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Wet Weather Integration: a Summary of Benefits and Challenges

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Over the past several years, the Environmental Protection Agency (EPA) has focused efforts on promoting the use of a watershed-based approach to water quality management. For the National Pollutant Discharge Elimination System (NPDES) permit program, the effort produced policy statements and guidance directed at how permitting authorities and permittees could benefit from developing and issuing NPDES permits on a watershed basis. During the development of the guidance, EPA recognized the importance of addressing wet weather sources. A substantial amount of water quality impairment is attributed to municipal wet weather sources of pollution to receiving waters, such as storm water, combined sewer overflows (CSOs), and sanitary sewer overflows (SSOs). Although these discharges contribute the same types of pollutants, they can be extremely variable in frequency, duration, volume and pollutant load from one wet weather event to the next. This variability makes it difficult for communities to manage wet weather discharges. It also makes it difficult for NPDES permitting authorities to draft permits to address wet weather discharges. Current regulatory and management approaches address these wet weather sources under at least three separate NPDES programs. Despite the fact that these programs all involve sewer pipes and other infrastructure, they do not effectively address the interconnectivity of municipal wet weather discharges. This may result in less progress in achieving water quality improvements than could be made if these sources were considered collectively. This concept of considering the sources collectively is termed "wet weather integration." EPA believes that integration across multiple wet weather programs will achieve the water quality goals of the Clean Water Act in a more efficient manner. Although NPDES permit holders and permit authorities have expressed interest in managing wet weather issues collectively, relatively few communities have integrated activities to address municipal wet weather discharges. Where communities have taken steps towards integration, limited information has been compiled on how well these programs/permits are working. The purpose of this presentation and paper is to discuss the benefits and challenges of implementing a "wet weather integration" approach. Specifically, it will summarize the benefits and the challenges for permit holders and for permitting authorities in developing an integrated permitting or management approach. This presentation and paper will make use of case examples to describe different approaches that have been used to integrate municipal wet weather permits/programs, and describe common experiences in investigating and/or implementing integrated approaches. These common experiences, realized or perceived benefits, and realized or perceived challenges—including both the benefits and challenges within the permitted communities themselves, and also the benefits and challenges between the permitted communities and the permitting authorities— will also be summarized.
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Keywords: CSOS; NPDES; PERMITTEE; PERMITTING; STORM WATER; WET WEATHER

Document Type: Research Article

Publication date: 2007-10-01

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