(June 18, 2019) - NACWA met with senior EPA Office of Water and Office of Enforcement and Compliance Assurance staff again last week to discuss compliance issues for combined sewer overflow (CSO) communities that reach the end of their long-term control plans (LTCPs). The issue in question is what happens post-LTCP when the clean water agency may still not meet water quality standards during wet weather conditions despite having completed CSO remediation work that was agreed upon. EPA updated NACWA staff about its discussions with states and evolving thought process on this significant regulatory and policy issue.
NACWA has formed a workgroup of interested member utility leaders to help guide the Association’s engagement with EPA and the states on post-LTCP Clean Water Act compliance. EPA is planning to meet with NACWA and key members in late summer to get additional input.
In the meantime, NACWA is working on a CSO LTCP benchmarking database to quantify expenditures and volume of overflow reduction that will be achieved at the end of each community’s LTCP. This information can be used by NACWA and our members in communication with regulators and the public. The information will also be used for NACWA’s 50th Anniversary Report, which will detail the record of success of public agencies over the last 50 years in terms of the economic, social, and public health/environmental progress made as a result of the sector’s clean water investments.
CSO communities interested in the workgroup and/or providing information for the benchmarking database should contact Amanda Waters, NACWA’s General Counsel.