INCONSISTENCIES IN CSO/SSO PROGRAM IMPLEMENTATION:MAJOR FINANCIAL IMPLICATIONS FOR MUNICIPAL ENTITIES

摘要

For the past decade EPA has been in the process of developing numerous requirementsapplicable to design and permitting of facilities intended to ensure proper management of wetweather flows. These requirements have been issued in a number of contexts and have, at times,been subject to widely varying interpretation across the country. These actions include:1. Issuance of various combined sewer overflow policies;2. Development of regulations to require elimination of sanitary sewer overflows;3. Enforcement actions against municipal entities interpreting various NPDES regulationsadopted under different circumstances;4. Objections to state program permits;5. Informal guidance to Regional Offices; and6. Regional Office initiatives.The purpose of this paper is to review the major inconsistencies in current programimplementation, evaluate the proper application of the applicable federal regulations and permitapproaches and to recommend broadly, how communities with SSO and CSO related flowsshould approach state and federal agencies in resolving these matters.