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MWMC WASTEWATER FACILITIES PLAN AND SYSTEM DEVELOPMENT CHARGE UPDATE - RESPONSE TO APRIL 2, 2004, QUESTIONS FROM EUGENE CHAMBER OF COMMERCE The DEQ standard considers water quality in its development of an overflow frequency standard. Specifically, the standard is based on the bacteria specifications of the State water quality regulations. DEQ requires that sanitary sewer collection systems not discharge untreated wastewater for storm events smaller than the 5-year, 24-hour duration recurrence interval during the winter months. This water quality-based standard is used by all wastewater agencies throughout the State as their design criteria. Because it is based on impacts to receiving water quality and takes into account the seasonal river flows, it is considered a more common sense standard. It is this Oregon DEQ standard that the 20-year project list is based on. Relative to the draft EPA SSO policy that would prohibit overflows for nearly all wet weather events, the Oregon standard is certainly a more common sense standard. If the Federal EPA SSO rule were to be implemented, there would be significant increases in both projects and costs to the current 20-year project list. Perhaps more importantly, however, is the set of standards and expectations that were developed and adopted in the MWMC Wet Weather Flow Management Plan. Completed in 2001, this plan involved an exhaustive review of the performance that should be achieved in managing peak flows. A citizen advisory committee (CAC), made up of a broad spectrum of community interests and stakeholders, found consensus in the objective that overflows should be eliminated, and that the treated wastewater should be treated to a higher standard than it is currently during peak flow conditions. While the CAC did not pursue the most aggressive capital improvement program, it recommended an approach that balanced cost and benefits of building increased increments of peak flow capacity. The Facilities Plan carries forward these citizen recommendations, which became adopted policy by the MWMC and which have served as the guidance for the Cities' I/I programs since 2001. CHAMBER OF COMMERCE RESPONSES FINAL. DOC PAGE 8 OF 8