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MUNICIPAL CONSENT ORDERS
Overview
The Consensus Process
In April 2002, the municipal officials, engineers and solicitors
of the ALCOSAN service area communities began negotiations with
the Environmental Protection Agency, PA Department of Environmental
Protection (DEP) and the Allegheny County Health Dept. (ACHD) regarding
municipal consent orders for their sewage collection systems. Almost
two years later in January 2004, nearly 100 percent of the municipalities
signed consent orders that are feasible and cost-effective for
the communities while also meeting the objectives of the regulatory
agencies to comply with the Clean Water Act.
During those two years, 3 Rivers Wet Weather facilitated an extensive
consensus-building process for the municipal representatives of the communities
within the ALCOSAN service area through more than 150 meetings. Throughout
this process, the municipal officials, solicitors and engineers worked together
across municipal boundaries in an unprecedented manner.
Highlights of the process include:
- February 2002: EPA proposes a non-traditional enforcement approach—municipal
consent orders, one designed for combined sewer communities
and another for separate sanitary communities—which do not include
penalties for past and current violations of the Clean Water Act and
the Clean
Streams Law.
- April 2002: DEP and ACHD distribute an initial draft of the
consent orders. 3RWWDP initiates a consensus-building effort
for the development of a more feasible and cost-effective version of
the proposed
consent orders.
- August 2002: The municipalities submit to the agencies, proposed
consensus-based draft orders.
- May 2003: the regulatory agencies distribute another draft
agreement to the ALCOSAN communities. 3RWWDP again initiates
a consensus-building effort to continue the negotiations and work toward
feasible consent
orders.
- Late October/November 2003: ACHD and DEP distributed final
consent agreement documents to all 83 ALCOSAN communities
with a signing deadline of January 31, 2004.
- February 19, 2004: A Moving Forward 2004 event is held at the
David L. Lawrence Convention Center to mark the region’s progress
on the wet weather sewage overflow issue.
Consent Order Requirements
Under the municipal consent orders, the EPA assigned enforcement
responsibility to the DEP and ACHD. Municipalities operating a combined
sewer system (carrying wastewater and stormwater in the same set of pipes)
received a “Consent Order and Agreement,” which is enforced
by the DEP. Communities with a separate sanitary sewer system (wastewater
and stormwater are transported in two separate systems) received an “Administrative
Consent Order,” which is enforced by the ACHD. The orders span six
years (2004-2010), and require communities to complete the following activities:
- Assess and map the sewer collection system
- Clean and televise the system
- Make critical repairs
- Conduct flow monitoring
- Develop a long-term control plan in conjunction with ALCOSAN
For a specific timeline of required activities, click the appropriate order below:
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