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FINAL REPORT
City of Glendale
STORMWATER MANAGEMENT PROGRAM PERFORMANCE AUDIT
June 10, 2025
Moss Adams LLP
999 Third Avenue, Suite 2800
Seattle, WA 98104
(206) 302-6500
Stormwater Management Program Performance Audit Report
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Table of Contents
I. Executive Summary 1
A. Statement of Compliance with Standards 1
B. Conclusions 2
C. Commendations 4
II. Introduction 5
A. Introduction 5
B. Background 5
C. Objectives 6
D. Scope and Methodology 7
III. Findings and Recommendations 8
A. Stormwater Funding and Costs 8
B. Program and Asset Management 22
Appendix A: Definitions of Assessment Finding Rankings 38
Appendix B: Peer Benchmarking 39
Appendix C: Management Response 44
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I. EXECUTIVE SUMMARY
As a part of the fiscal year (FY) 2025 internal audit program for the City of Glendale, Arizona (the
City), Moss Adams LLP (Moss Adams) conducted a performance audit to assess the City’s
Stormwater Management Program (SWMP). The objectives of this performance audit were to:
• Evaluate the sustainability of funding mechanisms for stormwater management, including capital
improvements, maintenance, and compliance with Municipal Separate Storm Sewer System
(MS4) permits.
• Review stormwater asset management practices, including inventory management, clarity of
maintenance responsibilities across departments, and the effectiveness of current maintenance
practices in preventing system failures.
• Analyze how stormwater costs are captured for areas serviced by non-City water providers.
• Compare services, infrastructure, funding, and rates to similarly situated cities in the Valley.
To complete this performance audit, Moss Adams conducted interviews and reviewed documents
including, but not limited to, budgets, technical reports, stormwater management plans, organization
charts, program reports, policies and procedures, and relevant City and state laws and regulations to
understand current practices and challenges. To complete our analysis, we conducted peer
benchmarking with four cities in the region and researched industry best practices to inform our
recommendations.
A. STATEMENT OF COMPLIANCE WITH STANDARDS
This engagement was performed in accordance with Standards for Consulting Services established
by the American Institute of Certified Public Accountants. Accordingly, we provide no opinion,
attestation, or other form of assurance with respect to our work or the information upon which our
work is based. This engagement was also performed consistent with the guidance issued by the
Institute of Internal Auditor’s (IIA’s) Global Internal Audit Standards (GIAS). This report was
developed based on information gained from our interviews and analysis of sample documentation.
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B. CONCLUSIONS
The following findings assess the City’s SWMP challenges, including the lack of a structured cost-
tracking system, deficiencies in asset management, gaps in preventive maintenance, and limitations
in program coordination. These findings highlight risks related to financial oversight and long-term
program sustainability. Recommendations are intended to help the City improve SWMP efficiency,
enhance interdepartmental coordination, and strengthen data-driven decision-making. All findings are
ranked as medium or low-rated findings. Refer to Appendix A for definitions of finding rankings.
FINDINGS AND RECOMMENDATIONS
Stormwater Funding and Costs
Medium-Rated Finding
1. Finding The City’s SWMP including maintenance, inspections, contractors, and capital
projects is funded through a variety of methods including sewer revenue,
general funds, and grants, and has thus far been able to meet demands.
Services funded through general funds and sewer revenues struggle to
compete with other municipal priorities, which presents a future risk such as
underfunding to the program.
Recommendations Evaluate options for implementing a stormwater fee, focusing on updated
conditions, potential benefits, and equity among residents.
Continue established practices of pursuing grant funding for programmatic
elements such as public outreach and capital improvement.
Low-Rated Findings
2. Finding The City does not have a framework to distinguish stormwater program work
from routine departmental functions. While stormwater responsibilities are
spread across multiple departments, there is no unified system for tracking
work hours or budgets dedicated specifically to the SWMP.
Recommendations Develop a unified tracking system for stormwater-related hours, materials,
and budgets, designed to integrate with existing workflows and minimize
administrative burden.
Aggregate all stormwater costs, including internal labor and contracted
services, into a single budget to identify funding gaps and secure stable
funding sources, such as stormwater fees.
3. Finding The City provides stormwater management services for the area west of 115th
Avenue. However, because residents and businesses in this area are served
by private water and sewer providers, they do not pay City water or sewer
fees—which fund stormwater maintenance. While they don’t contribute to this
system through water fees, they do pay City taxes that go into the general fund,
which supports other aspects of the City’s stormwater program.
Recommendation If the City were to pursue the setup of a stormwater fee, it could recover the
cost of stormwater services to the area. If not, the cost of the program will need
to be incorporated into future rate and tax studies.
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FINDINGS AND RECOMMENDATIONS
Program and Asset Management
Medium-Rated Findings
4. Finding The City uses CentralSquare as a centralized asset management system, but
many departments also use shared spreadsheets and cloud software to track
assets. This approach has left the stormwater asset inventory incomplete, with
critical details—such as ownership, maintenance responsibility, type, material,
condition, and size—often missing or inaccurate.
Recommendations The City should continue its initiative to address deficiencies in
CentralSquare and establish this as its system of record for stormwater
assets.
Develop an asset management framework to guide decentralized asset
management tasks across departments.
5. Finding The City’s stormwater asset management program lacks a centralized
preventive maintenance plan that addresses all program aspects. While efforts
like the 2023 Outfall Prioritization and Inspection Standard Operating
Procedure and Water Services Division-Stormwater Management rotational
inspection schedule exist, they are limited in scope. This gap results in reactive
maintenance, deferred repairs, and reliance on emergency responses,
increasing costs, risks of regulatory non-compliance, and threats to public
safety and water quality.
Recommendation Develop a preventive maintenance plan that consolidates regular inspections
and maintenance schedules and prioritizes maintenance work based on asset
condition and criticality.
Low-Rated Finding
6. Finding The City struggles to effectively coordinate and manage stormwater program
tasks as the program continues to grow and changes in department leadership
and staffing occur. This creates fragmented efforts, unclear roles, and limited
coordination, which reduce the overall effectiveness of stormwater initiatives.
Recommendations Formalize a decision-making framework to clarify roles and standardize the
process for allocating responsibilities for stormwater management activities
across departments.
Develop a consistent process for effectively communicating the process to
new members as personnel changes occur.
Establish a regular cadence by which roles and responsibilities are
reviewed to ensure they remain up-to-date, are considerate of
departmental capacity, and can be appropriately funded.
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C. COMMENDATIONS
Although the focus of this performance audit was to identify opportunities for improvement, it is
important to recognize areas where the City has demonstrated effective stormwater management
practices, including:
• Commitment to Regulatory Compliance: The City has implemented inspection schedules,
stormwater sampling, and public education efforts to support compliance with its MS4 permit.
These efforts demonstrate a proactive approach to meeting regulatory obligations.
• Interdepartmental Collaboration on Stormwater Management: Despite challenges in tracking
and coordination, multiple City departments—including Water Services, Engineering,
Transportation, and Field Operations—actively contribute to stormwater management activities.
This cross-departmental effort reflects a commitment to maintaining stormwater infrastructure and
responding to community needs.
• Investments in Stormwater Asset Tracking and Maintenance: The City has taken steps to
prioritize asset tracking and inspection processes, including the use of CentralSquare for asset
management. While further improvements are needed, these initial efforts lay a foundation for
enhancing preventive maintenance and infrastructure management.
We would like to thank City staff and leadership for their willingness to assist with this project.
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II. INTRODUCTION
A. INTRODUCTION
The City contracted Moss Adams to conduct a performance audit of the City’s SWMP. We evaluated
the City’s stormwater funding mechanisms, asset management practices, and cost-tracking
processes, performed a peer City comparison, and conducted best practice research to develop our
findings and recommendations. This performance audit was conducted as part of the FY 2025 Annual
Audit Plan developed by the City’s Independent Internal Audit Program (IIAP). Our performance audit
took place between November 2024 and February 2025. Refer to Appendix A for definitions of finding
rankings.
B. BACKGROUND
The City’s SWMP is responsible for ensuring compliance with federal and state stormwater
regulations, maintaining drainage infrastructure, and reducing the risk of flooding and water pollution.
The program’s activities are spread across multiple departments, including:
DEPARTMENT/DIVISION DESCRIPTION
Water Services Department- Environmental Resources Division
● MS4 permit negotiations and planning
● MS4 permit compliance oversight and coordination
● Public education and outreach
● Municipal facility inspections
● Commercial/Industrial inspection program, including illicit discharge
investigations and enforcement
● Review of laboratory data for stormwater samples and quality assurance
of sample collection and analysis
● Oversight of “found waste” program (abandonment of hazardous waste
on City property)
● Reporting to the Arizona Department of Environmental Quality (annual
report, discharge monitoring reports, etc.)
Water Services Department- Stormwater Maintenance Division
● Maintain (inspect and clean) underground stormwater pipe network
● Outfall inspections, including dry weather screening/sampling
● Public education and outreach
● Illicit discharge investigations
● Contract management for drywell maintenance and wet weather sampling
Development Services
Department
● Maintain records and update geographic information system
● Receive development plans and coordinate reviews
Engineering Department ● Flood control and drainage master plan
● Review development plans, including grading and drainage plans
● Review Stormwater Pollution Prevention Plans for construction sites
● Inspect construction sites, including illicit discharge investigations and
Best Management Practices enforcement
● Capital Improvement Plan (CIP) program
● Post-construction warranty inspections
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DEPARTMENT/DIVISION DESCRIPTION
Code Compliance ● City Code inspection and enforcement program
● Public education and outreach
● Illicit discharge investigation and enforcement
Field Operations- Solid Waste Division
● Street sweeping
● Household Hazardous Waste collection events
Transportation Department ● Maintain streets and right-of-way, including associated scuppers,
retention basins, swales, channels, etc.
Parks and Recreation ● Maintain parks, including associated scuppers, retention basins, swales,
channels, etc.
Fire Department ● Response to spills of hazardous materials
● Fire Marshal inspection of commercial/industrial facilities storing/using
hazardous materials
To coordinate cross-functional SWMP work, the City uses a Stormwater Committee consisting of staff
representing their respective departments/divisions. The Committee meets on a monthly basis to
discuss the stormwater program and monitor the implementation of best practices associated with
MS4 permit requirements.
The City operates under an MS4 permit, which requires municipalities to implement best practices to
control pollutants in stormwater runoff. Compliance with MS4 regulations involves activities such as
street sweeping, drainage inspections, stormwater sampling, and public education programs. While
the City has implemented elements of a stormwater management strategy, the absence of a unified
cost-tracking system, structured preventive maintenance plan, and centralized asset inventory has
led to inefficiencies in program execution and financial oversight.
As the City’s stormwater program continues to grow and regulatory requirements evolve, improving
program coordination, financial oversight, and long-term maintenance planning will be critical to
sustaining an effective stormwater management strategy. This performance audit evaluates the City’s
current stormwater management framework, identifies key operational challenges, and provides
recommendations to enhance efficiency, compliance, and accountability.
C. OBJECTIVES
This performance audit’s objectives include:
• Evaluating the sustainability of funding mechanisms for stormwater management, including
capital improvements, maintenance, and compliance with MS4 permits.
• Reviewing stormwater asset management practices, including inventory management, clarity of
maintenance responsibilities across departments, and the effectiveness of current maintenance
practices in preventing system failures.
• Analyzing how stormwater costs are captured for areas serviced by non-City water providers.
• Comparing services, infrastructure, funding, and rates to similarly situated cities in the valley.
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D. SCOPE AND METHODOLOGY
To complete this performance audit, we conducted the following procedures:
• Interviews: We conducted interviews with 14 staff across multiple departments involved in the
City’s SWMP, including representatives from Water Services, Engineering, Transportation, Field
Operations, and Development Services. Interviewees included program managers, engineers,
field supervisors, and staff responsible for stormwater inspections, maintenance, and compliance.
• Document Review: We reviewed multiple documents, including but not limited to:
○ Organizational charts
○ Role matrices
○ Financial reports
○ MS4 permit guides and annual reports
○ Stormwater program management plans
○ Policies and procedures
○ Previous stormwater program assessments
• Benchmark Analysis: We engaged four peer cities (Chandler, Mesa, Scottsdale, and Tempe)
within the state of Arizona in benchmarking, requesting data, and conducting interviews to gather
information on a range of topics, including:
○ Stormwater program governance and coordination
○ Stormwater cost tracking and budgeting
○ Preventive maintenance and asset management
○ Stormwater infrastructure and capital planning
○ Regulatory compliance activities
Benchmarking results are provided in Appendix B: Peer Benchmarking
• Industry Best Practices Research: We conducted industry best practices research from entities
such as the Environmental Protection Agency (EPA) and scholarly published articles.
The performance audit was conducted between November 2024 and February 2025.
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III. FINDINGS AND RECOMMENDATIONS
A. STORMWATER FUNDING AND COSTS
Stormwater Funding Mechanisms – Medium Risk
1. Finding The City’s SWMP including maintenance, inspections, contractors, and
capital projects is funded through a variety of methods including sewer
revenue, general funds, and grants, and has thus far been able to meet
demands. Services funded through general funds and sewer revenues
struggle to compete with other municipal priorities, which presents a
future risk such as underfunding to the program.
Recommendations A. Evaluate options for implementing a stormwater fee, focusing on
updated conditions, potential benefits, and equity among residents.
B. Continue established practices of pursuing grant funding for
programmatic elements such as public outreach and capital
improvement.
Criteria
As recommended by the EPA, a stormwater fee is the most reliable funding mechanism to ensure the
stability and sustainability of stormwater management. A stormwater fee provides a dedicated
revenue stream by charging users fees based on their contribution to stormwater runoff, much like
electric or water utilities. This approach supports essential activities such as:
• Infrastructure development and maintenance
• Regulatory compliance
• Planning and capital improvements
• Repair and replacement
Condition
The City has dedicated utility fees for water and wastewater but does not have a standalone
stormwater fee that can be used to fund its SWMP. Multiple departments within the City contribute to
stormwater management through a range of coordinated activities, including infrastructure
maintenance, development plan reviews, and public education initiatives. The funding for these
activities is primarily sourced from departmental budgets, which are supported by a combination of
sewer fees, grants, and general funds. This decentralized funding structure makes it challenging to
capture the complete operational costs associated with the program and comprehensively assess the
sustainability of current funding. It also makes it difficult to ensure the program’s funding remains
sustainable in the long term.
A sources and uses analysis was conducted for the Stormwater Maintenance Division to assess—to
the extent possible— the sustainability of funding for the program. The analysis captured sources and
uses of funds channeled through the Water Services Department (WSD) but did not capture sources
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and uses for all departments that contribute to the program. This is due to the lack of comprehensive
cost tracking and allocation that could be used by each department to indicate which activities,
personnel time, equipment, or hours contribute to the stormwater program (see Observation 2: Cost
Tracking and Resource Allocation). When interviewed, personnel across the City reported that their
work is so interconnected to their role within the City as a whole that it would be difficult to segregate
costs. For example, street sweeping is an important part of the stormwater program as street
sweeping ensures that debris and pollution don’t enter the system. However, when asked how
changes in the City’s SWMP might impact street sweeping (such as frequency, routes, regulatory
compliance, equipment, and staffing) interviewees reported that this team’s work is minimally
influenced by the stormwater program.
Presented in the following table, stormwater program costs have increased incrementally year over
year, while sewer fund operating revenues have decreased.
DESCRIPTION FY 2022 FY 2023 FY 2024
Sources of Funds
Sewer Fund Operating Revenues $28,440,000 $27,260,000 $25,275,000
Sewer Revenue Allocated to the Stormwater Division $884,312 $963,265 $1,125,973
Uses of Funds
Water Services – Stormwater management salaries and benefits $463,749 $557,033 $807,513
Water Services – Stormwater management other
expenses $191,147 $196,988 $110,672
Infrastructure maintenance and improvements $177,217 $142,544 $9,533
Maintenance of City-owned drywells0F1 - - $115,546
Contractor for collection of stormwater samples $39,597 $52,097 $37,612
Contracted laboratory services for water quality
testing $2,369 $4,285 $2,831
Fees for ADEQ permit, truck permits, and STORM
affiliation dues $10,233 $10,318 $14,925
Supplies - - $27,340
Total Uses of Funds $884,312 $963,265 $1,125,973
Percent Change in Total Uses of Funds - 9% 17%
Percent Change in Sewer Fund Operating Revenues - 4% - 7%
1 Maintenance of City-owned drywells is a subcategory of infrastructure maintenance and improvements. This subcategory was
established in FY 2024.
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Though not comprehensive of all stormwater management-related costs and funding sources from
across the City, this analysis indicates that it will become increasingly difficult to fund the Stormwater
Maintenance Division of the WSD alongside other programs that are also funded through sewer
revenues. In the future, this could lead to an increased reliance on General Funds or other water
revenues to fully fund the SWMP.
Interviewed staff also reported that in some instances, their annual work plan or proposed projects
were limited to fit within known budget constraints. For example, if it’s known that the annual
maintenance budget is $35,000, the proposed maintenance projects will equal only that budget
amount in order to ensure that some maintenance activities can take place. This may not represent
the full scope of maintenance work that should occur and can give the illusion that current funding is
sufficient to cover programmatic needs when actual funding needs may be higher.
The City has conducted studies to assess the financial implications of implementing a standalone
stormwater utility fee. These studies analyze the City's financial forecasts and the potential impact of
a stormwater fee on maintaining and improving service standards. Presentations to City Council, such
as the one on February 11, 2025, have discussed these findings, indicating ongoing efforts to develop
a sustainable funding mechanism for stormwater management.
Peer Analysis
Stormwater program funding sources for peers are somewhat varied and can rely on any combination
of enterprise funds, general funds, or one-time funds, such as through grants. Three out of four peers
engaged have either a stormwater fee or an environmental fee that covers the cost of stormwater
management-related activities such as street sweeping, household hazardous waste collection, or
capital projects, outlined on the following page.
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TYPE GLENDALE CHANDLER MESA SCOTTSDALE TEMPE
Rate Effective
Date January 20241F2 January 2024 January 2024 January 2024 January 2024
Stormwater or
Environmental Fee
Proposed $3.00
per month
N/A $7.32 per
month
$8.10 per
month
$3.00 per
month
Customer
Type Single-Family Single-Family Single-Family Single-Family Single-Family
Wastewater/
Sewer Rate $12.402F3 –
Monthly Fee
Inside City Limits
$4.76 –
Volumetric
Charge Inside
City Limits
$27.65 –
Inside
City Limits
$44.24 –
Outside City
Limits
$24.11 – Inside
City Limits
$35.49 –
Outside City
Limits
$9.90 – 5/8
Meter Monthly
Charge
$5.94 –
Volumetric
Charge
$7.75 – 5/8
Meter Monthly
Charge
$2.25 –
Volumetric
Charge
$16.12 – Monthly
Fee Outside City
Limits
$6.19 –
Volumetric
Charge Outside
City Limits
Of peers that have an established stormwater or environmental fee, all peers use a flat rate per
customer, and two of three calculate the fee based on cost-recovery considerations, summarized as
follows:
• Mesa: The environmental fee is a flat rate, and each utility customer, regardless of water use,
property value, or the type of account, pays the same amount. The current fee has been
established to fully recover the costs of the federal and state regulatory mandates. Federal and
state environmental regulations change, and increased regulation may necessitate an increase in
the fee. Any future changes to this fee will have to be approved by City Council. The fee was first
implemented in 2007.3F4
2 Effective January 2025, the City proposed increases to their water and sewer rates. To maintain the comparability of the rate
analysis, 2024 data was used.
3 Rather than assessing the monthly fee based on meter size like Scottsdale and Tempe, Glendale adjusts its monthly fee
based on customer type. For example, single family, multi-family, laundromat, gas station, etc. Glendale also differentiates
between customers inside the City and outside the City. The comparative rates shown for Glendale, Chandler, and Mesa are
for single-family customers.
4 https://www.mesaaz.gov/Environment-Sustainability/Environmental
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• Scottsdale: Similar to Mesa, the stormwater fee is structured as a flat monthly charge of $8.10
per customer and is calculated to recover the costs of various stormwater-related expenses,
including Sewer Fund Operations and Maintenance (O&M), General Fund for Stormwater O&M,
and Drainage and Flood Control Capital Projects.4F5
• Tempe: The stormwater fee is also a flat rate and was implemented at $3.00 per account in 2022
to recover the full cost of stormwater infrastructure O&M. Since that time, costs have increased
while the $3.00 fee has remained flat, leading the current fee to recover approximately 82% of
stormwater costs.5F
6
Cause
The City has historically considered implementing a stormwater fee but has lacked sufficient
administrative capacity to plan, propose, develop, and implement one. The ability of the SWMP to
remain compliant with its MS4 permitting requirements has also contributed to the postponement of
adopting a stormwater fee. Additionally, the cost of the SWMP has been successfully sustained
through decentralized funding mechanisms. Now, however, WSD is looking ahead to large-scale
capital improvement projects and substantial increases in O&M expenses and construction costs.
This places stormwater funding in competition with these other projects, making it imperative for the
City to explore other revenue-generating options.
Effect
Funding availability and reliability for the City’s stormwater program is a dual narrative: While the
system is currently functioning and effectively managing stormwater—evidenced by the City’s ability
to maintain, renew, and comply with its MS4 permit—the City’s decentralized funding model has
contributed to challenges in tracking program expenditures, assessing total stormwater-related costs,
and determining whether available funding is sufficient to meet operational needs. This presents a
potential risk to effectively assessing the program’s long-term funding sustainability.
As urban development increases, so too does the complexity and cost of managing stormwater,
including the need for infrastructure maintenance, regulatory compliance, and environmental
protection efforts. Without a stable, reliable funding source, there is a risk of reduced program
effectiveness, potential degradation of stormwater management infrastructure, and risk of non-
compliance with MS4 permit requirements.
Recommendations
On February 11, 2025, the City conducted a Council workshop to review its five-year Water and
Wastewater Enterprise Funds forecast. The forecast revealed the need for additional financial
measures to ensure ongoing funding (including for stormwater) and proposed an initial stormwater
fee of $3.00 per account per month, beginning in October 2025, with a 5% increase per year for 2027
through 2030. The actual fee amounts and implementation may change based on public hearings,
further data analysis, and input from City Council. Revenue generated from this fee would go toward
maintenance of the City’s stormwater infrastructure. If this fee were to pass, it is anticipated to result
in $2.3 million in revenue for the program, reducing the program’s reliance on General and Sewer
5 https://www.scottsdaleaz.gov/docs/default-source/scottsdaleaz/planning---develpment/fees/stormwater-management-fee-
schedule.pdf?sfvrsn=64c5f14e_1
6 https://www.tempe.gov/home/showpublisheddocument/111018/638712513579970000
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Funds. A separate stormwater fee will provide a structure to manage, fund, and maintain the
stormwater program.
The City should continue to pursue adoption of the proposed fee. The flat-rate structure is consistent
with peers, and the proposed 5% increase per year starting 2027 through 2030 can help mitigate the
challenges faced by Tempe, which implemented a similar fee structure in 2022 but to date is able to
recover only 82% of stormwater costs through its fee.
Since stormwater fees are typically tied to specific services provided by the City, such as maintaining
stormwater infrastructure, they are generally classified as fees, not taxes. As a result, they do not
require voter approval. The Arizona Revised Statutes (ARS) § 9-500.03 allows cities to impose new
fees without voter approval, provided that the fee is for a specific service and the City follows required
procedures, including:
• Holding a public hearing to gather input from the community.
• Publishing notice of the proposed fee in advance of the hearing.
• Ensuring that the fee is reasonable and related directly to the service or program being funded (in
this case, stormwater management).
Arizona Constitution (Article 9, Section 14) limits the imposition of taxes and requires voter approval
for general taxes, but fees for services, such as stormwater management, are exempt from this
requirement on the condition that the fee is tied directly to the service it funds (in this case,
stormwater management infrastructure and related services).
At the local level, the City Charter outlines procedures for the implementation of new fees requiring
the City Council to:
• Approve new fees by a majority vote
• Conduct public hearings to solicit public input to ensure transparency
Alongside the adoption of a stormwater fee, the City should take active steps to roll out
comprehensive cost-tracking practices (see Recommendation 2: Cost Tracking and Resource
Allocation). This is a critical step to ensuring that the actual costs of the program are captured and
that revenue generated through the fee contributes to the program as a whole. As part of fee
implementation, the City will need to adopt formal policies regarding charges and fees. The
Government Finance Officers Association (GFOA) makes the following recommendations when
setting fee policy6F
7:
• Identify the factors (affordability, pricing history, inflation, service delivery alternatives, and
available efficiencies) to be taken into account when pricing goods and services.
• State whether the jurisdiction intends to recover the full cost of providing goods and services. Set
forth under what circumstances the jurisdiction might set a charge or fee at more or less than
100% of the full cost. If the full cost of a good or service is not recovered, then an explanation of
the government’s rationale for this deviation should be provided.
7 https://www.gfoa.org/materials/establishing-government-charges-and-fees
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• Outline the considerations that might influence governmental pricing decisions. Such policy
concerns might include the need to regulate demand, the desire to subsidize a certain product,
competition with private businesses, economic development, the elasticity of demand for the
particular service, and visibility of the service to the community.
• The specifics of how the fees and charges will be levied and collected should be a consideration
when developing policy.
In 2030, the City should reevaluate how the fee is calculated and consider adopting a methodology
similar to that of Scottsdale and Mesa, where the costs of the stormwater program are used to
calculate the fee. This is also a practice recommended by GFOA7F8. The Glendale City Code (Title 33 –
Water and Wastewater) outlines specific rules for managing water and wastewater systems, which
include stormwater management. These regulations could help guide how new fees (such as a
stormwater fee) should be calculated, applied, and adjusted.
The City should also continue to pursue additional sources of funds for major capital projects.
Revenue generated through the fee can be an important factor in securing additional grant funds, as
several options often require a match. Consistent with peers, the City should continue to anticipate
that some costs for the stormwater program will continue to come from General Funds.
MANAGEMENT RESPONSE
Management
Agreement Concur
Owner Initially, the Water Services Department
Target Completion
Date 12/31/2025
Action Plan
Council to vote on establishment of a stormwater fee on 6/24/2025. If approved,
the fee will be implemented 1/1/2026. See full management action plan in
Appendix C.
8 Ibid.
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Cost Tracking and Resource Allocation– Low Risk
2. Finding The City does not have a framework to distinguish stormwater program
work from routine departmental functions. While stormwater
responsibilities are spread across multiple departments, there is no
unified system for tracking work hours or budgets dedicated
specifically to the SWMP.
Recommendations A. Develop a unified tracking system for stormwater-related hours,
materials, and budgets, designed to integrate with existing
workflows and minimize administrative burden.
B. Aggregate all stormwater costs, including internal labor and
contracted services, into a single budget to identify funding gaps
and secure stable funding sources, such as stormwater fees.
Criteria
Municipal programs that rely on multiple departments for service delivery should implement structured
tracking mechanisms to accurately report labor hours, material costs, and project expenditures.
Effective cost-tracking frameworks allow agencies to monitor resource allocation, evaluate program
efficiency, and ensure compliance with regulatory obligations.
Best practices in municipal stormwater management recommend categorizing stormwater-related
labor separately from general departmental functions, using standardized reporting processes to
distinguish regulatory compliance activities from routine operations. The EPA’s MS4 guidance
outlines the importance of tracking stormwater-specific activities to demonstrate compliance and
assess program performance.
Between 2021-2022 the City engaged a third-party to conduct a stormwater maintenance plan and
utility feasibility evaluation as part of its integrated water master plan. The results of the evaluation
were reported in the 2022 Technical Memorandum – Stormwater Utility Feasibility Evaluation and
were reviewed as part of this engagement. The memorandum reviewed cost accounting processes
for SWMP and recommended establishing dedicated cost-tracking tools to improve transparency and
financial oversight, ensuring that staffing and contract costs align with permit requirements and long-
term operational needs. The recommendations in the memorandum are consistent with
recommendations that would be included in this report and can be referenced for additional details to
guide implementation efforts.
Condition
The City does not have a structured framework to differentiate stormwater management activities
from routine departmental functions. While multiple departments contribute to stormwater efforts,
there is no unified system to track labor hours, project costs, or budgets specifically dedicated to
stormwater compliance and operations.
Stormwater-related work—such as drainage inspections, flood response, and pollution control—is
funded, managed, and reported as part of general departmental operations without being identified as
stormwater-specific costs. Additionally, there is no centralized accounting process to consolidate
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internal labor, contracted services, or materials used for stormwater management, preventing the City
from determining the full cost of the program.
Although stormwater responsibilities are spread across several departments—including Water
Services, Engineering, Transportation, Field Operations, and Development Services—the City does
not have a mechanism to track and report their collective stormwater-related efforts.
Peer Analysis
Other municipalities have established structured processes to track stormwater-related work hours
and budget expenditures separately from general departmental functions.
• Chandler tracks costs specifically related to MS4 permit compliance, similar to Tempe,
distinguishing stormwater management expenses from general public works operations.
Departments report hours spent on stormwater activities. This ensures that the City has an
accurate understanding of the resources allocated to stormwater regulatory requirements.
• Mesa tracks stormwater program expenses through annual budget reports that provide a line-
item breakdown of personnel costs, maintenance expenses, and compliance-related
expenditures. The program is funded through the Environmental Compliance Fee (ECF),
revenues which are managed by the City Manager and budget office. Any program or department
that conducts qualifying activities can access ECF funds. Expenses are reported annually through
the ECF fund. The report includes all personnel and materials costs associated with the
Environmental Services Division stormwater staff activities, parks basin maintenance, streets,
transportation, and stormwater infrastructure maintenance, street sweeping, illegal dumping
cleanups, and the household hazardous materials facility.
• Scottsdale also tracks stormwater expenditures separately from general department operations
through the stormwater fee. As part of the fee calculation, Scottsdale allocates certain portions of
its fee to various programs including Sewer Fund for O&M related to stormwater ($0.30), General
Fund for O&M related to stormwater ($0.85), and Drainage and Flood Control capital projects
($6.95), ensuring that stormwater-related costs are allocated and reported independently.
• Tempe requires all departments that implement stormwater programs to report annual
expenditures and funding sources to ensure that stormwater-related costs are accurately
accounted for. This process allows the City to separate stormwater expenditures from other
operational budgets and provides a clear summary of program costs to the Arizona Department
of Environmental Quality (ADEQ). Departments report staff time, equipment, developer fees,
permit fees, contract services, O&M costs, outreach materials, dues, and staff salaries.
Peers like Mesa and Scottsdale, which have a stormwater fee that is calculated based on operational
considerations like O&M, staffing, or capital projects, track their costs entirely through the dedicated
fund. Between these two, there are slight differences in fund administration. Whereas Mesa’s
program funding is entirely managed through the budget office, Scottsdale’s program funding is
distributed to different funds according to the fee breakdown, and then each department manages its
portion.
Cause
The City’s stormwater management activities evolved without a structured framework, resulting in
responsibilities being distributed across multiple departments. Because stormwater work is
embedded within daily operations, there is no standardized method for differentiating tasks performed
to maintain compliance with stormwater regulations from routine maintenance activities.
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As a result, departments fund, manage, and report stormwater-related work as part of their general
operations, without isolating stormwater-specific labor hours or costs. This lack of differentiation has
prevented the City from establishing a unified system to track stormwater work hours, project costs,
or budget allocations, making it difficult to determine the total cost of stormwater management efforts.
Effect
The absence of a structured framework to track stormwater labor hours and project costs has
resulted in an incomplete understanding of the total cost of the City’s SWMP. Without centralized
tracking, the City cannot determine how much of its budgeted funds directly support stormwater
efforts, making it difficult to evaluate whether current funding levels are adequate to sustain the
program.
A lack of work-hour tracking also prevents the City from assessing whether staffing levels align with
stormwater program needs. Since FY 2022, 34.75 positions have been added across departments
involved in stormwater management, yet the City has no mechanism to determine how many of these
positions support stormwater-specific responsibilities. As a result, the City cannot evaluate whether
additional staffing has improved compliance, maintenance efficiency, or overall program effectiveness
(see also Finding 6: Roles and Responsibilities). Similarly, the lack of a centralized cost-tracking
system complicates contract management and compliance monitoring. While the City has budgeted
funds for services such as drywell maintenance ($115,000/year) and stormwater sampling
($50,000/year), there is no consolidated record of stormwater-related contracts. This limits the City’s
ability to assess whether contracted services align with MS4 permit requirements. Without a tracking
framework, the City cannot accurately assess stormwater program performance or forecast future
needs.
Recommendations
To improve the City’s ability to track and assess stormwater program costs, the City (including
departments that are involved in stormwater management as well as finance, and others as relevant)
should implement a structured approach to tracking labor hours, materials, and budgets. Establishing
a centralized system will provide clarity on resource allocation and ensure that funding decisions align
with program needs. This will be an important process to develop over the next three years as the
City implements a stormwater fee. Effective documentation and justification of costs related to
stormwater program activities funded by user fees are critical for the successful establishment of a
stormwater utility. At present, the WSD is the sole department actively monitoring expenses
associated with stormwater management. As the City continues to distribute stormwater management
duties across various departments, it is essential to create standardized processes for documenting
and tracking all expenses tied to the program. These expenses will be fundamental in determining
future revenue needs. Even capturing costs that are not expected to be recouped through a
stormwater fee will help highlight the importance of securing a sustainable funding source for
stormwater management.
It is recommended that all departments responsible for stormwater management implement
consistent processes and procedures for tracking and reporting all relevant costs, including
personnel, contracts, materials, supplies, equipment, and capital expenditures. Utilizing work order
management systems, such as CentralSquare, can be particularly beneficial for this purpose,
provided that staff actively engage with the system and consistently log the necessary information for
all tasks. Alternative tracking tools and spreadsheets are also acceptable if staff regularly enter the
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required data. The Stormwater Committee should establish periodic reviews of the stormwater
resource documentation, ensuring that resources are tracked in real-time or as closely as possible.
Establishing and applying these tracking procedures in the near future is vital for accurately
determining the total program costs and revenue requirements, which will support justifications for the
stormwater fee and future increases. Without effective tracking systems in place, efforts to develop a
user fee may encounter challenges due to insufficient service level and cost information. Core
elements that can be used to build the framework include:
• Cost Categories (operating, capital, variable, fixed, project-specific costs)
• Department or Service Areas (where costs are being tracked)
• Detailed Cost Codes (for accurate classification of expenses)
• Budget versus Actual Comparisons
• Time Tracking (if labor costs are included)
• Invoices and Contracts (for vendor or contractor costs)
Formalizing each department’s roles and responsibilities (see Recommendation 6: Roles and
Responsibilities) will be a helpful step when developing this framework. Gathering updated
information on how each department is supporting the program will facilitate the fair and accurate
distribution of funds to departments contributing to the program. This can help avoid disputes or
competition over funds. There are several supportive documents that can also help in this effort; most
recently, the 2022 Technical Memorandum – Stormwater Utility Feasibility Evaluation provided an
overview of how costs could be captured and calculated across departments. This memorandum
contains information that can form the basis of future discussions with the Stormwater Committee and
supporting departments.
To help increase the likelihood of adoption and minimize administrative barriers, the system should
be integrated into existing workflows such as each department’s budget, reporting, or timekeeping
processes. To further support the implementation and adoption of the new processes, the City
should:
• Aggregate Stormwater Costs into a Single Budget. To improve financial oversight, the City
should establish a comprehensive budgeting approach that consolidates all stormwater-related
costs, including internal labor, contracted services, and materials, into a single stormwater
budget. A clear and unified budget will provide visibility into program expenditures, allowing the
City to identify funding gaps and ensure that financial resources are allocated effectively.
• Enhance Interdepartmental Coordination and Reporting. To ensure consistent and accurate
stormwater cost tracking, the City should formalize roles and responsibilities for cost tracking and
reporting across departments. Establishing clear expectations will help prevent inconsistencies in
how costs are reported and categorized.
• Provide Training: Providing training and guidance on cost-tracking procedures will ensure that
all departments apply a standardized approach, improving the reliability of financial data and
long-term planning efforts.
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MANAGEMENT RESPONSE
Management
Agreement Concur
Owner Stormwater Executive Committee (SwEC)
Target Completion
Date Establish the SwEC by 8/1/2025. Implement a solution by 7/1/2026.
Action Plan See full management action plan in Appendix C.
Cost Capture West of 115th Avenue – Low Risk
3. Finding The City provides stormwater management services for the area west of
115th Avenue. However, because residents and businesses in this area
are served by private water and sewer providers, they do not pay City
water or sewer fees—which fund stormwater maintenance. While they
don’t contribute to this system through water fees, they do pay City
taxes that go into the general fund, which supports other aspects of the
City’s stormwater program.
Recommendation If the City were to pursue the setup of a stormwater fee, it could recover
the cost of stormwater services to the area. If not, the cost of the
program will need to be incorporated into future rate and tax studies.
Criteria
Funding should ensure that residential, commercial, industrial, and institutional groups benefiting from
stormwater services, regardless of location or water/sewer provider, contribute proportionally to the
costs of managing runoff and maintaining infrastructure, avoiding inequities and funding gaps.
Condition
The City provides stormwater services for areas west of 115th Avenue, but residents and businesses
in these areas do not fully contribute to stormwater funding because they receive water and
wastewater services from private providers rather than the City. Private providers include:
• EPCOR
• Valley Utilities
• Liberty Utilities
• Adaman Water
The City’s SWMP is funded through a variety of mechanisms, outlined in Finding 1, including sewer
fees, general funds, and other fees collected through contributing departments. Residential,
commercial, industrial, and institutional groups west of 115th Avenue are not subject to the City’s
sewer fees, which would be used to fund stormwater maintenance. Additionally, the area west of
115th is also served by a private trash provider and does not pay trash fees to the City, which would
also partially contribute to the costs of the SWMP. Therefore, the cost of managing stormwater in
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these areas is largely subsidized by sewer and trash and paying customers east of 115th Avenue.
These areas do pay City taxes that contribute to the City’s general funds, which does help fund the
City’s SWMP.
Peer Analysis
Among the peer cities, none provide stormwater program coverage for areas outside of their standard
utility service boundaries. Municipal stormwater services are typically funded through dedicated fees
or general fund allocations, and peer cities do not extend program resources to areas that do not
contribute financially to stormwater management. Mesa does not provide stormwater services to
areas where a stormwater, water, or sewer fee is not collected, ensuring that stormwater program
costs are tied directly to revenue sources. Similarly, Chandler, Scottsdale, and Tempe limit
stormwater services to areas within their established service boundaries, aligning program
responsibilities with defined funding mechanisms.
These peer city practices reflect a common approach to stormwater service provision, where program
funding and service coverage remain linked directly. Unlike the City, which currently provides
stormwater management services to areas outside of its utility coverage, peer cities do not assume
financial responsibility for areas that are not incorporated into their stormwater funding structures.
Cause
Property owners west of 115th Avenue receive water and sewer services from private providers and,
as a result, do not contribute to the sewer rates that fund the City’s SWMP. This exclusion creates a
funding gap and limits equitable contributions from residential, commercial, industrial, and institutional
groups benefiting from stormwater services.
Effect
The current funding structure creates an equity issue, as property owners east of 115th Avenue bear
complete financial responsibility for the stormwater maintenance program, despite all residents,
businesses, and visitors benefiting from the services. The exclusion of property owners west of 115th
Avenue from contributing to the stormwater maintenance program creates a risk that the long-term
maintenance of stormwater assets in that area will become inadequately funded. This funding gap
threatens the City’s ability to sustain infrastructure and address future maintenance needs effectively.
Recommendation
If the City adopts a stormwater fee, effective January 2026, it will help fund the cost of providing
stormwater management services, as the fee will apply to all residents and businesses within the
municipal planning area. The challenge for the City will be in the additional administrative logistics
required to collect the fee from residents and businesses that are not currently part of the system.
Implementing a stormwater fee in an area served by a private water provider has some administrative
complexity since the City doesn’t have established infrastructure for the area to identify parcels, send
bills, or collect fees. Here are key administrative considerations the City should keep in mind across
the major operational areas:
• Review the City’s GIS data to ensure all properties are accounted for (including residential,
commercial, tax-exempt, etc.). Consider coordinating with the County Assessor’s office to get
accurate ownership and property class information.
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○ Consider adding impervious surface data for fair and consistent fee calculation (this could be
based on equivalent residential units or similar methods).
• Work with the finance team and/or customer service departments to leverage current utility billing
systems and processes and identify opportunities to integrate the new fee into existing workflows.
○ Depending on the system and staffing capabilities, consider less frequent billing cycles (such
as quarterly or annually) during the implementation period to reduce the total volume of
transactions. This could have a negative impact on customers who may be more comfortable
with a more frequent but lower overall bill.
• The City should review enforcement and collections policies to ensure that the teams responsible
for following up on non-payment understand changes to their volume or scope of work.
○ Appeals processes should also be reviewed and updated as needed.
• Changes should be supported by robust communication and change management best practices
that include information on what to expect for community members as well as staff.
If the City does not adopt a stormwater fee, it should integrate stormwater funding needs into future
water, sewer, highway, and other rate and tax studies to ensure equitable cost distribution. Part of the
approach should include a financial impact analysis to determine current and projected stormwater
costs for areas west of 115th Avenue. This analysis should determine how best to capture stormwater
program costs for areas west of 115th Avenue and consider alternative funding mechanisms, such as
tax-based models or development impact fees. Based on this analysis, the City can update its long-
term funding strategy to ensure financial sustainability.
MANAGEMENT RESPONSE
Management
Agreement Concur
Owner Stormwater Executive Committee
Target Completion
Date 1/1/2026
Action Plan See full management action plan in Appendix C.
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B. PROGRAM AND ASSET MANAGEMENT
Centralized Asset Management – Medium Risk
4. Finding The City uses CentralSquare as a centralized asset management
system, but many departments also use shared spreadsheets and cloud
software to track assets. This approach has left the stormwater asset
inventory incomplete, with critical details—such as ownership,
maintenance responsibility, type, material, condition, and size—often
missing or inaccurate.
Recommendations A. The City should continue its initiative to address deficiencies in
CentralSquare and establish this as its system of record for
stormwater assets.
B. Develop an asset management framework to guide decentralized
asset management tasks across departments.
Criteria
Asset management, according to the International Organization for Standardization (ISO), is the
coordinated activity of an organization to maximize value from assets. Asset management practices
maximize service while minimizing total life-cycle costs from focused and anticipated resource use
when acquiring, operating, maintaining, and renewing assets, including infrastructure.
To ensure efficiency and regulatory compliance, best practices include documenting essential asset
details such as ownership, maintenance responsibility, type, material, condition, and size. Regular
validation of asset inventories helps address data gaps and inaccuracies, while condition and
criticality assessments guide maintenance priorities and cost estimates. Ongoing monitoring and
adjustments keep the asset management plan aligned with evolving operational needs and
community expectations. By following these practices, organizations can enhance decision-making,
improve compliance, and maintain an effective stormwater management system8F9.
Condition
The City lacks a comprehensive framework to guide stormwater infrastructure asset management
activities across the City, including inventory, prioritization, maintenance, risk management, reporting,
and performance monitoring. Instead, stormwater asset management responsibilities are distributed
across various departments. The City’s storm drainage system is comprised of both underground
(storm sewer system) and surface (basins, washes, channels, culverts, spillways, and associated
assets) drainage infrastructure. The WSD stormwater maintenance team is responsible for storm
sewer system maintenance, and Engineering, Transportation, Parks and Recreation, and Special
Events (PFRSE), and Development Services all have roles in maintaining drainage assets.
The City maintains its inventory of its stormwater assets across a variety of systems, including
Geographic Information System (GIS) and CentralSquare, as well as tools such as Excel
9 https://www.stormwater.com/transportation-and-construction/runoff/article/55018130/asset-management-the-critical-missing-
element-in-stormwater
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spreadsheets and Smartsheet. Each department uses its preferred system to track and manage data
independently and the data captured within these platforms varies in detail and completeness, with
some information being outdated or lacking necessary granularity (such as physical characteristics,
purchase date, installation date, maintenance/repair history, condition, warranty information, cost, and
location). Annexations on the west side of the City have introduced new assets, such as channels,
which have not yet been fully integrated into the GIS system. Documenting these assets and
assigning maintenance responsibilities remains an ongoing process.
Along with differences in how stormwater assets are inventoried, each system is used to manage
different parts of the asset management program, including work orders, repairs, maintenance, and
inspections. CentralSquare is primarily used for processing work orders, while GIS is used for
planning inspections. Other platforms are used to track departmental maintenance, repairs, or
replacements. Informally, each department is responsible for managing the assets it’s responsible for
inspecting, maintaining, repairing, or replacing; however, as noted in Observation 6: Roles and
Responsibilities, the City has not formalized a framework for how roles and responsibilities are
defined, and the City has not consistently assigned ownership over its stormwater assets.
There are some standard operating procedures (SOPs) to guide the frequency of inspections that
would inform maintenance plans, and the requirements outlined in the MS4 permit also include some
guidance on how often assets should be inspected and maintained. Due to staffing limitations, the
WSD has had to scale back the scope and frequency of these inspections to meet the minimum
requirements outlined in the permit. This reduction in inspection activity further complicates the City’s
ability to monitor asset conditions effectively and respond to maintenance needs in a timely manner.
Compounding these issues, many stormwater assets transition between City property and private
property, including those managed by homeowners’ associations (HOAs). This overlap creates
ambiguity in defining ownership and maintenance responsibilities, making it challenging to collect
accurate data.
As part of the City’s MS4 permit, the City reports on its total asset inventory, which can be a manual
and time-consuming process to gather information from all departments. Other than its annual
reporting on total assets, the City does not produce other consolidated asset management reporting.
This absence of centralized reporting means that there is no cohesive overview of asset conditions,
replacement schedules, or maintenance planning. Furthermore, the City does not have a robust
preventive maintenance plan in place (see Observation 5: Preventive Maintenance), which is crucial
for prolonging asset life and ensuring reliable service delivery. The City also lacks effective cost-
forecasting methods, making it difficult to plan for future maintenance needs and allocate resources
appropriately. This gap in planning and strategy further complicates the City’s asset management
efforts and limits its ability to respond proactively to asset-related challenges.
Peer Analysis
All other peers track stormwater infrastructure through a GIS platform, and three of four peers also
use CentralSquare to track stormwater assets. All peer cities rely on multiple departments to update
asset data in the respective system but have clearly defined workflows that outline roles,
responsibilities, and expectations for where, when, how, and what information is updated. This is
connected closely to how roles and responsibilities for stormwater management are defined within the
respective City. For example, Chandler uses CentralSquare for asset management and GIS for
mapping. The public works and streets departments are responsible for tracking and managing
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stormwater assets in CentralSquare during their regular inspections of public assets. For construction
inspections, municipal facility inspections, and monitoring of illicit discharges, Chandler’s
Environmental Management team uses Survey 123, a tool to facilitate data collection and reporting.
For its post-construction program, GIS data is integrated with CentralSquare, where inspectors
conduct site visits to verify the asset and catalog it in the system.
Cause
The absence of a comprehensive asset management framework and low levels of adoption of
CentralSquare have contributed to the City’s challenges in effectively managing its stormwater
assets.
As demonstrated by peers, asset management should be a collective effort where multiple
departments are able to access and manage assets within established systems. Consistent with any
decentralized strategy, it’s most effective when there are clear guiding documents that outline the
roles, responsibilities, and expectations of how assets will be inventoried and managed across
departments. Now that the City is looking to adopt a stormwater fee, it has become increasingly
important to standardize how stormwater assets are tracked and managed across departments. This
is an opportune time to revitalize efforts to formalize a comprehensive and cohesive inspection and
maintenance framework. Clear and consistent expectations for inspections and reporting can help
ensure that important department needs are captured in the system. With a more fulsome picture of
total program needs, WSD and the City can engage in strategic prioritization of projects and
spending, contributing to improved system health.
When the City adopted CentralSquare (formerly Lucity) as its asset management system, it made an
initial effort to catalog all City assets and centralize management. Interviewees report that limitations
in the system functionality caused teams to revert to previous asset management strategies (such as
through spreadsheets or other platforms). The City has also invested significant effort into updating its
GIS data to include a full, as-built, drainage system inventory for its stormwater infrastructure.
Interviewed staff report that while considerable progress has been made, there are ongoing
discoveries of stormwater pipelines from past projects and that GIS data is continuously updated.
Similar to the data captured in CentralSquare, there can be varying levels of detail and information
captured in the GIS layer.
Effect
Without standardized practices, different departments may approach asset management
inconsistently, leading to disparities in asset tracking, maintenance scheduling, and lifecycle
management. This fragmentation can create silos of information, where each department has its own
set of data and procedures, making it difficult to gain a comprehensive view of the City’s overall asset
portfolio. This lack of coordination can result in duplicated efforts, missed maintenance opportunities,
and inefficient use of resources, ultimately increasing operational costs and jeopardizing asset
performance.
A lack of integrated asset data and performance monitoring is limiting the City’s ability to evaluate
infrastructure needs and forecast capital improvement requirements. Incomplete asset data increases
the risk of the City being unaware of assets under its responsibility. If an untracked asset fails, it could
lead to non-compliance with stormwater regulations and negatively impact residents through issues
such as flooding or water quality problems. Inaccurate asset data limits the City’s ability to make
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informed decisions about capital improvements or preventive maintenance, which could lead to
growing deferred maintenance (see Observation 5: Preventive Maintenance) or inefficient allocation
of resources. Without comprehensive tracking of asset condition and maintenance history, the City is
unable to track the complete cost of the stormwater program and make investments effectively.
Recommendation
System
To revitalize efforts in adopting CentralSquare, the City could benefit from reconnecting with
neighboring cities that also use the platform. By engaging with three peer cities that have successfully
implemented CentralSquare, the City can arrange walkthrough sessions to gain firsthand insights into
their experiences and best practices. These collaborative walkthroughs would allow City
representatives to observe how other cities have configured and customized the system to meet their
specific needs. Additionally, it would provide an opportunity to address common challenges, such as
data integration, workflow automation, and reporting features, with input from cities that have
overcome similar obstacles.
In addition to these walkthroughs, the City could explore specific configurations and functionalities
that may enhance the effectiveness of CentralSquare. For example, peers may have developed
unique workflows or automated processes that could streamline operations or improve data accuracy
and accessibility. Understanding how these configurations contribute to the success of the program in
other cities could serve as a model for adapting CentralSquare to better fit the City’s objectives.
Ultimately, this peer collaboration will help refine the adoption strategy, ensuring that the system is
configured to maximize its potential and improve operational efficiency across departments.
To support the adoption internally, the City should prioritize comprehensive training and ongoing
support for staff at all levels. Ensuring that employees are well-equipped with the knowledge and
skills to navigate the system is critical for its success. This could involve scheduling hands-on training
sessions, creating user-friendly documentation, and offering personalized support during the
transition period.
Asset Management Framework
First, the City should determine what asset management policies, procedures, or practices (both
informal and formal) are already in place or what may exist at the Citywide level that would either
influence the development of a program for stormwater assets or could be used as the foundation for
the development of a stormwater asset management program.
Based on the results, WSD should develop an asset management program for its stormwater
infrastructure that is consistent with any established Citywide practices. The American Public Works
Association (APWA) provides a comprehensive framework for developing an asset management
program that focuses on optimizing the performance of public infrastructure. APWA’s
recommendations for creating an asset management program include the following elements:
• Asset Management Policy: The City should prioritize the development of a comprehensive,
City-wide asset management policy to guide the long-term maintenance, replacement, and
investment in public infrastructure. However, recognizing that creating such a policy is a
significant undertaking that may take time, WSD, and the Stormwater Committee should move
forward in the interim by establishing an asset management policy specifically for stormwater
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infrastructure. This program-level policy will help ensure that stormwater assets are properly
tracked, assessed, and maintained while the broader City framework is being developed. Once
the City-wide policy is finalized, the stormwater asset management policy can be updated to align
with it—either serving as a complementary document tailored to stormwater needs or being fully
integrated into the City’s overarching asset management approach.
• Clear Goals and Objectives: Specific goals for the asset management program, such as
improving service delivery, reducing costs, or extending asset life cycles, should be realistic,
achievable, and supported by performance measures and reporting. These goals should also
align with broader City objectives.
• Asset Management Team: The City has an established Stormwater Committee composed of
representatives from various departments. The responsibility for overseeing the implementation
and continuous improvement of the asset management program can be incorporated into this
committee’s agenda. As needed, individuals from Finance or IT can be engaged or informed to
make sure the program is feasible.
• Asset Inventory and Condition Assessment: Develop and communicate the standard by which
all assets should be cataloged, including their location, condition, owner, cost, and criticality. This
will be a critical endeavor for the City. The success of this effort will have far-reaching
implications, determining whether the City will be able to track total stormwater program costs,
cost recovery calculations from the proposed stormwater fee and future increases, preventive
maintenance planning, capital project planning, and financial forecasting.
• Lifecycle Management Plans: For each asset type, develop a lifecycle management plan that
outlines when maintenance, repairs, or replacements will occur, based on the asset’s age,
condition, and performance. These plans should focus on optimizing the lifecycle of assets to
maximize value and minimize costs (see Recommendation 5: Preventive Maintenance).
• Performance Metrics and Monitoring: Define performance metrics to assess the effectiveness
of the asset management program. These could include asset condition scores, maintenance
costs, downtime, and service delivery levels. Regularly review and analyze performance to
identify areas for improvement.
• Promote Communication and Training: Ensure that staff at all levels are trained in asset
management practices and tools, and promote clear communication between departments and
stakeholders. This helps to ensure consistency and accountability throughout the program.
These steps will enable the City to proactively manage stormwater assets, reduce risks of system
failures, and ensure long-term compliance and sustainability. There are several supportive
documents already in place that can help inform the program, including MS4 permit requirements,
SOPs, and best maintenance practices from the 2022 Technical Memorandum – Stormwater Utility
Feasibility Evaluation. Together, these documents outline the regulatory requirements and best
practices for maintenance, inspections, and information management.
The outcome of the asset management program should enable the City to address the Fundamental
Themes of Asset Management recommended by the APWA as illustrated in the following figure9F10:
10 https://www.apwa.org/resource/introducing-the-apwa-asset-management-road-map-and-best-practices/
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MANAGEMENT RESPONSE
Management
Agreement Concur
Owner Multiple departments.
Target Completion
Date Initial date 1/1/2027
Action Plan See full management action plan in Appendix C.
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Preventive Maintenance – Medium Risk
5. Finding The City’s stormwater asset management program lacks a centralized
preventive maintenance plan that addresses all program aspects. While
efforts like the 2023 Outfall Prioritization and Inspection Standard
Operating Procedure and Water Services Division-Stormwater
Management rotational inspection schedule exist, they are limited in
scope. This gap results in reactive maintenance, deferred repairs, and
reliance on emergency responses, increasing costs, risks of regulatory
non-compliance, and threats to public safety and water quality.
Recommendation Develop a preventive maintenance plan that consolidates regular
inspections and maintenance schedules and prioritizes maintenance
work based on asset condition and criticality.
Criteria
Preventive maintenance plans are proactive measures that outline regular inspections, scheduled
upkeep, and standardized maintenance procedures to prevent system failures. A comprehensive
maintenance strategy helps reduce reliance on reactive repairs and emergency responses, ensuring
the entire infrastructure remains in a state of good repair. Best practices emphasize proactive
inspection schedules, systematic maintenance tracking, and coordinated response planning to
minimize service disruptions and reduce long-term costs.
Condition
The City’s SWMP lacks a comprehensive, centralized preventive maintenance plan that
encompasses all aspects of the program. While efforts such as the 2023 Outfall Prioritization and
Inspection SOP, WSD-SWM’s rotational inspection schedule, and the Stormwater Monthly Inspection
spreadsheet provide some structure to inspection planning, these documents do not address the full
scope of the City’s stormwater maintenance needs and do not capture the cost, condition, or risk level
that could be used to proactively maintain, or repair stormwater infrastructure.
The City’s ability to develop a preventive maintenance plan for its stormwater assets hinges on its
ability to centralize its data and standardize roles, responsibilities, and expectations for asset
management (see Observation 4: Asset Management). Until information is centralized, there will be
significant barriers to the City’s ability to conduct comprehensive preventive maintenance planning,
likely perpetuating the current state where comprehensive preventive maintenance planning is limited
or does not take place.
A key challenge for the stormwater program has been the availability of funds and personnel to carry
out planned inspections, repairs, maintenance, and replacements. Notably, interviewed staff
commented that maintenance and inspection plans have been reduced to fit within available staffing
and funding. The City is able to meet its permit requirements but has had to reduce the frequency of
its planned inspections or limit the scope of its inspections. As a result, preventive maintenance and
inspections are deferred, which places the City at a heightened risk of costly equipment failures. This
also forces the stormwater program into a reactive position where maintenance work is postponed
until issues of higher priority are solved first. Departments responsible for stormwater maintenance
operate without a unified set of protocols, leading to differences in how assets are inspected,
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maintained, and documented. There is no formal system to ensure that all stormwater infrastructure
receives preventive maintenance at appropriate intervals, and maintenance activities are generally
determined on an as-needed basis rather than through a structured plan.
Peer Analysis
Peer cities have somewhat varied preventive maintenance planning activities, outlined in the following
table:
CITY PREVENTIVE PLANNING
Chandler Similar to Glendale, the city is divided into Fire Maintenance Areas (FMAs), each covering a
quarter-mile section. Stormwater assets in each FMA undergo annual inspections, and
identified maintenance needs are scheduled for repair. Chandler’s inspection schedule is
informed by its MS4 permit requirements.
Mesa Preventive maintenance planning is integrated into the city’s GIS-based asset management
system. Mesa assigns multiple departments—such as Development Services,
Transportation, and Budget—to track and update asset conditions, ensuring that deferred
maintenance is recorded, prioritized, and addressed as part of an ongoing maintenance
strategy.
Scottsdale Preventive maintenance and CIP planning is split between the Water Quality team and the
Stormwater and Floodplain Management team. All other departments are responsible for
maintaining their assets in Scottsdale’s GIS.
Tempe Tempe incorporates preventive maintenance into its larger maintenance program, ensuring
that stormwater assets are managed alongside other municipal infrastructure. There is an
engineer who manages Tempe’s CIP program and helps determine which stormwater
projects to include in the plan.
Cause
The absence of a stormwater asset management framework to guide how, where, and when assets
are tracked and managed across departments involved in the stormwater program (see Observation
4: Asset Management) has led to data gaps and inconsistencies, making comprehensive preventive
maintenance planning infeasible. Without consistent data entry and reporting, the City lacks the ability
to systematically track maintenance needs, fund maintenance activities, monitor deferred
maintenance, and coordinate maintenance efforts across departments.
The funding mechanisms have also contributed to the lack of comprehensive multi-year preventive
maintenance planning. Since the stormwater program does not have a dedicated funding source,
there is little incentive to centralize preventive maintenance. Instead, when the work that a
department contributes to stormwater management is integrated into its regular operations and not
disaggregated to outline which activities are specific to the program (see Observations 2, and 6) each
department would reasonably develop plans and fund maintenance independently.
Effect
Without centralized preventive maintenance planning, the City will continue to struggle to
comprehensively understand the scope and cost of its stormwater program and strategically prioritize
maintenance and repair activities that take advantage of economies of scale. This has far-reaching
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consequences for the City’s ability to manage its assets effectively and sustainably. Without a long-
term strategy in place, maintenance activities have become reactive, responding to issues only as
they arise rather than preventing problems before they occur. The lack of a centralized approach also
means that critical maintenance tasks may be delayed or overlooked, increasing the risk of system
breakdowns, such as blocked drains or flooding, particularly in high-risk areas. The City may end up
facing emergencies that require costly, expedited repairs, straining resources and impacting the
ability to allocate staff or funding to other important areas.
Additionally, the absence of a multi-year preventive maintenance plan hinders the City’s ability to
forecast and manage costs. Without a comprehensive plan to track and schedule maintenance, the
City cannot accurately estimate future expenses or allocate funding in advance. This lack of foresight
creates financial instability, as maintenance needs can quickly outpace the available budget. As a
result, the City may be forced to prioritize short-term fixes rather than strategic, long-term investments
in infrastructure, leading to maintenance backlogs and creating a cycle of reactive repairs. Without
planning, the City risks budget overruns and difficulty justifying expenditures, as there is no
framework to demonstrate the long-term benefits of proactive maintenance.
The absence of preventive maintenance planning also means that the City misses opportunities to
leverage economies of scale. By grouping similar tasks together or scheduling maintenance activities
in advance, the City could negotiate better contracts, reduce operational inefficiencies, and make use
of bulk purchasing for materials or services. However, without a coordinated, multi-year approach,
these opportunities are not realized, and the City can end up incurring higher costs due to
decentralized efforts. In the long term, this can result in higher total maintenance costs and an overall
decrease in the efficiency and reliability of the stormwater infrastructure.
The deterioration of stormwater infrastructure further increases public and environmental risks,
including flooding, water pollution, and safety hazards. Unaddressed maintenance needs can reduce
the reliability of stormwater systems, impacting the quality of life for residents and diminishing public
trust in municipal services.
Recommendation
The City should take steps to develop a comprehensive, multi-year preventive maintenance plan.
This plan is an extremely important step in determining the actual cost of the City’s stormwater
program and developing strategies to ensure that there are enough people and sufficient funding to
ensure the program’s ongoing sustainability.
Creating a multi-year cross-functional preventive maintenance plan for a decentralized stormwater
program requires coordination among multiple departments, clear communication, and a data-driven
approach. The success of preventive planning is contingent upon the City’s ability to centralize its
asset management practices. When developing a preventive maintenance plan the City should:
• Bring together its Stormwater Committee and as-needed representatives from departments such
as Finance or IT. This team should also involve key personnel responsible for field operations,
data management, and budget planning. Having a cross-functional team ensures that the plan
considers the needs and constraints of each department while fostering collaboration and
ownership Citywide.
• Review existing maintenance practices, procedures, and historical data across departments. This
step helps identify areas where maintenance activities are fragmented or inconsistent. Gathering
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data on previous maintenance schedules, costs, and inspections will provide insights into existing
gaps in service and help assess where improvements are needed. Identifying the lack of cost
tracking or decentralized workflows will also help shape the approach to better integrate data and
resources moving forward.
• Work with the cross-functional team to develop criteria for prioritizing maintenance tasks based
on asset condition, criticality, and risk. This may include considering factors such as flood-prone
areas, areas with high traffic, or locations that serve as essential components of the stormwater
system. A risk-based approach helps ensure that high-priority assets are maintained on a regular
basis, preventing larger issues and ensuring that the most critical assets receive the attention
they need first.
• Using the asset inventory (see Recommendation 4: Asset Management) and prioritization criteria,
develop a multi-year maintenance schedule that outlines preventive maintenance activities for
each asset. This should include regular inspections, cleaning, repairs, and any necessary
replacements, with timelines for when each task will be completed. Scheduling maintenance
across multiple years helps plan resources, budget, and workforce needs, allowing for more
effective coordination. The schedule should be flexible enough to accommodate unforeseen
issues or changes in priority.
• Establish clear performance metrics to measure the success of the preventive maintenance plan.
These could include metrics such as reduced emergency repairs, lower operational costs,
improved asset lifespan, and increased system reliability. Regular monitoring and reporting of
these metrics will help ensure that the plan is achieving its goals and will provide opportunities for
continuous improvement.
Since stormwater systems are dynamic, it will be important to review and update the preventive
maintenance plan annually. This includes assessing new data, evaluating asset conditions, and
adjusting priorities as needed. Continuous feedback from all departments will ensure that the plan
remains relevant, and the City can adapt to changing needs, budget constraints, and evolving
infrastructure.
MANAGEMENT RESPONSE
Management
Agreement Concur
Owner Stormwater Executive Committee
Target Completion
Date 6/30/2026
Action Plan See full management action plan in Appendix C.
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Roles and Responsibilities – Low Risk
6. Finding The City struggles to effectively coordinate and manage stormwater
program tasks as the program continues to grow and changes in
department leadership and staffing occur. This creates fragmented
efforts, unclear roles, and limited coordination, which reduce the overall
effectiveness of stormwater initiatives.
Recommendations A. Formalize a decision-making framework to clarify roles and
standardize the process for allocating responsibilities for
stormwater management activities across departments.
B. Develop a consistent process for effectively communicating the
process to new members as personnel changes occur.
C. Establish a regular cadence by which roles and responsibilities are
reviewed to ensure they remain up-to-date, are considerate of
departmental capacity, and can be appropriately funded.
Criteria
Municipal stormwater maintenance is most effective when governed by a hybrid model that balances
centralized oversight with clearly defined decentralized responsibilities. Centralized authority should
maintain accountability for system-wide planning, regulatory compliance, and financing, ensuring
consistency and efficiency in core infrastructure management. Decentralized roles, supported by
clear guidelines, education, and technical resources, can enhance responsiveness and operational
efficiency in localized stormwater management. This approach should prioritize coordination across
municipal departments to bridge specialization gaps and achieve integrated water management
goals10F11.
Condition
While the City’s stormwater management operating model is consistent with industry practice, it lacks
a formalized framework for defining the responsibilities of key departments that can be used to
coordinate decentralized tasks. In the past, members of the Stormwater Committee tried to develop a
matrix to define the primary party and secondary party responsible for stormwater program tasks.
Some progress was made; however, the document was never finalized or adopted and is not
currently referenced on an authoritative basis. Key stormwater management activities—such as
maintenance, inspections, and compliance—are instead managed through informal communication
and ad hoc coordination, making it difficult to ensure consistency. This has been particularly
challenging when there is turnover in department management or staff who are part of the SWMP.
Individuals moving into management positions can struggle to understand the scope of their roles and
responsibilities, and new staff can struggle to reconcile previous practices with City operations.
Collaboration can also break down when departments experience changes in their operating
environment (such as reductions in the availability of staff, equipment, or funds) that make it more
difficult to carry forward ownership of certain tasks.
11 Erik, Porse. (2013). Stormwater Governance and Future Cities. Water, 5(1):29-52. doi: 10.3390/W5010029
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In addition to the absence of a formal document outlining roles and responsibilities, the City has not
yet developed a consistent process for transitioning responsibilities when management or staff
turnover occurs. When turnover does occur, departments are often left to work between themselves
to coordinate the ownership of tasks. In most situations, a department’s role in stormwater
management is clearly defined and integrated into its regular work. For example, Engineering will
always be responsible for reviewing drainage permits and conducting construction site inspections
regardless of staff turnover. However, some tasks are less clear, such as management of illegal
dumping on rights of way or maintenance of catch basins, channels, and retention basins. When
there is turnover in key personnel and no established process to define roles and responsibilities or
protocol to communicate expectations, ownership of the work is relitigated, which has resulted in
some tension between departments. During interviews, departments shared hesitancy to take on and
commit to stormwater management responsibilities without a clear understanding of the full scope of
those responsibilities.
Effective delineation of stormwater management activities is further complicated by parties outside
the City who are also responsible for stormwater management tasks. The Flood Control District,
HOAs, commercial businesses, and annexed areas are part of the stormwater infrastructure and can
be responsible for maintenance of channels, retention basins, Salt River Project pipes, and
inspections. In most instances, roles and responsibilities are defined through intergovernmental
agreements (IGAs). Staff report that communication of agreements made in the IGAs isn’t always
communicated in advance. This has contributed to difficulties in effectively managing the full scope of
roles, responsibilities, and expectations for stormwater management across the City.
Peer Analysis
Other municipalities have implemented defined coordination processes to ensure stormwater
program responsibilities are clearly assigned and effectively managed. Unlike Glendale, where
stormwater tasks are distributed across multiple departments without a formalized coordination
framework, peer cities have established clear role assignments, interdepartmental review processes,
and structured coordination efforts to improve program efficiency.
• Chandler defines stormwater responsibilities using performance measures for each department,
ensuring tasks are assigned based on expertise. The city reviews MS4 permit requirements and
designates responsibility to the department best suited for each function. Public Works oversees
the maintenance of public stormwater assets, while Development Services manages plan
reviews.
• Mesa assigns stormwater roles through structured interdepartmental meetings. Before the
implementation of the new MS4 permit, the city conducts a series of meetings with responsible
departments to review roles and adjust responsibilities as needed. Additionally, Mesa regularly
reviews stormwater assignments before new permit cycles, conducting structured discussions to
ensure that new compliance requirements are appropriately delegated.
• Scottsdale has a defined separation between Water Quality and Stormwater and Floodplain
Management, ensuring each group has clear responsibilities. Water Quality oversees MS4
compliance, public outreach, stormwater sampling, and inspections, while Stormwater and
Floodplain Management handles drainage issues and stormwater conveyance. Scottsdale also
holds interdepartmental meetings to clarify responsibilities when new stormwater tasks arise,
providing a mechanism for departments to collaborate on role adjustments when necessary.
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• Tempe assigns stormwater responsibilities based on the existing duties of each department,
aligning stormwater-related tasks with broader departmental functions. Each department funds its
own stormwater-related staff and responsibilities.
These peer city practices demonstrate how structured role assignments, interdepartmental
coordination, and proactive responsibility reviews can improve stormwater program management and
prevent role ambiguity. Establishing a similar approach in Glendale would provide greater clarity in
stormwater program oversight, enhance collaboration across departments, and ensure
responsibilities remain well-defined as the program evolves.
Cause
A history of successfully meeting stormwater program requirements has generated a lack of urgency
to formalize roles and responsibilities across departments. Departments have consistently managed
to fulfill their obligations and achieve compliance without a clearly defined framework, creating the
perception that the current informal processes are sufficient. As a result, stakeholders are reluctant to
invest time and resources into establishing a more structured approach, believing that existing
practices are adequate for maintaining program effectiveness.
The lack of urgency is compounded by the absence of a clear policy owner who would champion the
development of a roles and responsibilities framework, hold individuals accountable, and spearhead
the creation of a transition protocol. Where the City has made efforts to formalize roles and
responsibilities, turnover of key personnel has disrupted efforts. Turnover can lead to the loss of
institutional knowledge and continuity, making it even more challenging to maintain momentum for
formalizing roles, responsibilities, and expectations.
The method by which the roles and responsibilities matrix was developed could also contribute to
challenges developing and adopting the framework. The previous effort focused on a task-based
approach where roles were defined by type (maintenance, quality/compliance, planning), further
detailed by element and activities, and then assigned a primary party (P) and secondary party (S). An
abbreviated example is provided on the following page.
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WSD –
SWM
WSD –
ER
Parks Trans. Eng
–Capital
System Maintenance
Dry Wells Manage inspection and
maintenance contract for all
250+ City-owned drywells (at
City facilities, in City-owned
retention basins/parks, in ROW)
P S - - -
Storm Sewer
Inlets, Catch
Basins,
Junction
Chambers,
and
Manholes
Routine inspection and
maintenance of inlets, catch
basins, junction chambers, and
manholes
P - - - S
Planned
rehab/repair/replacement of
inlets, catch basins, and
manholes
P - - - S
System
Planning
Asset
Management
Planning
Prioritization of capital and
maintenance projects
S - S S P
The inherent complexity of stormwater management means there will always be exceptions to the
rules when assigning tasks. Unique circumstances, such as specific project requirements, resource
availability, or urgent community needs, can complicate the allocation process. These exceptions can
create additional friction among departments, as some may feel that their capabilities or contributions
are being overutilized. This uncertainty further reinforces the fragmented approach, as departments
are reluctant to assume accountability for tasks that may exceed their current capacity or resources.
Effect
Without a shared understanding of priorities and objectives, there are some instances where
determining which department is best suited to handle specific tasks can become a subjective
process, leading to confusion and potential for conflict. Each department may have its own
perspective on what constitutes its core responsibilities, resulting in a reluctance to take on work that
falls outside their perceived scope. Disputes over who is accountable for specific aspects of
stormwater management not only hamper collaboration but can also make it more challenging to
manage key tasks and obligations outlined through the City’s program and also in IGAs. Without
clearly defined roles, there is a heightened potential for critical tasks to fall through the cracks, as no
single department may feel fully accountable for their execution. This ambiguity can lead to gaps in
compliance and service delivery, jeopardizing the City’s ability to meet its obligations under the permit
and IGAs.
When key staff members leave without a structured plan in place, critical knowledge and expertise
can be lost, leading to disruptions in ongoing projects and initiatives. New personnel may struggle to
acclimate to their roles without clear guidance on processes, responsibilities, and expectations,
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resulting in a steep learning curve that can delay progress and hinder productivity. The lack of a
transition plan can create uncertainty and confusion among remaining team members, who may be
unsure of how to fill the gaps left by departing staff. This can lead to increased stress as employees
grapple with additional workloads and the pressure to maintain program continuity.
The lack of clarity also makes it increasingly difficult to accurately capture personnel and funding
needs. When roles are not well-defined, departments may struggle to assess their resource
requirements effectively, leading to underfunding or allocation of resources. This misalignment can
strain budgets and result in inefficiencies, as departments may find themselves competing for limited
resources without a clear understanding of their collective needs.
Recommendation
The City should revitalize efforts to develop and formalize a roles and responsibilities matrix. An
important part of the success of this work is to identify a champion or lead for this initiative. This
person could be selected collaboratively through the Stormwater Committee but should be clearly
identified, given the appropriate authority, and have sufficient capacity to carry out this work. This
does not mean that this individual will be the only person responsible for development of the matrix,
but they will be responsible for managing the process to completion.
This matrix should serve as a foundational tool that clearly delineates the specific contributions of
each department, ensuring that everyone understands their roles within the broader context of
stormwater management. The matrix should include a summary statement for each department that
outlines at a high level how it contributes to the SWMP. This statement should be clear and concise
but with sufficient detail so that when new tasks or projects arise, these principles will help
departments assess their capabilities and responsibilities, ensuring that work is allocated efficiently
and effectively.
The matrix should also include accountability measures. Each task within the matrix should have a
designated owner responsible for its completion, along with clear expectations for performance.
Collaboratively, the Stormwater Committee should establish a process by which issues are surfaced
and resolved in situations where a department is not performing according to expectations. This
accountability will foster a culture of ownership among departments, encouraging them to take
initiative and work collaboratively.
To create the matrix, the City should engage key stakeholders from all relevant departments,
facilitating discussions to gather insights on current roles and responsibilities. This collaborative
approach will ensure that the matrix reflects the realities of each department’s work and fosters buy-in
from all parties involved. Once the matrix is drafted, it should be circulated for feedback, allowing
departments to review their roles and suggest adjustments, as necessary.
Once finalized, the roles and responsibilities matrix should be communicated effectively throughout
the City. This practice can be replicated in the event of turnover to help employees understand how to
use the matrix and its significance in their daily work. This proactive approach will reinforce
accountability and encourage adherence to the defined roles.
Finally, the City should establish a regular review schedule to monitor and update the matrix as
needed. By periodically assessing the matrix, the City can ensure that it remains relevant and
continues to reflect any changes in roles, responsibilities, or organizational structure. This ongoing
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evaluation will help the City adapt to new challenges and opportunities, ultimately strengthening the
SWMP and enhancing its ability to serve the community effectively.
MANAGEMENT RESPONSE
Management Agreement Concur
Owner Stormwater Executive Committee
Target Completion Date 10/1/2025
Action Plan See full management action plan in Appendix C.
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APPENDIX A: DEFINITIONS OF ASSESSMENT
FINDING RANKINGS
We utilized the City’s IIAP risk rankings, presented below, and assigned rankings to our findings
based on our professional judgment. A qualitative assessment of high, medium, or low helps to
prioritize implementation of corrective action, as shown in the following table.
HIGH
Findings with a high likelihood of causing significant negative impact (i.e., pose a threat
to achieving organizational objectives) if not promptly addressed. Recommendations
from high-risk findings should be implemented (preferably within three months).
MEDIUM
Findings with a medium likelihood of causing negative impact if left unaddressed. These
should be prioritized for corrective action to improve performance. Recommendations
arising from medium-risk findings should be implemented in a timely manner (preferably
within six months), to address moderate risks and strengthen or enhance efficiency.
LOW
Findings with a low likelihood of causing significant negative impact (i.e., pose a threat to
achieving organizational objectives) if not promptly addressed. Recommendations
arising from low-risk findings should be implemented within 12 months.
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APPENDIX B: PEER BENCHMARKING
DESCRIPTION GLENDALE CHANDLER MESA SCOTTSDALE TEMPE
City Boundaries
(sq. mi.) 60.1 64.5 137.1 184.4 40.2
Do you provide
services outside
City boundaries?
Yes No No No No
MS4 Permit Phase One Two One One One
Stormwater
Program
Administration
Permit requirements are
managed through the
Water Services Division.
Field tasks are delegated
to individual
departments.
The Stormwater
Committee convenes
monthly to support
program coordination
and administration.
Permit requirements are
managed through the
Environmental
Management
Department.
Field tasks are delegated
to individual
departments.
Permit requirements are
managed through the
Environmental and
Sustainability
Department (ESD).
Field tasks are delegated
to individual
departments.
Permit requirements are
managed through the
Water Quality Division.
The Water Quality
Division and the
Stormwater and
Floodplain Management
Division are the two
parties responsible for
most stormwater
management work.
Other field tasks are
delegated to individual
departments.
Permit requirements are
managed through the
Water Utilities Division,
Environmental Section.
Field tasks are delegated
to individual
departments.
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DESCRIPTION GLENDALE CHANDLER MESA SCOTTSDALE TEMPE
Involved
Departments
● Water Services
Department –
Stormwater
Maintenance (WSD-
SWM)
● Water Services
Department –
Environmental
Resources (WSD-
ER)
● Engineering
● Engineering – Plan
Review
● Transportation
● Field Operations
● Parks and Recreation
● Development
Services –
Geographic
Information System
(GIS)
● Development
Services – Code
Compliance
● Management
Services Department
– Environmental
Management Division
● Public Works and
Utilities Department
● Capital Projects
Division
● Development
Services Department
● Communications and
Public Affairs
● Department (CAPA)
● Law Department
● Chandler Police
Department
● ESD
● Public Works
Department
● Energy Resources
● Transportation
● Parks and Recreation
● Development
Services Department
● Communications and
Public Involvement
Team
● Law Department
● Inspection Teams
● Public Works – Street
Operations
● Public Works –
Facilities & Fleet,
● Community &
Economic
Development
● Public Works -Capital
Projects
Management
● Office of
Environmental
Initiatives
● Communications –
Citizen Service
● Municipal Utilities –
Water Utilities
Division
● Engineering and
Transportation –
Transportation
Division
● Engineering and
Transportation –
Engineering Division
● Division Municipal
Utilities – Field
Operations Division
● Communications &
Media Relations
● Community
Development –
Development
Services Division
● Community Services
– Parks & Recreation
Division
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DESCRIPTION GLENDALE CHANDLER MESA SCOTTSDALE TEMPE
Program Roles
and
Responsibilities
Guided through historical
practices and managed
on an ongoing basis
through Stormwater
Committee coordination.
Defined by the permit,
then allocated based on
which department the
activity correlates to.
Roles have been well
established over the
years, and ongoing
activities are coordinated
through ESD.
Water Quality and
Stormwater and
Floodplain management
roles are outlined based
on historical practices.
The City is working to
close the gap between
these two divisions.
If tasks lack clarity, the
division holds an
interdepartmental
meeting to discuss and
allocate.
Roles are assigned
based on their
commonality with other
duties of the department
and the work each
department is actively
conducting.
Funding
Mechanisms
● General funds
● Enterprise funds
● Flood Control District
Grants
● Energy Efficiency and
Conservation Block
Grant
● General Fund, liability
account
● Environmental
Compliance Fee
● Stormwater Fee ● CIP fund
● Department general
and enterprise funds
● Stormwater fee
Rate Effective Date January 202411F12 January 2024 January 2024 January 2024 January 2024
Stormwater or
Environmental
Fee
Proposed $3.00 per
month
N/A $7.32 per month $8.10 per month $3.00 per month
Customer Type Single-Family Single-Family Single-Family Single-Family Single-Family
12 Effective January 2025, the City proposed increases to their water and sewer rates. To maintain the comparability of the rate analysis, 2024 data was used.
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DESCRIPTION GLENDALE CHANDLER MESA SCOTTSDALE TEMPE
Wastewater/
Sewer Rate $12.4012F13 – Monthly Fee
Inside City Limits
$4.76 – Volumetric
Charge Inside City Limits
$27.65 – Inside City
Limits
$44.24 – Outside City
Limits
$24.11 – Inside City
Limits
$35.49 – Outside City
Limits
$9.90 – 5/8 Meter
Monthly Charge
$5.94 – Volumetric
Charge
$7.75 – 5/8 Meter
Monthly Charge
$2.25 – Volumetric
Charge
$16.12 – Monthly Fee
Outside City Limits
$6.19 – Volumetric
Charge Outside City
Limits
Asset
Management
System
CentralSquare
GIS database
CentralSquare
GIS database
GIS database GIS system called Water
Work (a new system is
being developed)
CentralSquare
GIS database
Preventive Maintenance The City is divided into
quarter-mile sections
called fire maintenance/
management areas
(FMAs). Every year the
City inspects all FMAs on
the public side to inform
maintenance.
Similar to Glendale,
Chandler is divided into
FMAs, each covering a
quarter-mile section.
Stormwater assets in
each FMA undergo
annual inspections, and
identified maintenance
needs are scheduled for
repair. The city’s
inspection schedule is
informed by its MS4
permit requirements.
Preventive maintenance
planning is integrated
into Mesa’s GIS-based
asset management
system. The city assigns
multiple departments—
such as Development
Services, Transportation,
and Budget—to track
and update asset
conditions, ensuring that
deferred maintenance is
recorded, prioritized, and
addressed as part of an
ongoing maintenance
strategy.
Preventive maintenance
and CIP planning is split
between the Water
Quality team and the
Stormwater and
Floodplain Management
team. All other
departments are
responsible for
maintaining their assets
in Scottdale’s GIS.
Tempe incorporates
preventive maintenance
into the city‘s larger
maintenance program,
ensuring that stormwater
assets are managed
alongside other
municipal infrastructure.
There is an engineer who
manages Tempe’s CIP
program and helps
determine what
stormwater projects to
include in the plan.
13 Rather than assessing the monthly fee based on meter size like Scottsdale and Tempe, Glendale adjusts its monthly fee based on customer type. For example, single family, multi-
family, laundromat, gas station, etc. Glendale also differentiates between customers inside the City and outside the City. The comparative rates shown for Glendale, Chandler, and
Mesa are for single-family customers.
Stormwater Management Program Performance Audit Report | 43
FOR INTERNAL USE OF CITY OF GLENDALE ONLY
DESCRIPTION GLENDALE CHANDLER MESA SCOTTSDALE TEMPE
Asset
Management
Roles and Responsibilities
Multiple departments.
WSD staff conduct
inspections and update
as-built information in
GIS. Other department
practices vary and asset
information updates
occur within the preferred
tracking platform.
Multiple departments.
Public Works is
responsible for tracking
assets in CentralSquare.
The GIS team updates
the system during post-
construction asset
verification.
The Environmental
Management team
gathers information on
construction inspections,
municipal facility
inspections, and illicit
discharge via Survey
123.
Multiple departments.
Development Services
coordinates with the
Transportation and
Budget departments to
input city-owned
infrastructure (budget
because each asset
carries an asset value).
Engineering oversees
the private infrastructure
since it has an interface
with the city-owned
infrastructure. Data is
typically input following
the final approval/
certificate of occupancy
or completion of a
project.
Multiple departments. Multiple departments.
Stormwater Management Program Performance Audit Report | 44
FOR INTERNAL USE OF CITY OF GLENDALE ONLY
APPENDIX C: MANAGEMENT RESPONSE
C. PERFORMANCE AUDIT ACTION PLAN
In response to the six findings in the Stormwater Management Program Performance Audit, the City of
Glendale’s action plan includes:
• (Finding #1) On June 26, 2025, Council will vote on the establishment of a stormwater fee ($2/month
for residential water accounts; variable rate based on water meter size for commercial, industrial and
institutional water accounts). If approved, the fee would be implemented beginning in January 2026.
• A Stormwater Executive Committee (SwEC) will be established by 8/1/2025. The SwEC will meet on
a regular basis and consist of department directors or their delegates from the following departments:
Water Services, Engineering, Budget and Finance, Parks and Recreation, Transportation, Field
Operations, and Code Compliance. The purpose of this committee will be to:
○ (Finding #2) By 1/1/2026, develop procedures for tracking stormwater-related expenses.
○ (Finding #2) By 7/1/2026, develop procedures for tracking staff’s stormwater-related hours.
○ (Finding #1) After 6-months of fee collection (1/1/2026 through 8/1/2026), evaluate revenue from
new fee compared to current and projected expenses and identify funding gaps.
○ (Finding #3) By 1/1/2026, discuss options for cost recovery for properties west of 115th Avenue
that do not receive a water bill from the City of Glendale.
○ (Finding #4) Track progress towards completion of asset data collection/ verification.
Management of asset data will be ongoing, but set an initial goal of 1/1/2027 for populating
missing asset information.
○ (Finding #6) By 10/1/2025, review/revise roles and responsibilities and service-level
expectations.
○ (Finding #1) Review and prioritize stormwater-related capital projects and opportunities for grant
funding.
• (Finding #4) City staff will continue to address inaccurate or missing asset information through the
review of as-builts and field verification activities. Asset details will continue to be maintained in the
City’s asset management system (CentralSquare).
• (Finding #5) The City’s existing Stormwater Committee (comprised of City staff conducting
stormwater-related activities) will develop a preventive maintenance plan (PMP) by 6/30/2026. Staff
will review maintenance frequencies recommended by national associations and local practices. The
PMP will consider the condition and criticality of assets. Once drafted, the PMP will be presented to
the SwEC for review and approval.