OVERVIEW OF THE UPCOMING U.S. EPA CMOM REGULATIONS ON SANITARY SEWER OVERFLOWS

Many U.S. municipalities' sanitary sewer systems suffer from excessive infiltration and inflow (I/I), producing sanitary sewer overflows (SSOs) during wet weather. EPA is developing new regulations to clarify existing SSO prohibitions and National Pollutant Discharge Elimination System (NPDES) requirements for proper operation and maintenance of collection systems. The proposed rule includes provisions on satellite systems, recordkeeping, and reporting, but the provision that has received the most attention is referred to as capacity, management, operation, and maintenance (CMOM).This paper reviews the proposed CMOM rules in light of an integrated watershed modeling approach, an essential requirement for developing capital improvement plans that address the watershed as a whole, as opposed to isolated capital improvement projects addressing sitespecific SSOs.