Abstract

Stormwater runoff directly correlates to the amount of impervious surfaces on a property. Impervious surfaces allow the water to fill up pipes and streams faster, increasing the potential for street and/or storm system flooding during heavy rains and increasing maintenance and repair requirements of the storm sewer system. In late 2005, The United States Environmental Protection Agency (USEPA) performed a ‘wet-weather inspection’ in Peoria, Illinois. They determined that the City needed to make improvements to the combined sewer system. Further, in 2006, USEPA and the Department of Justice (DOJ) found the City of Peoria was in violation of the Clean Water Act (CWA), and offered to enter into a tolling agreement, in lieu of filing suit. The City agreed to negotiate and signed the first tolling agreement. In 2017, the City of Peoria provided the USEPA with its preliminary strategic assessment and proposed a sustainable solution to the CSO problem. This paper highlights various processes, strategies and legal challenges faced by the City of Peoria to meet its obligations to the USEPA. In early 2018, the City of Peoria will complete its strategic assessment and reach a final agreement with the USEPA. This paper will provide insights for other cities and communities to examine and utilize various innovative and sustainable solutions to CSO problems facing similar cities across the globe. Further, the authors will provide meaningful guidance on awareness and strategic communication with the general public to justify expected increases in utility rates. The paper will outline the processes involved in meeting the legal challenges presented by the USEPA and its mandates for clean water in Peoria, Illinois, USA. It is expected that the proposed green solution will require an investment of $200 million to $300 million.

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