The City of Memphis, Tennessee, has entered into a proposed consent decree with the U.S. Environmental Protection Agency (EP A) and Tennessee Department of Environment and Conservation under the Clean Water Act (CW A), agreeing to make improvements to its sewer systems, at an estimated cost of $250 million, to eliminate unauthorized overflows of untreated raw sewage. United States v. City of Memphis, No. 10-2083 (W.D. Tenn. filed 4/16/12). Under the proposed settlement, the city would replace portions of its wastewater collection and treatment system that are in the worst condition; assess 10 percent of its sewer system on an annual basis; and, develop, implement and improve a series of management, operations and maintenance programs. The city would also be required to conduct monitoring and testing to provide regular status reports to state and federal agencies. Under the agreement, the city must also pay a civil penalty of $1.29 million, half of which must be paid to the United States. The proposed consent decree is subject to public comment and court approval.