Wet Weather Partnership National Association of Clean Water Agencies Water Quality Compliance Strate

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Wet Weather Partnership National Association of
Clean Water AgenciesWater Quality Compliance
Strategies and Key Long-TermControl Plan
Developments for CSO CommunitiesChicago - June
2006

• Long-Term Control Plan Development Issues
• Clyde Wilber

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(No Transcript)
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Issues

• Presumptive Approach When?
• Which of the Three Criteria??
• Demonstration Approach When?
• Obtaining LTCP approvals

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PresumptiveApproach

• Meet one of the three criteria
• 4 to 6 overflows per year ( smaller events get
  Primary Treatment
• 85 of the CS volume gets Primary Treatment
• Pollutant Mass capture equal to 85 volume
  control with Primary treatment
• ANDgtgtgt
• Permit Writer can REASONALBLY assume WQS will be
  met

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Why Presumption?

• Because data and modeling of wet weather events
  often do not give a clear picture of the level of
  CSO controls necessary to protect WQS.

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Presume WQS are met? What were they thinking in
1992?

• Office of Water View
• Environmental Activist View
• Municipal View
• 2006 The OECA View

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Demonstration

• Demonstrate WQS met
• Though less than Presumption
• .. or not met
• Due to nature background or pollution other than
  CSO
• Stormwater
• Upstream Load
• Urban Conditions
• Human Caused Conditions that can not be removed??

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Getting to YesQuestions You Should Ask

• Where is Enforcement Coming From?
• What Rules Does Enforcement Live By?
• What is the Path for Municipalities?
• Was that a yes?

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What does enforcement want?

• Expect a plan to meet WQS
• Expect all the dots and crosses
• Are interested in outcome even if it is not
  clear from the agencies stated goals
• Will respond to a plan that is in line with CWA
  goals
• But
• expect local government to do it
• Want what George wanted

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Getting a to yes

• It helps to show you meet one of the presumption
  criteria
• The level of control that satisfies
• Two views

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Getting to yesTwo views of public spending

• Civil/Environmental Engineering
• Good Rate of Return, Cost/Benefit
• Public sees a Benefit They Want
• Enforcement
• Meet Water Quality Standards as written, or if
  meeting standards is not feasible
• Eliminate pollution to the point your source will
  not cause or contribute to violations if all
  other sources were controlled
• Spend to Limit of Economic Capability

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Getting to YesThe level of control that
satisfies

• Level beyond which little or no benefit accrues
• Limit of economic capability
• Level at which WQS met if all other sources were
  controlled
• Level at which WQS would be met if there were no
  other sources

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Getting to Yes

• The Original 1.5 of MHI
• Morph to 2 MHI
• What is a community?
• Service Area
• Political Jurisdiction
• Core City
• Urban Core

Show me the Money!
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Economic Capability A poor tool for deciding
what you should do

• Spend to the Limit of Economic Capability
• Plan A restores 90 percent of Uses at 50 of
  Economic Capability
• Plan B restores 90.1 percent of uses at 150 of
  Economic Capability
• Go to Plan B-minus at 100 of Economic
  Capability restoring 90.001 of Uses or
• Extend the Schedule indefinitely spending at the
  Limit
• Is Using Economic Capability or Control to the
  Point where you do not Contribute Public
  Malfeasance?
• Reserve Public Money for expenditures that
  actually produce a measurable benefit?

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First Have a Plant that Provides Real Benefit
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Getting to Yes Use it all

• First have the plan you want to build
• Fix the real problems
• Protect the public
• Meet all the process
• Understand your regulators problems solve them
  if you can
• But
• Dont offer to build something you do not believe
  has a benefit