Search
Regulatory Alert - RA 02-4 - EPA RELEASES CSO REPORT TO CONGRESS / AMSA RESPONDS WITH COMPANION REPORT

Member Pipeline - Regulatory - Alert (RA 02-4)

print Printer friendly version

To: Members & Affiliates, and Wet Weather Issues Committee
From: National Office
Date: February 1, 2002
Subject: EPA RELEASES CSO REPORT TO CONGRESS / AMSA RESPONDS WITH COMPANION REPORT
Reference: RA 02-4

On January 29, the U.S. Environmental Protection Agency's (EPA) Office of Water released its Report to Congress: Implementation and Enforcement of the Combined Sewer Overflow Policy ("CSO Report"), presenting data and findings on the progress made by EPA, states, and municipalities in implementing and enforcing the Combined Sewer Overflow (CSO) Control Policy ("Policy") since 1994. The CSO Report can be accessed electronically through the AMSA web site at http://www.amsa-cleanwater.org/private/epa/dec01epacsorep.pdf or through EPA's web site at http://www.epa.gov/npdes. In response to EPA's CSO Report, AMSA is releasing its own assessment of municipal progress and program challenges. The report, Communities at Work ... The National Response to Combined Sewer Overflows ("CSO Companion Report"), summarizes data from AMSA's CSO survey, and provides Congress and EPA with recommendations on how to move the program forward in the coming years. AMSA's CSO Companion Report is accessible through the AMSA web site at http://www.amsa-cleanwater.org/advocacy/01-31-02csoreport.pdf, or by contacting Jennifer Burke at 202/533-1801 or jburke@amsa-cleanwater.org.

 
AMSA's Report Finds Substantial Progress and Investment, Recommends Path Forward
The CSO Companion Report is based on responses to AMSA's August 2001 CSO Survey, which drew a 58% reply rate, as well as the considerable expertise of our CSO members. AMSA's CSO Companion Report confirms that support remains strong in the wastewater treatment community for the fundamental regulatory approach in EPA's CSO Policy. Since 1994, AMSA members have made significant progress towards implementing the CSO Policy's requirements, devoting massive capital and human resources to CSO controls and, as a result, reducing overflows by an average 45 percent in volume and 50 percent in frequency. However, challenges to greater progress must be acknowledged and addressed expeditiously to keep the CSO program moving forward. Among the most pervasive of these challenges are: 1) the extremely high costs of CSO controls, which consume an average of 36.8% of local capital improvement budgets, and the lack of available funding assistance; 2) the inconsistencies in interpreting the Policy among states and EPA Regions; and 3) the lack of progress made to review the applicability of existing state water quality standards (WQS) to wet weather conditions.

Based on these findings, the CSO Companion Report recommends that EPA and Congress take action to: 1) provide new and increased technical and financial assistance; 2) develop guidance for states to conform to the CSO Policy's approach; 3) develop new approaches to other wet weather discharges, such as sanitary sewer overflows (SSOs) based on the CSO Policy's basic framework; 4) focus renewed energy and resources on reviewing the applicability of water quality standards to wet weather conditions; and 5) support greater use of urban watershed management principles to set priorities and proportionate accountability for removal of pollutants. The CSO Companion Report is being distributed to EPA Headquarters, all EPA regions, CSO states, and members of Congress. For more information, contact Greg Schaner at 202/296-9836 or gschaner@amsa-cleanwater.org.


EPA's CSO Report Cites Progress and Challenges
The CSO Report cites the "substantial progress and investments" made by cities since 1994, estimating a 12 percent reduction overall in untreated CSO discharge volumes and pollutant loadings. However, the CSO Report also indicates that CSOs "continue to pose a serious environmental and public health threat" and concludes that "much remains to be done to fully realize the objectives of the CSO Control Policy." The document identifies several noteworthy challenges to CSO management including the considerable costs of control and mounting wastewater infrastructure needs, insufficient coordination between the development of long term control plans and the state water quality standards (WQS) review process, the lack of a national data system for comprehensively evaluating the implementation, and the lack of clear, national performance measures to assess the effectiveness of CSO control. For more information on the CSO Report, contact EPA's CSO National Program Manager, Tim Dwyer, at 202/564-0717 or dwyer.tim@epa.gov.