In a recently issued Clean Water Act (CW A) draft guidance document, the U.S. Environmental Protection Agency (EPA) encourages municipalities to use green infrastructure and water quality trading to satisfy CW A permit requirements for storm water and waste water discharges. The draft guidance also calls for the use of flexible compliance schedules.
EPA plans to hold workshops on the guidance in Atlanta, New York City, Seattle, Kansas City, and Chicago starting January 31, 2012. 77 Fed. Reg. 1,687 (1/11/12) The agency will be soliciting input during the workshops from state officials, waste water treatment plant operators and environmental groups on a framework for municipalities that find it difficult to fully comply with costly water regulations.
EPA encourages municipalities to adopt an integrated approach or plan that could ultimately allow a single National Pollutant Discharge Elimination System (NPDES ) permit to manage both waste water and storm water discharges. The draft guidance would require municipalities and municipal-owned utilities to spell out potential noncompliance scenarios as well as projected future water quality requirements. It would also require them to characterize and identify waste water and storm water discharges, their infrastructure assets and deficiencies in existing infrastructures that would impede compliance.
Under the draft guidance, NPDES program requirements for sanitary sewers, combined sewer systems, municipal storm water sewer systems and waste water sewer plants could be accommodated in a single permit. After obtaining input from its five workshops, EPA will finalize the draft guidance.
