September 25, 2015
By:
Walter G. Wright
Category:
Arkansas Environmental, Energy, and Water Law
Arkansas Environmental, Energy, and Water Law
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The United States Environmental Protection Agency (“EPA”) Office of Inspector General (“OIG”) conducted an examination of EPA’s combined sewer overflow (“CSO”) enforcement efforts.
OIG addressed the following questions:
- How are selected municipalities implementing consent decrees issued under EPA’s enforcement initiative to keep raw sewage and contaminated stormwater out of the nation’s waters, and are they achieving milestones and anticipated outcomes?
- What opportunities exist for EPA to improve the efficiency and effectiveness of tracking the progress of consent decree implementations and outcomes?
CSOs transport both sanitary sewage and stormwater runoff in a single-pipe system to a wastewater treatment facility. Problems can occur during periods of significant rainfall as a portion of the combined flow of stormwater runoff and sewage may directly discharge to surface waters. Such discharges of raw sewage can significantly effect a waterbody’s compliance with applicable Clean Water Act water quality standards.
OIG states that EPA lacks a national tracking system that consistently monitors CSO consent decree results. It also states that EPA has not established an Annual Commitment System goal for regional consent decree tracking. It states that such tracking would allow EPA headquarters to incentivize consent decree tracking in regions. Also, OIG notes that the increased use of promising new technologies and public reporting can improve the efficiency of federal agency oversight and its ability to demonstrate that associated water quality improvements result from the CSO program.
OIG recommends that the EPA Assistant Administrator for Enforcement and Compliance Assurance develop and report outcome-based goals and measures for the CSO consent decrees; develop national consent decree tracking system for regional and headquarter use; develop an Annual Commitment System goal that establishes regional goals for monitoring and reporting outcomes associated with CSO consent decrees and provide a public website for consent decree information.
Click here to download a copy of the OIG report.
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