Association Discusses Great Lakes CSO Reporting Rule with White House Budget Office

two(December 12, 2017) - NACWA met with the White House Office of Management & Budget (OMB) on December 6 to discuss the final rule establishing public notification requirements for combined sewer overflows (CSOs) to the Great Lakes Basin.  EPA was required to develop this rule by Congress in the Consolidated Appropriations Act of 2015.  In the proposed rule, utilities would need to provide public notification of a CSO within four hours of “becoming aware by modeling, monitoring, or other means that a CSO discharge has occurred.”  A supplemental notice, which would include the estimated CSO volume, would also be required 24 hours after the overflow ended. 

NACWA reiterated to OMB the issued raised in its comments on the proposed rule, focusing on the impacts of the quick notification times on utilities.  NACWA asked that more time be allowed for the initial notification, or that clarity be provided about what “becoming aware” means, so that utilities are not required to add additional staff for nights, weekends, or holidays.  More time should also be allowed for the supplemental notification, since this information is used only as a data collection tool for Great Lakes CSOs.  NACWA also emphasized that Congress allowed flexibility with its requirements, and EPA should use this flexibility as much as possible and not require more than Congress stipulated. 

 

The final rule is expected to be published by the end of the year.  Contact Cynthia Finley, NACWA’s Director of Regulatory Affairs, with any questions.