GEORGIA's INNOVATIVE APPROACH TO CMOM IMPLEMENTATION – GEORGIA MEMBER ASSOCIATION & STATE COLLABORATE TO IMPROVE SSO APPROACH

In 1998, the Georgia Environmental Protection Division (EPD) adopted a Zero Tolerance Policy for the area in and around metro Atlanta to address sanitary sewer overflows (SSOs). This policy required EPD to take an enforcement action against utilities for any SSO, regardless of the size, volume, or cause of the release. In response to this enforcement-based SSO strategy, at the request of its members, the Georgia Association of Water Professionals (GAWP) proposed an alternative implementation strategy to EPD. This GAWP developed alternative implementation strategy took the form of a voluntary model consent agreement. This consent agreement would require utilities to take a capacity assurance, management, operation, and maintenance (CMOM) -based approach to addressing SSOs.The GWEF's Collection Systems Committee (GWEF-CSC), comprised of volunteer members representing utilities, equipment manufacturers, regulatory agencies, consulting engineers, and other water professionals, collaboratively developed the guidance for implementation of this alternative strategy in a way that met the needs of the regulatory agencies, addressed the concerns of the utility owners, and served the interests of the public. This regional (zero tolerance area) solution developed by GAWP to address a regional issue (Zero Tolerance Policy) is now applied statewide by EPD, confirming the advantages of a collaboratively developed solution that incorporates national trends and industry best practices for improving utility business practices to achieve the regulatory goals of zero preventable SSOs and protection of the environment. This proved to be a win-win-win solution for utilities, regulatory agencies, and the environment.