IMPLEMENTATION OF THE WATER QUALITY PROVISIONS OF THE 1994 NATIONAL CSO CONTOL POLICY: WHERE DO WE STAND?

A key principle of implementing the water quality provisions of EPA's 1994 Combined Sewer Overflow (CSO) Policy is the review and revision, as appropriate, of water quality standards of receiving waters that are impacted by CSOs. Six years after the CSO policy was issued, only two of the 30 States with CSO municipalities have taken actions to facilitate the implementation of water quality provision of CSO policy.Many CSO communities have not yet completed the long term CSO control plans, in part because States are either reluctant or unable to review and revise, as necessary, the water quality standards as envisioned by the CSO policy. Without States' review and revision of the current water quality standards, CSO communities are reluctant to commit their limited resources to CSO controls that may have very limited water quality benefits. The estimated national CSO control costs for meeting current water quality standards exceed 200 billion.Human-induced conditions in urban areas and other point and non-point sources of pollution may make current water quality standards in some urban waters no longer appropriate or unable to be met, regardless of CSO controls that are implemented. A proper review and revision of existing water quality standards can save unnecessary expenditures, ensure that proper water uses are maintained, and significantly facilitate the implementation of water quality-based provision of the CSO policy.