NEIWPCC recently weighed in on the EPA’s proposed allotment formula for the Sewer Overflow and Stormwater Reuse Municipal Grants program.
In a letter dated September 3, NEIWPCC, on behalf of our member states, provided comments addressing the proposed formula allotment for funding that will help manage combined sewer overflows (CSOs), sanitary sewer overflows (SSOs), and stormwater.
The letter was in response to Docket ID No. EPA-HQ-OW-2020-0282.
While Section 4106 of the America’s Water Infrastructure Act (AWIA) amended Section 221 of the Clean Water Act (CWA) to reauthorize the Sewer Overflow and Stormwater Reuse Municipal Grants Program, NEIWPCC notes that the proposed formula relies on old data.
Much of the data (approximately 83%) used to determine allocations is based on the 2012 Clean Watersheds Needs Survey (CWNS) and the 2010 U.S. Census.
NEIWPCC also noted that the 2012 CWNS “did not include complete CSO, SSO, and stormwater infrastructure needs” and by “factoring data into the formula that is specific to CSO, SSO, and/or stormwater events would be much more helpful in allocating investments to address those issues.”
Additionally, NEIWPCC, on behalf of its member states, requested that the EPA increase the weighting factor in the proposed formula for average annual precipitation, and “deemphasize the weighting factors for Total Population and Urban Population”, instead focusing on “only the urban population where issues with CSOs, SSOs (municipal sewer systems) and stormwater are most prevalent.”
NEIWPCC also requested the EPA extend its 30-day comment period, which closed on September 3, for an additional 60 days to “allow for further discussion within and among the states” regarding the proposed allotment formula.