of Salt Lake City, Utah, this _____ day of __________, 2025.
________________________
CHAIRPERSON
ATTEST:
______________________________
CITY RECORDER
Transmitted to the Mayor on __________________
Mayor’s Action: ____ Approved ____ Vetoed
_________________________
MAYOR
ATTEST:
_______________________________
CITY RECORDER
(SEAL)
Bill No. _________ of 2025.
Published: ___________________
Salt Lake City Attorney’s Office
Approved As To Form
/s/ Carly Castle
Carly Castle
Senior City Attorney
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SALT LAKE CITY ORDINANCE
No. ______ of 2025
(Amending Salt Lake City Code Chapter 17 regarding Salt Lake City’s Water System,
Wastewater Control and Sewer System, and Stormwater Sewer System)
An ordinance adopting new Sections 17.16.655, 17.32.061, and 17.32.451; repealing
Section 17.16.345; and amending Sections 17.16.020, 17.16.100, 17.16.220, 17.16.345,
17.16.400, 17.16.670, 17.16.685, 17.16.790, 17.32.650, 17.36.010, 17.52.030, 17.52.060,
17.52.190, 17.64.030, 17.72.030, and 17.81.200.
WHEREAS, Salt Lake City Department of Public Utilities completed a Water, Sewer,
and Stormwater Rate Study in 2024; and
WHEREAS, the 2024 Water, Sewer, and Stormwater Rate Study recommends changes to
the structure of water, sewer, and stormwater rates to meet the objectives of revenue sufficiency,
fairness and equity, economic efficiency, sustainability and predictability, clarity, cost allocation,
and affordability; and
WHEREAS, the Salt Lake City Consolidated Fee Schedule is proposed to be amended to
incorporate new water, sewer, and stormwater structures in coordination with the approval of the
Public Utilities’ Fiscal Year 2025-2026 budget; and
WHEREAS, Salt Lake City Department of Public Utilities underwent a Public Utilities
Pretreatment Program Legal Authority Audit in 2023 conducted by the Utah Department of
Water Quality; and
WHEREAS, the Department of Water Quality requires changes to Salt Lake City Code
Chapter 17 to comply with findings in the 2023 Pretreatment Program Legal Authority Audit;
and
WHEREAS, it is now proposed that Salt Lake City Code Chapter 17, Public Services be
amended to modify certain language to implement rate changes identified in the 2024 Water,
Sewer, and Stormwater Rate Study ; and to implement changes identified in the 2023 Salt Lake
City Department of Public Utilities Pretreatment Program Legal Authority Audit; and
WHEREAS, the City Council finds (i) these amendments to Salt Lake City Code Chapter
17 are necessary and reasonable to implement new water, sewer, and stormwater rates; and (ii) the
City Council finds the amendments to Salt Lake City Code Chapter 17 are necessary and reasonable
to comply with regulatory requirements imposed by Department of Water Quality; and (iii)
adoption of this ordinance reasonably furthers the welfare of the citizens of Salt Lake City.
WHEREAS, the City Council of Salt Lake City, Utah, desires to adopt new Sections
17.16.655, 17.32.061, and 17.32.451; repeal Section 17.16.345; and amend Sections 17.16.020,
17.16.100, 17.16.220, 17.16.400, 17.16.670, 17.16.685, 17.16.790, 17.32.650, 17.36.010,
17.52.030, 17.52.060, 17.52.190, 17.64.030, 17.72.030, and 17.81.200.
NOW, THEREFORE, be it ordained by the City Council of Salt Lake City, Utah:
SECTION 1. Amending the text of Salt Lake City Code Chapter 17.16 Article IX. That
Chapter 17.16 Article IX of the Salt Lake City Code (Culinary Water System: Rates and
Payments) shall be, and hereby is, amended to adopt a new Section 17.16.655, which shall read
as follows:
17.16.655: ABATEMENTS:
Customers who qualify for a property tax abatement may qualify for a water, sewer, and/or
stormwater fee abatement pursuant to the city’s consolidated fee schedule.
SECTION 2. Amending the text of Salt Lake City Code Chapter 17.32 Article II. That
Chapter 17.32 Article II of the Salt Lake City Code (General Provisions and Definitions:
Definitions) shall be, and hereby is, amended to adopt a new Section 17.32.061, which shall read
as follows:
17.32.061: AMMONIA (NH3)
“Ammonia (NH3)” means nitrogen in the form of free ammonia and ionic ammonium measured
using methods set forth in 40 CFR 136 or its successor.
SECTION 3. Amending the text of Salt Lake City Code Chapter 17.32 Article II. That
Chapter 17.32 Article II of the Salt Lake City Code (General Provisions and Definitions:
Definitions) shall be, and hereby is, amended to adopt a new Section 17.32.451, which shall read
as follows:
17.32.451: Total Phosphorus (TP)
“Total Phosphorus (TP)” means all forms of phosphorus (orthophosphate, condensed phosphate,
or organic phosphorus) measured using methods set forth in 40 CFR 136 or its successor.
SECTION 4. Repealing Salt Lake City Code Section 17.16.345. That Section 17.16.345
of the Salt Lake City Code (Lot Hydrant; Fee) shall be, and hereby is, repealed in its entirety.
17.16.345: LOT HYDRANT; FEE:
When a culinary water service meter is not used for construction purposes, then during any lot or
subdivision construction in the city's service area, the contractor shall install for each lot a hose
bib (standpipe with automatic drain) meeting the requirements of the city's director of public
utilities. A flat fee, as shown on the Salt Lake City consolidated fee schedule, for water used
during construction per residential lot shall be charged to and paid by the contractor. Commercial
properties shall pay metered rates.
SECTION 5. Amending Section 17.16.020. That Section 17.16.020 of the Salt Lake City
Code (Application; Contents), shall be, and hereby is, amended to read as follows:
17.16.020: APPLICATION; CONTENTS:
The applicant shall state fully and truly the purpose for which water is required, the anticipated
daily water use, and shall agree to conform to and be governed by such ordinances, rules and
regulations as may be prescribed by the city for the control of the water supply. The applicant(s)
agrees to be responsible for and pay all bills due the city on account of materials or labor
furnished costs incurred to provide services.
SECTION 6. Amending Section 17.16.100. That Section 17.16.100 of the Salt Lake City
Code (Connections from Mains; Specifications) shall be, and hereby is, amended to read as
follows:
17.16.100: CONNECTIONS FROM MAINS; SPECIFICATIONS:
The service pipes and connections from the main to the water meter, including the meter box, a
meter yoke and valve are to be placed within the parking strip by a licensed, bonded plumber, to
city standards, and subject to city inspection and approval. In the absence of a parking strip,
service pipes and connections are to be placed in the public right of way or private right of way
as determined by the director. The meter shall be accessible to the department and remain
unobstructed at all times. The city shall install, and applicant will pay the city's costs of such
installation when so determined by the director of public utilities. The plumber shall warrant the
work and facilities installed by him/her against defects in workmanship or materials for a period
of one year from date of acceptance thereof by the city.
SECTION 7. Amending Section 17.16.220. That Section 17.16.220 of the Salt Lake City
Code (Responsibility for Costs of Service) shall be, and hereby is, amended to add a new
subsection to read as follows:
17.16.220: RESPONSIBILITY FOR COSTS OF SERVICE:
A. Before water will be supplied through such service pipe, some person(s) must agree in
writing to be responsible for and pay for all water delivered through the service meter.
B. Where water is now supplied through one service to one or more houses or persons, the
public utilities director may, in his/her discretion, either refuse to furnish water until separate
services are provided, or may continue the supply, on condition that one person shall be
responsible for and pay for all water delivered through the service meter.
C. Where water is now supplied for culinary and outdoor irrigation uses, the director may, in
his/her discretion, require the installation of separate meters to account for culinary water use
separately from outdoor irrigation use.
SECTION 8. Amending Section 17.16.400. That Section 17.16.400 of the Salt Lake City
Code (Meter Maintenance Charges) shall be, and hereby is, amended to read as follows:
17.16.400: METER MAINTENANCE CHARGES:
A. After the one year guarantee of the plumber or if the city makes the installation, the city
shall maintain all water connections of three-fourths inch (3/4") and one inch (1") sizes within
the city, or as otherwise determined by written contract, fro m the point of connection with the
water main up to and including the meter, where the meter is set in the parking strip, or in the
absence of a parking strip, in the public right of way or private right of way as determined by the
director. The meter shall be accessible to the department and remain unobstructed at all times .
B. All maintenance and replacement, where necessary, on all service lines and meters above
one inch (1") in size, is to be kept at the entire expense of the consumer.
SECTION 9. Amending Section 17.16.670. That Section 17.16.670 of the Salt Lake City
Code (Minimum Charges) shall be, and hereby is, amended to read as follows:
17.16.670: MINIMUM CHARGES:
Each customer shall pay the following minimum fixed charge shown on the Salt Lake City
consolidated fee schedule, effective for all meter readings during the periods from and including
July 1, 2011, and thereafter until further amended, to cover meter reading, billing, customer
service and collection costs incurred to provide service.
SECTION 10. Amending Section 17.16.685. That Section 17.16.685 of the Salt Lake
City Code (Urban Vegetable Garden Adjustment Program) shall be, and hereby is, amended to
read as follows:
17.16.685: URBAN VEGETABLE GARDEN ADJUSTMENT PROGRAM:
Customers who occupy property with a vegetable garden of a size between 0.10 and 0.25 of an
acre are eligible to request an adjustment related to additional allocation of water in block 2 for
the months of April through October in support of the city's loc al food production initiative. The
additional block 2 water allocation is based on 17.94 17.22 Ccf per month for each 0.1 acre of
vegetable garden between 0.1 acre and 0.25 acre. Water used in excess of the adjusted block 2
allocation will be billed at block 3 and/or block 4 rates. Applications for an urban vegetable
garden adjustment, which includes an additional block 2 water allocation, are made through the
city’s department of public utilities.
SECTION 11. Amending Section 17.16.790. That Section 17.16.790 of the Salt Lake
City Code (Delinquent Payment; Penalty) shall be, and hereby is, amended to read as follows:
17.16.790: DELINQUENT PAYMENT; PENALTY:
In case of vacancy, where service is discontinued or meter taken out, unless delinquent bills are
paid within thirty (30) days after the service has been discontinued, a penalty of ten percent
(10%) shall may be charged in addition to the regular bill.
SECTION 12. Amending Section 17.32.650. That Section 17.32.650 of the Salt Lake
City Code (Total Suspended Solids or Suspended Solids) shall be, and hereby is, amended to
read as follows:
17.32.650: TOTAL SUSPENDED SOLIDS (TSS) OR SUSPENDED SOLIDS (SS):
"Total suspended solids" or "suspended solids" means the total suspended matter that floats on
the surface of or is suspended in water, wastewater or other liquids, and which is removable by
laboratory filtering in accordance with methods set forth in 40 CFR 136 or its successor.
SECTION 13. Amending Section 17.36.010. That Section 17.36.010 of the Salt Lake
City Code (Supervision of POTW) shall be, and hereby is, amended to read as follows:
17.36.010: SUPERVISION OF POTW:
The POTW shall be supervised and directed by the director or his or her designee.
SECTION 14. Amending Section 17.52.030. That Section 17.52.030 of the Salt Lake
City Code (Permit; Application Contents) shall be, and hereby is, amended to read as follows:
17.52.030: PERMIT; APPLICATION CONTENTS:
A. Users required to obtain a wastewater discharge permit shall complete and file with the
POTW an application in the form prescribed by the POTW, accompanied by a fee as set forth in
section 17.52.270 of this chapter. In support of the application, the user shall submit, in units and
terms appropriate for evaluation, some or all of the following information:
1. Identifying Information:
a. Name, address, telephone number and location (if different from the address) of
applicant and owner of the premises (if different from the tenant when property is leased) from
which industrial wastes are intended to be discharged,
b. The name of an authorized representative or duly authorized representative to act on
behalf of the facility,
c. Description of activities, facilities, and plant production processes on the premises.
SECTION 15. Amending Section 17.52.060. That Section 17.52.060 of the Salt Lake
City Code (Permit; Decisions) shall be, and hereby is , amended to read as follows:
17.52.060: PERMIT; DECISIONS:
A. Incomplete or inaccurate applications will not be processed and will be returned to the user
for revision.
B. The director will evaluate the data furnished by the SIU IU and may require additional
information. Within one hundred twenty (120) days of receipt of a complete permit application,
the director will determine whether to issue a wastewater discharge permit. The director may
conditionally approve or deny any application for a wastewater discharge permit.
SECTION 16. Amending Section 17.52.190. That Section 17.52.190 of the Salt Lake
City Code (Date of Receipt of Reports), shall be, and hereby is, amend ed to read as follows:
17.52.190: DATE OF RECEIPT OF REPORTS:
For written reports that are mailed through a mail facility serviced by the United States postal
service, such reports will be deemed to have been submitted on the date postmarked. For written
reports that are shipped using other common reliable carriers, the carrier's pick up or ship date
will be deemed the submittal date. If a postmark or pick up/ship date is not available, the date of
receipt of the report shall govern. For reports, which are not mailed, postage prepaid, into a mail
facility serviced by the United States Postal Service, the date of receipt of the report shall govern.
SECTION 17. Amending Section 17.64.030. That Section 17.64.030 of the Salt Lake
City Code (Classification of Users) shall be, and hereby is, amended to read as follows:
17.64.030: CLASSIFICATION OF USERS:
The users of the POTW may be divided into various classifications, including, but not limited to,
single dwelling units, duplexes, multiple dwelling units, and nonresidential. Further
classifications may be established by the POTW for each nonresidential user class.
SECTION 18. Amending Section 17.72.030. That Section 17.72.030 of the Salt Lake
City Code (Schedule 1; Rates and Fees) shall be, and hereby is, amended to read as follows:
17.72.030: SCHEDULE 1; RATES AND FEES:
A. Purpose: For the purpose of defraying the cost of construction, reconstruction,
maintenance and operation of the city sewer system, there are hereby imposed the charges shown
on the Salt Lake City consolidated fee schedule upon all persons and premises receiving sewer
collection and treatment services.
B. Definitions:
AVERAGE WINTER CONSUMPTION: The average monthly water usage for residential
customers for the consecutive months of December, January, and February, which is the basis for
residential sewer billings for the twelve (12)-month period beginning July 1 immediately
following such months.
CUSTOMER CLASS: The classification or classifications applicable to each customer of the
sewer system for purposes of calculating such customer's service charge under this chapter,.
based on the applicable range of the strength of such customer's waste discharge, as measured by
BOD and TSS, as follows:
Customer Class BOD (mg/l) TSS (mg/l)
Customer Class BOD (mg/l) TSS (mg/l)
1 <300 <300
2 300 – 600 300 – 600
3 601 – 900 601 – 900
4 901 – 1,200 901 – 1,200
5 1,201 – 1,500 1,201 – 1,500
6 1,501 – 1,800 1,501 – 1,800
7 >1,800 >1,800
More than one class may apply to a customer at the same time. For example, a customer may be
in class 2 for BOD, and in class 4 for TSS. The director shall assign class designations to
customers based upon the nature of the facility owned or operated by the customer, and estimates
based on sample measurements taken from similar facilities. Any customer may, at its expense,
demonstrate that actual BOD or TSS discharges differ from the director's estimates, and the
director shall assign such customer to a different class or classes, accordingly. Such actual
measurements shall be conducted in accordance with procedures established by the director.
DUPLEX: A single building containing two (2) independent dwelling units.
DWELLING UNIT: A building or other structure or portion thereof, in which: 1) an individual
resides as a separate housekeeping unit, or 2) a collective body of persons (doing their own
cooking) resides as a separate housekeeping unit in a domestic bond based upon birth, marriage,
domestic employment or other family relationship, as distinguished from a boarding house,
lodging house, club, fraternity, motel or hotel.
MONITORED CUSTOMER: Non-residential customers, designated by the director, subject to
routine sample measurements of the customer’s wastewater flow and or discharge characteristics.
MULTIPLE DWELLING: Any building or other structure, having four (4) or more dwelling
units therein, including a mobile home park.
MULTI-FAMILY RESIDENTIAL: Any building or other structure having four (4) or more
residential dwelling units therein, including a mobile home park.
NON-RESIDENTIAL: Buildings used for uses other than residential purposes.
RESIDENTIAL: Buildings or dwelling units used to house people or persons for residential
purposes, including single dwelling units, duplexes, and triplexes, and excluding multi -family
residential structures or buildings.
SERVICE CHARGE: The charge for sewer collection and treatment services levied on all users
of the public sewer system, as calculated pursuant to this chapter.
SERVICE TO MULTIPLE BUILDINGS: Sewer service to multiple buildings shall be governed
the same as section 17.16.200 of this title.
SINGLE DWELLING UNIT: A building containing one dwelling unit.
TRIPLEX: A single building containing three (3) independent dwelling units.
UNMONITORED CUSTOMER: Any non-residential customer not designated as monitored.
C. Sewer Charges:
1. a. Each residential sewer customer in classes 1 to 6 shall be charged a monthly service
charge equal to the greater of: 1) the fixed monthly charge together with the cumulative flow
rate, BOD rate and TSS rate per one hundred (100) cubic feet of metered water usage during the
winter period, of average winter consumption as shown on the Salt Lake City consolidated fee
schedule, or 2) a minimum charge shown on the Salt Lake City consolidated fee schedule. The
average monthly water meter readings during the consecutive months of November, December,
January, February and March (hereinafter "winter months"), shall be the basis for sewer billings
for the twelve (12) month period beginning July 1 and ending June 30, immediately following
such winter months.
b. Each customer in class 7 and all other classes that are monitored separately monitored
non-residential customer shall be charged a monthly service charge equal to the fixed monthly
charge based on actual discharge strength. The flow together with the component will be charged
at a shown on the Salt Lake City consolidated fee schedule metered water monitored wastewater
flow measured used during the billing period as shown on the Salt Lake City consolidated fee
schedule. The charges for wastewater pollutants shall be billed as shown on the Salt Lake City
consolidated fee schedule.
Either a BOD or COD charge will be assessed, but not both. When there is an unexplained
difference between the two (2) test results of COD and BOD the higher of the two will be used.
Nothing in this section shall authorize discharges in excess of the maximum local limit
concentrations established by the director pursuant to section 17.36.090 of this title.
c. Each unmonitored non-residential customer and each multi-family residential customer
shall be charged a monthly service charge equal to the monthly service charge together with the
flow rate per the Salt Lake City consolidated fee schedule. The monthly water meter reading for
sewer billing purposes shall be equal to 70 percent (70%) of total water usage for the month.
cd. In cases where little or no water is used during one or more of the winter months, such
that the average metered usage during such winter months cannot be reasonably assumed to
reflect typical monthly usage for an account, the director may use other co nsumptive information
specific to such account to determine average monthly minimum usage for sewer billing
purposes the average winter consumption.
de. Meter readings for sewer billing purposes shall only include meters which measure
water entering the sewer system.
ef. In the case of sewer users whose water usage is based in whole or in part on water
sources other than the city, the city may require installation of a city approved meter, at the
sewer user's expense, on the well(s) or other sources of water supply, fo r measurement by the
city during the winter months to determine the sewer user's water use during the winter months.
fg. For each single-family dwelling sewer user using water other than city water and
desiring not to install a water meter as provided above, the director may waive the meter
requirement, in which event the user will be charged for sewer service as provided in subsection
E of this section.
D. Metering Of Sewage Flows:
1. Meters will be allowed in sewer lines when the user is permitted or required by the
director to have the sewage flow subject to the following requirements:
a. The charges for sewer service will be based upon the actual sewer meter readings rather
than upon the average of said winter readings average winter consumption or adjusted water
meter readings.
b. The user will furnish, install, and maintain at user's expense a meter pursuant to the
city's standards and specifications.
E. New Sewer Accounts:
1. For new residential sewer accounts, until the data required by subsection C1a of this
section is available, the monthly sewer rates shall be based on the average winter consumption
for comparative users. as shown on the Salt Lake City consolidated fee schedule.
a. For monitored and unmonitored non-residential class 7 customers, new accounts shall
be treated in the same manner as established accounts under subsections C1b and C1c,
respectively, of this section.
F. Service Charge Adjustment:
1. The director may provide for adjustments as needed to ensure equitable service charges.
Such adjustments may be made where excessive quantities of culinary water pass through the
water meter, but are consumed on the premises and do not enter the sewer system. In each such
instance, the user will have the burden of providing evidence of such inequities by showing that
the quantity of water not entering the sewer, but passing through the meter, exceeds twenty thirty
percent (20 30%) of the total flow in order to merit such consideration by the director. Each such
adjustment proposed to be made by the director shall first be presented to the public utilities
advisory committee for review and recommendation, following which review and
recommendation the director shall make a final determination.
2. Additionally, the director may make adjustments under the following conditions due to
faulty inside plumbing. All adjustments will be determined by prior usage. When the charge is
not based on preceding usage and has not been established on average winter consumption,
winter average the charge will be determined as outlined in this section or its successor. Only
one adjustment in total is allowed per account and under the following conditions:
a. When defective plumbing has caused the average winter water consumption to exceed
the previous year's average by twenty-five percent (25%) or more, there may be an adjustment
made based on prior usage. The customer must provide to the director evidence that plumbing
repairs were made within thirty (30) days of notification from the city issuance of the bill in
which the defective plumbing caused an increase in usage. Such evidence may be in the form of
a statement detailing the repairs made and the date of completion. The adjustment shall be made
following the determination by the director that the repairs have resulted in decreased water
consumption.
b. In the event of a customer's unexplainable large increase in water consumption during
the consecutive months of November through March December, January, and February of any
year, the director may make adjustments to any account when there has been a twenty -five
percent (25%) increase or more in usage during the winter months. Any adjustment may be made
only after an in-depth review of the account has been completed, and based solely on the merits
of each individual request, and the circumstances surrounding the request.
c. The director may make adjustments to the account of a single- family residence, if the
user or a user's tenant who has also signed the agreement for water service has temporary
additional (2 or more) people living at the residence during all or part of the "winter meter
readings" period and it has caused the average winter water consumption to exceed the previous
year's average by twenty five percent (25%) or more. Such adjustment may be made by using the
following guidelines:
(1) For one month or less, no adjustment will be allowed;
(2) For more than one month to twelve (12) months, the charge will be based on the new
average winter water use for the number of months said additional people were in the residence;
(3) For all months following the period when said additional people are not in the
residence, the charge will be based upon the previous year's established average use, or the fee
shall be as outlined in subsection F2d of this section, or its successor subsection.
dc. All adjustments will be determined by the sewer charge usage of the preceding year.
When the charge usage for the preceding year is not established on winter average winter
consumption, the charge will be determined as outlined in subsection F2c of this section, or its
successor subsection by other consumptive data or comparative users.
G. Sewer Service Fees: The director shall charge, and the city shall collect the fees shown on
the Salt Lake City consolidated fee schedule.
1. Special industrial and commercial uses, including car washes, laundromats, etc., as
determined by the city's public utilities director, shall be charged the fee shown on the Salt Lake
City consolidated fee schedule per equivalent fixture unit, as specified in the uniform plumbing
code.
2. Connection fees on property with prior development:
a. When a residential building is demolished and the existing lateral is used for the same
property, there is no new sewer connection fee for the property when residential use or building
type is same as prior to demolition. After five (5) years from date of demolition no credit will be
given for prior sewer connection fees. After five (5) years from demolition the property owner
will be required to pay all connection fees.
b. When a commercial building such as a hotel, motel, industrial building, etc., is
demolished the sewer fee shall be based and charged on new additional use pursuant to the
applicable fee shown on the Salt Lake City consolidated fee schedule. A fter five (5) years from
date of demolition no credit will be given for prior sewer connection fees. After five (5) years
from demolition the property owner will be required to pay all connection fees required by the
city.
3. Temporary sewer connections may only be made by approval of the director. Temporary
connections cannot exceed twenty four (24) months. The fee for each temporary connection shall
be shown on the Salt Lake City consolidated fee schedule. All other applicable fees will be
effective for temporary connections.
4. All other fees necessary for the operations, maintenance, and services provided by the
Wastewater Control and Sewer System and shown on the Salt Lake City consolidated fee
schedule.
SECTION 19. Amending Section 17.81.200. That Section 17.81.200 of the Salt Lake
City Code (System of Rates and Charges) shall be, and hereby is, amended to read as follows:
17.81.200: SYSTEM OF RATES AND CHARGES:
A. Generally: There are hereby imposed stormwater sewer service fees, rates and charges,
effective for all billing periods after and including July 1, 2011, and thereafter until further
amended, on the owner of each developed parcel within the city, except: 1) governmentally
owned streets, and 2) parcels on which are located stormwater sewer facilities operated and
maintained by, or for, the county. The charges shall fund the administration, planning, design,
construction, water quality programming, op eration, maintenance and repair of existing and
future stormwater sewer facilities.
B. Residential Service Charges: Residential service charges for use of the stormwater sewer
system shall be as shown on the Salt Lake City consolidated fee schedule.
C. Undeveloped Parcels: Undeveloped parcels shall not be assessed a stormwater service
charge.
D. Other Parcels: The charge for all other parcels shall be based upon the total square footage
of measured impervious surface, divided by two thousand five hundred (2,500) square feet, or
one ERU, and rounded to the nearest whole number. The actual total monthly service charge
shall be computed by multiplying the total ERUs for a parcel by the monthly rate shown on the
Salt Lake City consolidated fee schedule.
E. Credit For On Parcel Mitigation: Nonresidential parcels with on site stormwater detention
or retention facilities are eligible for a service charge credit upon application to the director by
the person owning the parcel, or such person's agent. The amount of credit, if any, shall be no
more than twenty-five percent (25%) of the full stormwater charge per the Salt Lake City
consolidated fee schedule, with the exception of entities that are individually permitted under the
Utah Water Quality Act and federal Clean Water Act. , for on site detention or retention facilities
is based on the following formula:
P = 0.25 + 0.70 (factor) + 0.05 (permit)
The foregoing symbols have the following meanings:
P Percentage of total service charge to be applied to each parcel.
0.25 Represents 10 percent for department administration cost plus 15 percent for utility operation and
maintenance costs (half of the estimated total cost for utility operation and maintenance).
0.70 Represents 15 percent for utility operation and maintenance (half of the estimated total cost for
utility operation and maintenance) plus 55 percent for a utility capital improvement program.
Factor Restricted discharge (Qr) from a developed parcel divided by the peak discharge (Qp) from the
same developed parcel which would result if the flow restriction facilities were not in place.
0.05 Represents 5 percent for NPDES stormwater permit for the parcel.
Permit The rate adjustment, which applies when the parcel has an NPDES discharge permit from the
state, will be equal to 0. When the parcel is included in the city NPDES permit, this rate
adjustment is equal to 1.
1. Mitigation credit is available only for those non-residential parcels whose stormwater
facilities meet the city's design and maintenance standards.
2. If the stormwater facilities are not properly maintained or if related structures are
modified from an approved design, the mitigation credit may be modified or terminated by the
city.
3. The director shall provide a complete on-site mitigation evaluation at the request and
expense of the person owning the parcel, or the owner's duly authorized agent.
F. Low-Income Abatement: A person who owns a single-family residential parcel and is
qualified for an abatement of the minimum monthly water charge pursuant to
section 17.16.670 of this title shall be eligible for a fifty percent (50%) reduction of the service
charge for such parcel
G. Nonservice Abatement: A parcel which is not directly or indirectly benefited by the
stormwater sewer utility shall be entitled to an abatement of the service charge for said parcel. In
order to receive such abatement, the owner, or the owner's agent, shall apply, in writing, to the
director pursuant to section 17.81.500 of this chapter.
SECTION 20. That a copy of the amended Salt Lake Code shall be published on the
official Salt Lake City website.
SECTION 21. That this ordinance shall become effective July 1, 2025.
Passed by the City Council of Salt Lake City, Utah, this _____ day of __________, 2025.
________________________
CHAIRPERSON
ATTEST:
______________________________
CITY RECORDER
Transmitted to the Mayor on __________________
Mayor’s Action: ____ Approved ____ Vetoed
_________________________
MAYOR
ATTEST:
_______________________________
CITY RECORDER
(SEAL)
Bill No. _________ of 2025.
Published: ___________________
Salt Lake City Attorney’s Office
Approved As To Form
/s/ Carly Castle
Carly Castle
Senior City Attorney
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CITY COUNCIL OF SALT LAKE CITY
451 SOUTH STATE STREET, ROOM 304
P.O. BOX 145476, SALT LAKE CITY, UTAH 84114-5476
SLCCOUNCIL.COM
TEL 801-535-7600 FAX 801-535-7651
COUNCIL STAFF REPORT
CITY COUNCIL of SALT LAKE CITY
TO:City Council Members
FROM: Austin Kimmel,
Public Policy Analyst
DATE:May 20, 2025
RE: ORDINANCE UPDATES TO TITLE 17 TO COMPLY WITH RATE STUDY AND
REGULATORY REQUIREMENTS
ISSUE AT-A-GLANCE
The Salt Lake City Department of Public Utilities (SLCDPU) proposes several ordinance amendments to Salt
Lake City Code Title 17: PUBLIC SERVICES. The amendments are proposed for two primary reasons, as
explained in this report.
First, several of the amendments are necessary to implement the proposed utility rates for Public Utilities in
Fiscal Year 2025-26 (FY26). These rates are informed by the 2024 Comprehensive Water, Wastewater, and
Stormwater Rate Study, which the City Council was briefed about on January 7, 2025.
Second, additional amendments are required to ensure compliance with State and Federal regulations regarding
the Public Utilities' Pretreatment Program. In 2023, SLCDPU underwent an audit by the State's Division of
Water Quality (DWQ) in its enforcement role of the City's Pretreatment Program. That audit identified several
regulatory requirements for Public Utilities necessitating additional amendments to Title 17.
Please refer to pages 79 – 93 of the Administrative Transmittal for a redlined version of Title 17.
Goal of the briefing: To review the proposal for updating Title 17 to comply with the City’s proposed water,
sewer, and stormwater rate structures, and to comply with regulatory requirements.
ADDITIONAL & BACKGROUND INFORMATION
Key Definition: Pretreatment Program: a regulatory framework that oversees industrial wastewater
discharged into the City's sanitary sewer system (publicly owned treatment works; POTW). Industrial customers
are required to treat wastewater to reduce or eliminate pollutants before discharge into the POTW. This program
is governed by the Salt Lake City Ordinance, Utah Administrative Code, and the Federal Clean Water Act.
IMPLEMENTATION OF THE 2024 RATE STUDY & PROPOSED FY26 UTILITY RATES
In 2024, the Department of Public Utilities conducted a comprehensive utility rate study with FCS Group, a
consulting firm specializing in municipal rate and fee setting. The study continues Public Utilities' practice of
conducting rate evaluations every five to six years, which is a necessary review in order to ensure the structure
meets the Department’s revenue needs, and adjusts based on projected capital and operating increases. The
study resulted in several recommended changes to more accurately reflect the actual cost of service delivery
Project Timeline:
Briefing: May 20
Public Hearings: May 20 and June 3
Potential Action: June 10, or later date
TBD
Page | 2
across different customer classes and amendments to Salt Lake City’s Consolidated Fee Schedule (CFS). Upon
adoption of the FY26 CFS and the FY26 SLCDPU Budget, several Title 17 amendments will be necessary.
Stormwater Credits: The City currently offers a stormwater credit program that reduces stormwater
rates for non-residential customers in exchange for installing on-site stormwater mitigation facilities.
The lower rates range from zero to more than 75 percent of the applicable rate, with the average existing
credit per parcel being 61 percent. As proposed in FY26, Public Utilities will reduce the maximum credit
to 25% for new developments seeking stormwater credits. Per the Rate Study, the credit reduction will
be phased in over three years for existing customers participating in this program. The proposed
amendment to section 17.81.200: SYSTEM OF RATES AND CHARGES updates the ordinance to reflect
this new maximum credit.
Average Winter Consumption (AWC): Monthly sewer rates are calculated from the previous year’s
average winter water consumption (AWC). Public Utilities proposes using only the months of
December, January, and February (three months, instead of the current six months of November
through March) to determine AWC. Amendments to 17.72.030: SCHEDULE 1; RATES AND FEES: will
implement this new definition into the ordinance. This will reduce the amount of time used in
calculating the AWC and more closely aligns with current best practices in establishing AWC for our
region. The AWC calculation for December, January, and February 2025 will be reflected in customer
bills starting July 1, 2026.
New high-strength surcharges: Some industries in Salt Lake City discharge higher levels (or
strengths) of pollutants into the sewer system, which carry a greater treatment cost. New regulations
now require the City to reduce the amount of nutrients in its wastewater discharge, which in turn is a
driver for the construction of the City’s new sewer treatment plant. The new sewer rates introduce
charges for nutrients, specifically ammonia (NH3) and total phosphorus (TP) in industrial discharges,
alongside other existing high-strength charges. Chapters 17.32.061 and 17.32.451 are added for this
purpose. The surcharges, with the single monthly service charge, allow the department to maintain
fairness and equity by identifying and monitoring select customers who cause a higher burden on the
wastewater conveyance and treatment systems.
Simplified customer classes: Amendments to 17.72.030 introduce new definitions for the following
customer classes: Monitored Customer, Unmonitored Customer, Multi-family residential, non-
residential, and residential. This change attempts to simplify the sewer classification system. With new
high-strength surcharges for nutrients, the current system could create over 1,200 unique classes if
customer classes are not simplified.
Volumetric charge: New language is added into 17.72.030 to define that the monthly water meter
reading for sewer billing purposes shall equal 70% of the total water used for unmonitored non-
residential and multi-family residential customers. As indicated in the Rate Study, the 70% figure is a
standardized allowance for water not returned to the City’s sewer system due to consumption.
PRETREATMENT AUDIT REPORT RECOMMENDATIONS
Public Utilities staff has not identified any elements of the 2023 audit ordinance amendment
recommendations that would financially impact rate payers.
Page | 3
TITLE 17 CLARITY
During its assessment of Title 17, Public Utilities identified areas of the code that are outdated and no longer
necessary, or could be improved with greater clarity.
Public Utilities identified four ordinance updates that are indirectly related to the Rate Study's structural rate
changes, which are necessary to implement the new rates and provide clarity. Public Utilities provided the
following information to help explain these proposed changes:
Addition of 17.16.655: Abatements: This section is added to more clearly and directly reflect the
existing CFS and practice of applying abatements for low-income relief based on property tax
abatement status. Current City Code addressing this is written in a confusing manner. This is one tool
that helps to address the affordability goals of the City’s rate policies.
Removal of 17.16.345: Lot Hydrant Fee: The use of lot hydrants for construction no longer meets
development standards and has not been used for quite some time. It is a legacy ordinance that is not
included in the existing CFS.
Addition to 17.16.100: Connections From Mains and 17.16.400 Meter Maintenance
Charges: With the increase in infill development, the current standard of placing meters in a park
strip does not always apply, and issues arise with meters being placed in areas we can’t access them.
This clarifies where meters can be located and gives the Department some flexibility to make case by
case determinations.
Addition of 17.16.220 (c): This will help implement changes in both the water and sewer rate
structures. For example, with the changes in the sewer rate structure for non-residential and multi-
family properties, some sites with a single meter used for both indoor use and outdoor watering may
experience a sewer charge that is based on higher outdoor irrigation, greatly increasing the sewer
charge. An example being an HOA with a single meter that is used for indoor water use, and the
watering of individual and shared outdoor spaces. Separate irrigation meters are not charged for
sewer and receive a target water budget. In some situations, it would be beneficial for the City and the
customer if separate meters are employed. This will more fairly and accurately account for indoor
and outdoor water use and apply sewer charges.
AWC – Average Winter Consumption
CFS – Consolidated Fee Schedule
DWQ – The Utah Division of Water Quality
FY – Fiscal Year
HOA – Homeowners Association
POTW – Publicly Owned Treatment Works
SLCDPU – Salt Lake City Department of Public Utilities
1.Administrative Transmittal
2.Fiscal Year 2025-26 Public Utilities budget book
3.2024 Comprehensive Water, Wastewater, And Stormwater Rate Study Council Staff Report
City Council Announcements
A. Downtown Alliance Exploration Changes
Staff has been in touch with the Downtown Alliance staff to confirm some
adjustments that have been made to the program to ensure compliance with the
Council's travel policy. This means that the full Council is eligible to go.
Let us know if you are interested in going and staff can register you. As a
reminder it is September 17-20 this year.
In addition, the Administration let us know they are putting together some extra
content in the days leading up to the DTA trip to review homeless service
providers in Seattle. Let us know if you're interested or available for those extra
days.
SALT LAKE CITY CORPORATION
SWORN STATEMENT SUPPORTING CLOSURE OF MEETING
I, Chris Wharton, acted as the presiding member of the Salt Lake Council, which met on May 20, 2025 in a hybrid meeting
pursuant to Salt Lake City Proclamation.
Appropriate notice was given of the Council's meeting as required by §52-4-202.
A quorum of the Council was present at the meeting and voted by at least a two-thirds vote, as detailed in the minutes of
the open meeting, to close a portion of the meeting to discuss the following: §52-4-205(l)(a) discussion of the character, professional competence, or physical or mental health of an individual; §52 -4-205(1)(b) strategy sessions to discuss collective bargaining; §52-4-205(l)(c) strategy sessions to discuss pending or reasonably imminent litigation; §52-4-205(l)(d) strategy sessions to discuss the purchase, exchange, or lease of real property, including
any form of a water right or water shares, if public discussion of the transaction would: (i) disclose the
appraisal or estimated value of the property under consideration; or (ii) prevent the public body from
completing the transaction on the best possible terms; §52-4-205(l)(e) strategy sessions to discuss the sale of real property, including any form of a water right
or water shares if: (i) public discussion of the transaction would: (A) disclose the appraisal or estimated
value of the property under consideration; or (B) prevent the public body from completing the transaction
on the best possible terms; (ii) if the public body previously gave public notice that the property would be
offered for sale; and (iii) the terms of the sale are publicly disclosed before the public body approves the
sale; §52-4-205(1)(f) discussion regarding deployment of security personnel, devices, or systems; and §52-4-205(1)(g) investigative proceedings regarding allegations of criminal misconduct. A Closed Meeting may also be held for Attorney-Client matters that are privileged pursuant to Utah Code
§78B-1-137, and for other lawful purposes that satisfy the pertinent requirements of the Utah Open and Public Meetings Act. Other, described as follows: _____________________________________________________________
The content of the closed portion of the Council meeting was restricted to a discussion of the matter(s) for which the
meeting was closed.
With regard to the closed meeting, the following was publicly announced and recorded, and entered on the minutes of the
open meeting at which the closed meeting was approved:
(a) the reason or reasons for holding the closed meeting;
(b) the location where the closed meeting will be held; and
(c) the vote of each member of the public body either for or against the motion to hold the closed meeting.
The recording and any minutes of the closed meeting will include:
(a) the date, time, and place of the meeting;
(b) the names of members Present and Absent; and
(c) the names of all others present except where such disclosure would infringe on the confidentiality
necessary to fulfill the original purpose of closing the meeting.
Pursuant to §52-4-206(6), a sworn statement is required to close a meeting under §52-4-205(1)(a) or (f), but a record by
electronic recording or detailed minutes is not required; and Pursuant to §52-4-206(1), a record by electronic recording
and/or detailed written minutes is required for a meeting closed under §52-4-205(1)(b),(c),(d),(e),and (g): A record was not made. A record was made by: : Electronic recording Detailed written minutes
I hereby swear or affirm under penalty of perjury that the above information is true and correct to the best of my
knowledge.
Presiding Member Date of Signature
Chris Wharton (Jun 13, 2025 10:21 MDT)Jun 13, 2025
May 20, 2025 Closed Meeting Sworn Statement
Final Audit Report 2025-06-13
Created:2025-06-12
By:DeeDee Robinson (deedee.robinson@slc.gov)
Status:Signed
Transaction ID:CBJCHBCAABAAxVGKxdi_buiO4YqsBYo1-oVepKB3df4h
"May 20, 2025 Closed Meeting Sworn Statement" History
Document created by DeeDee Robinson (deedee.robinson@slc.gov)
2025-06-12 - 9:49:36 PM GMT
Document emailed to Chris Wharton (chris.wharton@slc.gov) for signature
2025-06-12 - 9:50:33 PM GMT
Email viewed by Chris Wharton (chris.wharton@slc.gov)
2025-06-13 - 5:18:32 AM GMT
Document e-signed by Chris Wharton (chris.wharton@slc.gov)
Signature Date: 2025-06-13 - 4:21:05 PM GMT - Time Source: server
Agreement completed.
2025-06-13 - 4:21:05 PM GMT