Project Overview

The Alliance has been working proactively and collaboratively with its Member agencies and the Washington State Department of Ecology to develop a delegated program that will serve the current and future needs of our community. The Alliance’s Salmon Creek Regional Wastewater Management System is a critical part of the community’s public infrastructure. Handling approximately 8 to 10 million gallons of wastewater per day, the system meets the federal thresholds for pretreatment program delegation, which are based on the size of the treatment plant and the presence of industrial users in the service area. As a result, Ecology has indicated its interest in delegating authority to administer the program locally. Delegation of authority involves a transfer of legal and regulatory authority and responsibilities for the program from the state (Ecology) to the local level (Alliance). The delegated program will provide local users with a more accessible and responsive program.

Industrial Pretreatment Program Delegation
The pretreatment program is a critical element of the regional wastewater management system. The program is federally mandated by the Clean Water Act and is a requirement of the Salmon Creek Wastewater Treatment Plant’s National Pollutant Discharge Elimination System (NPDES) permit, which is issued by the Washington State Department of Ecology to the Alliance. The goal of pretreatment is to protect wastewater infrastructure, worker safety, and public and environmental health from potentially harmful discharges from industrial and commercial users. Program requirements apply to all non-domestic discharges (commercial use of the wastewater system). Some businesses are required to obtain permits to discharge to the wastewater system, based on federal, state, and local pretreatment requirements.

Industrial Pretreatment Program


Current Program FrameworkIn the current framework, the pretreatment program is already being fully administered within the Alliance service area. Currently, Ecology maintains overall legal and regulatory authority for the program and coordinates with Clark Regional Wastewater District (District) to work with local users.  Ecology responsibilities include issuing discharge permits to certain users, ensuring compliance with permit requirements and enforcement. The District currently administers a non-delegated pretreatment program, in coordination with the City of Battle Ground, that applies to all other industrial and commercial users of the wastewater system. District staff work with local businesses and Ecology to determine applicable pretreatment requirements for each user and to ensure that their wastewater discharge is in compliance with all federal and state pretreatment regulations. The District also engages with permitted users as the local point of contact and coordinates with and provides support to, Ecology as needed.

Current program requirements can be found in the local Sewer Use Ordinances for the District (Chapter 5.52) and the City of Battle Ground (Chapter 13.137).

Program DelegationProgram delegation involves a transfer of program authority and oversight from the state to the local level. Practically, this means that upon approval of the delegated program, the Alliance will assume the role that Ecology plays today, serving as the “Control Authority” for the program. The Alliance will then work directly with users for all aspects of the program, including administering discharge permits. This will provide a more accessible and responsive program by providing a consistent, local point of contact for all users and a more efficient and streamlined permitting process.
Delegated Program FrameworkAs Administrative Lead for the Alliance, the District will implement the delegated program and perform all required administrative and technical duties. The District and the City of Battle Ground, as the two agencies that own and manage collections systems, will continue to work cooperatively with the Alliance, to ensure that the delegated program is administered consistently and effectively across the entire regional service area.

Since many program elements are already occurring locally, most of the program changes with delegation are legal and administrative in nature, to facilitate the transition to a locally managed Alliance program. The delegation process involves updating the existing legal framework to incorporate additional federal and state requirements specific to delegated programs.

At the Alliance level, this involves amending the existing Wastewater Quality Resolution, that reflects the Alliance partnership and responsibility to manage regional assets in accordance with pretreatment regulations. The Alliance will also adopt Pretreatment Regulations, that specify discharge standards and prohibitions that apply to all commercial and industrial users of the wastewater system.

The District and the City of Battle Ground will update their existing local Sewer Use Ordinances to reference the Alliance Pretreatment Regulations.  They will also enter into an Interlocal Agreement with the Alliance governing the administration of the multijurisdictional, delegated program.

Draft program documents have been developed in collaboration with Alliance Members and legal counsel and reviewed by the Alliance Board. They are available for review here:


The Alliance completed program development and obtained local endorsement from the District and the City of Battle Ground in 2021. The Alliance submitted the proposed program to Ecology in April 2022 and has been coordinating closely with Ecology on its review. Once Ecology completes its review, a public notice for comment will be issued. Ecology will review and respond to comments after the comment period. Upon Ecology approval, the Alliance will adopt the delegated program, and the updated program framework will go into effect.



Contact Us

For more information about the program, or if you’d like to be notified of the dates for the public hearings, please contact Leanne. For technical questions, please contact Kristen.

Leanne Mattos
Administrative Services Manager | Board Clerk

Kristen Thomas
Regulatory Compliance Manager