Action Please By: July 10, 1997
To: Members & Subscribers From: National Office Date: June 18, 1997 Re: RA 97-14 Draft Sanitary Sewer Overflow Cost/Benefit Analysis
Attached is a copy of EPA’s draft SSO Cost Analysis which it has released to its Sanitary Sewer Overflow Advisory Subcommittee. The draft document, though still incomplete, presents an analysis of the projected total and incremental costs to implement a national program to control SSOs. These cost estimates will be critical in the coming months, as EPA, AMSA and others on the SSO Advisory Committee negotiate final details of a proposed policy/regulation.
EPA is soliciting comment on the draft document which includes a background section (Section 1), a discussion of sanitary sewer operating characteristics (Section 2), a discussion of causes and abatement of SSOs (Section 3), a description of the cost model and model inputs (Section 4), and resulting output of model runs (Section 5). In addition, EPA has specifically expressed its interest in obtaining additional data to help calibrate the cost model. Several operators on the SSO Subcommittee have preliminary concerns that the national model cost estimates presented in the document may not accurately reflect the real-world costs of controlling SSOs nationwide.
AMSA would like member agencies to review EPA’s cost model methodology and assumptions used, and assess whether the methodology and assumptions accurately model real-world costs. Section 4 describes model inputs, and discusses cost model development of various SSO mitigation alternatives, including flow equalization storage, increased wet weather capacity, sanitary sewer system rehabilitation, as well as unit cost estimates for operation and maintenance. Seventeen case studies were used to calibrate the cost models. In addition to providing input on EPA’s cost model methodology and assumptions used, members are encouraged to provide additional data to help calibrate EPA’s final model. Those members which are cited in Appendix D of the report, are encouraged to review their data for accuracy.
If you would like to comment or provide additional information on EPA’s draft cost analysis, please submit them to the National Office no later than July 10, 1997 via e-mail at amsa@clark.net, or fax at 202/833-4657 to the attention of Mark Hoeke. Comments more than three pages should be submitted in electronic format (WordPerfect preferred) via e-mail or 3.5" diskette. If you have any questions, please call Mark Hoeke, AMSA 202/833-9106.
ATTACHMENT: EPA’s Draft Sanitary Sewer Overflow Cost/benefit Analysis (Please contact AMSA’s National Office at 202/833-AMSA for a copy of this document)