To: Honorable Mayor and Members of Town Council
From: Mark Marlowe, P.E. Director of Castle Rock Water
Title
Ordinance Amending Chapter 13.04 Sewer System; Prohibited Discharges by Adding a New Section 13.05 Grease Interceptors Required (Second Reading - Approved on First Reading on April 21, 2020 by a Vote of 7-0)
Body
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Executive Summary
This item was presented as a Public Hearing item during the April 21, 2020 Town Council meeting, and approved by Council unanimously by a vote of 7-0.
The purpose of this memorandum is to request Council approval of the Ordinance (Attachment A) Amending Chapter 13.04 Sewer System; Prohibited Discharges by adding a new section, 13.05 Grease Interceptors Required. Castle Rock’s section 13.04 of Town Code requires all connectors to the sewer system to comply with the Code of Rules and Regulations of the Plum Creek Water Reclamation Authority (PCWRA). Grease interceptors are required under PCWRA’s rules, however as a referral agency for development projects or new businesses in Castle Rock, PCWRA’s rules surrounding grease interceptors are not always immediately obvious to those doing work on a project or new business in Castle Rock. The purpose of the code change is to make the requirements for grease interceptors a specific requirement of Town code so that the Town’s staff can help manage this process and better communicate the requirements to new applicants for development projects or new businesses rather than waiting on the referral process to PCWRA to identify the requirement for a grease interceptor. To this end, Castle Rock staff have also developed a form to use to make developers, business owners, and other applicants aware of the grease interceptor requirements at the time of application, (see Attachment B). Again, the purpose of this new form is to communicate grease interceptor requirements to applicants early and often to ensure that money is not spent or invested in projects without knowledge of these requirements.
Notification and Outreach Efforts
This item was presented to the Developer’s Roundtable on February 19, 2020. There was minimal feedback, but the feedback that was received was positive.
History of Past Town Council, Boards & Commissions, or Other Discussions
On February 26, 2020, Castle Rock Water staff presented this item to Castle Rock Water (CRW) Commission. The CRW Commission voted unanimously to recommend the Ordinance. On April 21, 2020, staff presented this item to Town Council, and it was approved unanimously with no changes on first reading.
Discussion
Outdoor grease interceptors are required for all food service facilities in Castle Rock already. The requirements are in the PCWRA Code of Rules and Regulations, and by Town code, sewer service within Castle Rock must be provided in accordance with these regulations. Town Code, however, does not specifically call out the requirement for grease interceptors. Currently, plans for new development, businesses or other projects are sent to PCWRA for review as part of a referral process. This ultimately results in review by PCWRA of the plans and identification of any required grease interceptors. The problem is the time required for the referral process and the timing of the referral.
In the current process, the applicant is directed to contact PCWRA to identify any requirements they might have at the time of pre-application. The next requirement occurs when the Site Development Plan (SDP) is being reviewed. At this point, an email is sent to PCWRA requesting that they review the SDP. There is no requirement for positive feedback or an approval from PCWRA before SDPs are approved, and the applicant moves on to construction documents (CDs). CDs are not referred to PCWRA for comment or approval at all. Finally at the point of building permit, the applicant is required to get a letter from PCWRA prior to issuance of the permit. There are a number of issues with this current process including the fact that no approval is required from PCWRA all the way until building permit which is far into the process. The applicant will have spent significant money by this point and may still not realize they need a grease interceptor. Other issues with the current process include breakdowns in communication especially with respect to timing, difficulty for applicants in navigating the online forms for PCWRA, and problems with applicants understanding PCWRA’s Code of rules and Regulations.
As part of the passing of this new ordinance, CRW plan review staff will take a more active role in communicating PCWRA’s requirements to the applicant, putting comments on the SDPs and requiring confirmation of what will be required at SDP prior to moving to CDs.
Budget Impact
There are no significant budget impacts to the proposed ordinance. Plan review staff will have some additional work to do to implement the ordinance and communicate the requirements to the development and business community at the time of application for new projects. Plan review staff will also have additional items to review on the plans to ensure that grease interceptors are in place and sized appropriately for specific projects as verified by PCWRA. None of this work is expected to have a significant impact on the budget.
Staff Recommendation
Staff and CRW Commission recommend Council approval of the ordinance on second reading as presented.
Proposed Motion
“I move to approve the Ordinance as introduced by title, on second reading.”
Attachments
Attachment A: Ordinance
Attachment B: Notification of Grease Interceptor Requirements Form