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Combined Sewer Overflows and Sanitary Sewer Overflows: EPA's Regulatory Approach and Policy Under the Federal Water Pollution Control Act

June 1996

Citation: 26 ELR 10296

Issue: 6

Author: Kevin B. Smith

Editors' Summary: Combined sewer overflows and sanitary sewer overlows present unique problems for regulators. Although these problems were largely ignored until recently, EPA has finally begun to address the significant environmental and public health hazards these pollution sources pose. The author first provides a brief overview of the problems of combined and sanitary sewer overflows and the basis for their regulation under the FWPCA. He next discusses EPA's policy and guidance efforts to date, including the relevant documents' specific requirements and the concerns that shaped them. Finally, he presents some thoughts on the direction future regulaton of combined and sanitary sewer overflows should take.

Kevin B. Smith is an Assistant Regional Counsel in U.S. Environmental Protection Agency (EPA) Region 4's Office of Regional Counsel. Prior to his current position, Mr. Smith worked in the EPA Headquarters Office in Washington, D.C., and was involved in the development of several federal regulatory revisions under the Federal Water Pollution Control Act. He is a Senior Attorney in the area of water law, though his practice also includes hazardous wastes, toxics, safe drinking water, and underground storage tanks. Mr. Smith speaks frequently on environmental and water law issues and serves as an adjunct professor at the Emory University School of Law in Atlanta, Georgia, instructing in the areas of environmental law and water resources. Mr. Smith prepared this Article in his private capacity. No official support or endorsement by EPA or any other agency of the federal government is intended and should not be inferred.

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