Changing the FOG Game - Bringing Multi-Family Properties into the Program

摘要

On December 20, 2011, DeKalb County, Georgia entered into a Consent Decree with the United States Environmental Protection Agency (EPA) and the State of Georgia Environmental Protection Division (EPD) due to high numbers of sanitary sewer overflows (SSOs) from the sewer system. As with most aging infrastructure systems, historical system maintenance may not have been performed as often as recommended by current industry standards; however, one well established and implemented program was the Fats, Oils, and Grease (FOG) Program that regulates Food Service Establishments FSEs). Yet even with a strong traditional FOG program in place regulating FSEs, sixty (60%) of the recorded spills (SSOs that actually resulted in discharges to Waters of the State) had FOG as the primary or contributing factor. This paper strives to outline a new way of addressing an old problem, seemingly impossible at the outset. It discusses the options considered, the path using a stakeholder working group, as well as the "sticking" points after the concepts were agreed, the difficulties crafting the language to regulate multi-family commercial properties, and the final agreements reached to create a FOG Program that regulates multi-family housing.