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On June 12, 2017, the Nebraska Department of Environmental Quality issued a permit modification to the City’s National Pollutant Discharge Elimination System (NPDES) Permit that covers the City’s combined sewer system. This modification was at the City’s request to change compliance dates to the CSO Long Term Control Plan schedule included in the permit. Approval was obtained in less time than it normally takes the Nebraska Department of Environmental Quality to make similar modifications. This is a recent example of how the City’s trusted working relationships with Nebraska Department of Environmental Quality have benefited the City.
The City’s Consent Order with Nebraska Department of Environmental Quality for the CSO Program was negotiated in 2007. It is based on a unique approach to ensuring City implementation of projects under the Long Term Control Plan. It is typical for Consent Orders and decrees to include all projects required under the Long Term Control Plan, each with a completion date. Any modifications to these dates require a reopening and renegotiation of the Consent Order. During negotiation of Omaha’s Consent Order, Nebraska Department of Environmental Quality and the City agreed to not include project deadlines in the Order but instead to include them in as appropriate in each renewal permit for the combined system. These Permits are renewed every five years. This approach allows for changes in project deadlines to be addressed easily and quickly. Ongoing communication and coordination between the City and Nebraska Department of Environmental Quality have resulted in permit modifications that have saved the City money, while continuing to make progress toward meeting regulatory requirements.
The recent permit modification addressed several project dates that could have resulted in permit violations. They include the following:
The CSO efforts above are examples of the City’s adaptive management approach to the CSO Program, whereby modifications are made to address changing conditions, improve the overall Program and reduce costs. Positive working relationships with the Nebraska Department of Environmental Quality and a flexible Consent Order allow modifications to be made without costly reopenings of the Consent Order. This kind of flexibility will continue to be valuable to the Program as the City and the Program Management Team consider future performance assessments, optimization and investments in other aspects of City infrastructure.