Implementing a Sewer Overflow Consent Decree through Watershed Management

Communities with combined sewer overflows (CSOs), sanitary sewer overflows (SSOs), or municipal storm water discharges may be expected to enter into a Consent Decree, particularly if water quality standards are not being attained. The decree typically specifies that the community develop and implement an overflow control plan to comply with federal and state clean water regulations. The role that other pollutant sources play in preventing attainment of standards is rarely a critical element, although these sources may be the primary reason why little or no improvement in water quality is observed after the costly plan is implemented. This paper describes the watershed-based approach that Sanitation District No. 1 (District) in Northern Kentucky is using to prepare Watershed Plans to meet the terms of its Consent Decree. The approach allows the District to determine a combination of affordable infrastructure and watershed controls to improve water quality, eliminate SSOs, and comply with the CSO Policy (59 Federal Register 18688).