Proactive Programs and Partnering with EPA Impacts Enforcement Action Outcome

In April 2002, the United States Environmental Protection Agency delivered Administrative Order CWA-309-9-02-17 to the City of San Diego requiring the development of 13 wastewater collection system plans. The order sets forth a comprehensive set of requirements that address all of the major components of controlling sanitary sewer overflows, from operations and maintenance requirements to rehabilitation and replacement of sewer pipes. This paper describes the advantages of the proactive planning, analysis, and implementation activities that the City performed prior to issuance of the Administrative Order and how these activities, along with open dialogue and partnering with the EPA, resulted in the development of Administrative Order requirements that are aligned with City goals and strategies.