A federal policy on sanitary sewer overflows (SSOs) remains an essential missing piece of the complex overflow puzzle. In the absence of a national policy and/or program for SSOs, EPA's current enforcement policies have forced many communities to commit tremendous resources in a fruitless
attempt to eliminate all SSOs. In many cases communities are forced to divert funds from other control efforts that would provide a greater overall benefit to the watershed in order to comply with SSO enforcement actions. The EPA's August 2004 Report to Congress on the Impacts and
Controls of CSOs and SSOs' (Report) characterization of SSOs nationwide provides some much-needed clarity regarding the proper direction for a national SSO program. Through the development of its recent Action Plan and continued work on the framework for a workable SSO program, NACWA
is recommending that EPA use the successful CSO Control Policy as a model for SSO control. This policy would apply a consistent technology-based standard (based on EPA's management, operation, and maintenance (MOM) program) to all collection systems nationwide and would require those collection
systems with recurring overflows to develop a system evaluation and capacity assurance plan. As described below, the policy would provide the flexibility necessary to incorporate SSO control into broader watershed planning efforts.
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