NACWA, EPA Discuss CSO Post-LTCP Compliance

(May 21, 2019) – NACWA met with senior EPA Office of Water staff last week to discuss compliance issues for combined sewer overflow (CSO) communities that have reached the end of their long-term control plan (LTCP) projects.  The conversation focused specifically on communities that may still not be meeting water quality standards, despite having completed all the work and CSO remediation projects that they agreed to under their LTCP, and how to address these issues through future permits.    

This is a complex regulatory and policy issue and will only become more important to address over the next few years as an increasing number of communities reach the end of their current LTCPs and related CSO enforcement actions. 

The conversation was very productive, with NACWA and EPA agreeing to further discussions in the near future that will also include EPA’s enforcement office.  There is broad consensus that communities which have completed their promised CSO programs should not be forced to spend significant additional ratepayer dollars on CSO projects that will not result in meaningful environmental improvement, but there is a need to determine the appropriate regulatory path to support these communities. 

NACWA is also forming a workgroup of interested utility members to help guide the Association’s engagement on this issue.  If you are interested in being part of the workgroup, please contact Amanda Waters, NACWA’s General Counsel.