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NLC seeks city ideas, comments regarding combined sewer overflows.

The U.S. Environmental Protection Agency recently convened a workgroup to develop a consensus for federal guidance on combined sewer overflows (CSOs). The National League of Cities is represented by Councilmember Steve John of Decatur, Ill., a member of the Energy, Environment and Natural Resources Steering Committee. Other participants representing municipalities, environmental activists, states (see below) and EPA officials complete the 15 member workgroup.

The product of the workgroup can have significant consequences for municipalities with combined sewer systems and NLC is interested in comments from affected cities on the issues identified by the workgroup for potential consensus.(*1)

In reviewing EPA statistics on municipalities with CSO systems, Councilmember John noted that close to 50 percent are municipalities with populations of 5,000 or less. He is especially interested in comments on the criteria outlined below from these municipalities to assure they have an adequate voice in any consensus.

The workgroup, in two previous meetings, established both the ground rules for negotiating a consensus agreement and a list of major issues to be resolved in developing a guidance for addressing Combined Sewer Overflows. What follows is the agenda for discussion and the issues to be resolved.

The framework for discussion and development of a consensus on CSO protocols is:

* An examination by the municipality of complete rainfall records for CSO system locations to facilitate selection of a range of design storms representative of rainfall and receiving water response.

* Selection of design storm[s] to meet any one or combination of the following criteria: (1) number of overflows per year, either on an outfall- specific or systemwide average basis, as is most appropriate; (2) percent capture by volume; (3) percent capture by mass; (4) percent increase in system storage; or (4) percent increase in ratio of storage capacity to dry weather flows.

The workgroup will attempt to agree on numbers for each of these proposed categories. In addition, each municipality may select the most appropriate criteria or combination of criteria on the basis of water quality impacts and cost-effectiveness.

* Develop definition of appropriate treatment technology or standards for all flows not diverted to secondary treatment plant.

* All systems must demonstrate compliance with water quality standards and protection of all existing and potential uses including: (1) prohibition of overflows into sensitive use areas such as beaches, drinking water supplies, shellfish beds and sensitive aquatic ecosystems; and (2) specific monitoring and analytical protocols to determine whether standards are met and uses protected.

* Municipalities may select the least cost solution or combination of solutions to meet these protocols after evaluation of all structural and non-structural approaches. The protocols will not require: end of pipe numeric water-quality based limits and end of pipe numeric technology-based limits.

* Protocols may allow implementation procedures that allow for limited exceedences of numeric water quality criteria (criteria that will also be part of this negotiation) so long as existing and potential uses are protected.

* The protocols will include timeframes for planning, design and implementation of solution, which will allow phasing of solutions to address water quality priorities.

* The protocols will provide the state and federal permit- writers, the permitees, and the public with reasonable certainty about CSO controls and permitting requirements.

Other issues raised in the discussions of the workgroup to date include:

* Grandfathering the activities municipalities have already undertaken in addressing CSO problems. These initiatives should be accepted as significant achievements and municipalities should not required to undo or redo these activities because they do not nealty fit newly developed protocols.

* Substantial financial assistance from other levels of government without which new requirements would be either significantly scaled back or not required at all.

* Encouraging the use of innovative and alternative technologies.

Other participants representing municipal interests are: the Association of Metropolitan Sewerage Agencies (AMSA), Michele Pla, San Francisco; the National Association of Flood and Stormwater Management Agencies (NAFSMA), Ed Wagner, New York City; the American Public Works Association (APWA), Ray Booth, Lynchburg, VA; and the CSO Partnership, David Evans, Legal Counsel to the Partnership.

In addition, Gordon Gardner, Executive Director of the Louisville and Jefferson County (KY) Metropolitan Sewer District, Chair of EPA's Management Advisory Group (MAG) is also a participant. National environmental groups on the workgroup are the Natural Resources Defense Council (NRDC) and the Environmental Defense Fund (EDF); other environmentalists represent local groups. Paul Zugger from Michigan's Department of Natural Resources is spokesman for the states. EPA's representatives are Martha Prothro, Deputy Assistant Administrator for Water and Michael Cook, Director of the Office of Wastewater Enforcement and Compliance.

(*1) Comments must arrive at NLC no later than September 3 and should be sent to Carol Kocheisen, Center for Policy and Federal Relations. FAX (202) 626-3043.
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Title Annotation:National League of Cities
Author:Kocheisen, Carol
Publication:Nation's Cities Weekly
Date:Aug 17, 1992
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