Negotiating a Post-construction LTCP Compliance Work Plan: The Toledo Experience

The City of Toledo, Ohio is one of the first large, combined sewer overflow (CSO) communities to complete construction of its consent decree program. The city has implemented a $512M program to control CSOs and known sanitary sewer overflows (SSOs). The terms of its consent decree with the United States Environmental Protection Agency (USEPA) and Ohio EPA require the city to confirm that the actual performance of constructed facilities meets the anticipated performance identified in the city's Long-Term Control Plan. Achieving regulatory approval of the city's Post Construction Compliance Monitoring (PCCM) plan was challenging and required multiple years of regulatory discussions. This paper identifies specific issues raised by USEPA as part of their review and how it was resolved to achieve plan approval. Few CSO communities have reached this point in their programs. The authors intend this paper to help other CSO communities plan for post-construction phases of their programs.