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When we deal with wet weather controls we're dealing with pollution that occurs
during rain events.
We have discharges from combined sewer systems, sanitary sewer systems
and storm water systems.
EPA has characterizeed wet weather flows as the biggest water
quality challenge of the 21st century.
Now, having made that statement
EPA
typically follows it up with regulations, and we are a heavily regulated market.
The CSO programs are governed by
the CSO control policy, which is codified in 2000.
SSO programs are governed by the pending SSO rule
which will deal with CMOM requirements,
permitting of satellite collection systems,
and the treatment of peak flows that arrive at
wastewater plants that are served by separate sanitary systems.
This blending issue has been a major regulatory challenge for the last ten years.
The storm water programs are governed by another pending regulation, the pending
storm water rule, which will be
drafted in December and finalized next year.
It will deal with requirements for
for new development in redevelopment,
possibly having retrofit requirements of existing development and EPA is even
considering numeric water quality based
limits
for stormwater permits.
So it's a very very significant regulatory challenge.
In addition,
the EPA's office of enforcement and compliance has identified wet weather as
their number one
enforcement priority in the Clean Water Act.
Their current initiative is called "Keeping Raw Sewage in Contaminated Stormwaters
out of the Nation's Waters."
And it focuses on
on working with municipalities to put them under consent programs to reduce
the discharges to the receiving waters.
We're also impacted by climate change.
Are the rainfall patterns that we base our analyses on changing? Are we seeing
more intense rainfall today then we have...
...are the storms bigger? So
the challenge of how we incorporate these going forward is significant.
EPA has also pushed for green infrastructure. In the last five years,
green infrastructure has become huge in the wet weather market,
and it's a challenge of how do we deal with them so that we're
dealing with the water before it gets into the system and what are the
benefits that can be derived there?
So, as we go forward...
I think we will continue to do things on a watershed basis.
We'll look at all of the sources of pollution.
What do the CSOs contribute?
What do other sources contribute? What's the upstream boundary? What's the
stormwater? So that there's an understanding of what's impacting it
because we need to understand it in order to come up with the proper
the proper solutions.
It'll be based on
detailed collection system modeling
state-of-the-art modeling will continue to advance particularly in the
hydrology area.
And because we're focused on receiving waters, we're going to see a much
greater reliance on receiving water quality models in the future to help us
understand the true impacts of these discharges and identify what are the
what are the
alternative means to attain compliance.
We'll also see
as we do the the collection systems, we'll be optimizing systems
and we'll be looking at repair and replacement needs so that we are dealing with the
pipes in the system that are fifty to hundred years old and need to be part of
the solution going forward.
We'll see
instances for the application of high rate treatment.
When we deal with these peak flows, be it in a combined system or a separate system,
we have high rate treatment that can very easily get us
equivalent primary.
We're still concerned with the dispute, the effluent from that in
terms of
disinfection effectiveness because pathogens are our main
water quality primary concern.
But as we move forward, we're also seeing can we stretch these
high rate treatment systems
and actually push
equivalent secondary
to help with the requirements there.
Collectively, I think
as we move forward because the focus is on receiving water compliance,
we will be looking aggressively
at the appropriateness of receiving water standards.
Are they protecting
properly the intended or existing uses?
And can we can with the regulators
with the state-of-the-art tools that we have developed
to modify changes or modifications to these standards...not to give license
to pollute, but to more accurately
protect the existing uses
and allow for short term excursions that do not compromise those uses.
So there are a lot of technology things that will be coming forward
and it's a very exciting time in the wet weather market.