The CSO Partnership, now the Wet Weather Partnership, has enjoyed considerable success, especially on the national stage. We are an action-oriented organization that is flexible and able to act strategically. Our Board is committed to taking incremental approaches to issues, rather than waiting until the time might be right (if ever) for comprehensive success on a particular issue. This incremental approach has resulted in notable long-term cumulative impacts, even in difficult political environments.
Here are some of our accomplishments in recent years:
- Successfully opposed litigation brought by special interest groups seeking to force EPA and the states to impose pollutant limits on a daily basis for CSOs and urban storm water, rather than the average annual approach called for in the CSO Policy.
- We have supported the successful passage of CSO/SSO grant funding extension measures in both the House and Senate.
- We forced a vote on the House floor for Federal grant funding for municipal water quality infrastructure.
- We have supported the development of state legislation and regulation to implement reasonable and appropriate CSO control programs, including state grant funding programs.
- The Partnership drafted and was the lead lobbying organization for the Wet Weather Water Quality Act of 2000, which incorporated the CSO Policy into the Clean Water Act and authorized $1.5 billion in grant funds for CSO and SSO control.
- We successfully lobbied several budget amendments/riders to EPA’s budget. This included a provision in EPA’s FY 1999 budget requiring EPA to issue guidance to facilitate wet weather use reviews. More recently, we lobbied a 2004 rider to EPA’s budget that called for the use of State permits rather than orders and decrees to implement CSO long-term control programs. The 2004 language also clarified that CSO discharges do not have to meet water quality standards until after full implementation of their LTCPs.
- We successfully persuaded EPA to include several CSO and storm water related designated use reviews in EPA’s 2004 National Designated Use Plan.
- We played a major role in the development of EPA guidance related to the CSO Policy.
- We have led the national effort toward the development of wet weather designated uses and associated water quality standards.
- We have relentlessly challenged EPA over its guidance and approach to assessing community financial capability to determine implementation schedules and affordable levels of control.
- We have supported numerous CSO and storm water communities in precedent-setting permit actions. For example, we are supporting DC WASA in an appeal of its recently renewed NPDES permit for its CSO outfalls. We are also supporting a municipal coalition in litigation over MS4 storm water permit requirements. In that case we are objecting to numeric concentration and mass loading limits that are being proposed for storm water discharges in the District of Columbia.
- We have also conducted numerous national educational workshops that have typically sold out and all of which have received rave reviews from attendees with regard to the high quality of the substantive information that was provided.
- We routinely meet and work with EPA Headquarters and Regional Office leadership on a wide range of funding, regulatory, policy, and legislative issues.