SSOs AND CMOM: AN OVERVIEW FROM THE LEGAL AND ENGINEERING PERSPECTIVES

Since 1995, the US Environmental Protection Agency's (EPA) has been developing a rule to address sanitary sewer overflows (SSOs) and the environmental and health impacts caused by them. In January 2001, after almost six years of development, former EPA Administrator Carol Browner signed the proposed SSO Rule. The proposal, however, was withdrawn several weeks later before it was published in the Federal Register by the new Administration as part of the Regulatory Review Plan. The proposed Rule is currently under review by the EPA Administrator Christine Todd-Whitman. Although the Rule is not currently effective, it does provide system owners and operators guidance on EPA's expectations for collection systems. The Rule will require municipal collection systems, including satellite facilities, to develop a capacity, management, operations, and maintenance (CMOM) program. The purpose of this paper is to explore the Rule from the legal and engineering perspectives, and the benefits of proactively implementing a CMOM program.