This article is the third installment of a four-part series addressing the importance of asset management. Part 4 will describe simple asset management strategies that utilities can implement now to improve regulatory compliance and reduce costs. Part 1 was a general introduction to asset management, emphasizing this "new direction" in competitiveness and describing the key elements of an effective asset management program. Part 2 explored the asset management implications of the new financial reporting standard, GASB 34, and analyzed what it requires as well as the choices it offers utilities for compliance.
By V. Kenneth Harlow, director of management services, Brown and Caldwell
Agencies with sewer collection systems will face a major asset management challenge with the EPA's proposed new Capacity, Management Operation, and Maintenance regulations. These "CMOM" regulations will become part of NPDES permit requirements. And for the first time, stand-alone collection systems will require NPDES permits.
Why is CMOM important?
CMOM is big news for sewer agencies. Spills, under almost any conceivable circumstance, are expressly prohibited. Further, the regulations will require that collection systems be actively and professionally managed. This will represent a major change for many agencies!
The most important of CMOM's many new requirements, which will apply to essentially all collection systems, are:
All these and more must be documented in a CMOM Plan ("CMOM program documentation"), which will be required in order to apply for an NPDES permit. The CMOM Plan will be a "living" public document, updated frequently and subject to self-audit annually. EPA will not judge the Plan, as the Plan itself will not be part of the permit. But having a thorough and complete CMOM Plan, and adhering closely to the plan, may help mitigate the regulatory response to spills.
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CMOM and asset management
From an asset management point of view, CMOM will require that you know your system in detailed and that you develop clear and comprehensive plans for maintaining its integrity. Specifically, a good CMOM Plan will include:
The last two items fall in the category of what the EPA calls "long-term spill mitigation." Regulators will be looking here for proof of your agency's willingness and ability to plan and manage your system effectively for the long haul, so that it has adequate capacity and stays in good condition over the years. This is clearly an asset management issue, and the methods normally used in asset management programs will be very relevant.
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The "CMOM gap"
In the author's experience, many agencies pay little attention to their collection systems. A lack of effective and programmatic CCTV procedures, which are required for organized condition assessment, is common. Even more agencies lack procedures for using information gathered by field crews to document spill information, grease buildup areas, root invasion locations, sags, offsets, protruding laterals, etc.
This inattention may be due, at least partially, to despair over gaining the funding needed to address system problems. As a result, many sewer agencies ignore their collection systems until conditions grow so bad that they can be ignored no longer. By that time, of course, pollution fines may be high and increasing, a consent decree may be in place, and the near-term costs may be enormous.
The proposed CMOM regulations will require a massive change in the way these agencies do business. Managing the collection system on a holistic basis will need to become part of an agency's day-to-day activities, just like cleaning is now. And effective asset management will need to become an integral part of normal business management.
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What is the status of CMOM?
The EPA submitted the proposed CMOM language to the Office of Management and Budget (OMB) over six months ago. At that time the language was expected back, with comments, in about ninety days. OMB evidently has had more than a few questions and comments!
The latest word is that the CMOM language should be returned to the EPA in the next week or so. It will then be published in the Federal Register and a 90-day public comment period will begin. After that, we can expect CMOM to become the law of the land in between one and two years. Just how quickly stand-alone collection systems will have to apply for NPDES permits is spelled out in the proposed CMOM language, available from the author.
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The EPA's proposed CMOM regulations will mean a whole new way of doing business for many sewer agencies. All aspects of collection system management will need to be documented, measured, and tracked. Managers will need to know the condition of their assets in great detail, and to plan for maintenance, repairs, upgrades, refurbishments, and replacements in an organized and systematic way.
Traditional long-interval exercises, such as master plans, will need to become living documents that are updated at frequent intervals. Analysis of system conditions and planning for the system's future will need to become a part of normal business operations. Above all, governing bodies will need to fund sewer systems at levels sufficient to maintain their long-term viability.
Part 2 explored the asset management implications of the new financial reporting standard, GASB 34, and analyzed what it requires as well as the choices it offers utilities for compliance.
Part 4 will describe simple asset management strategies that utilities can implement now to improve regulatory compliance and reduce costs.
About the author: V. Kenneth Harlow is Director of Management Services for Brown and Caldwell, a leading design and consulting firm with offices nationwide. Source documents mentioned in this series and analyses of GASB 34 and CMOM are available from Harlow by e-mail at firstname.lastname@example.org. For more information on Brown and Caldwell, call (800) 727-2224 or visit its web page at http://www.brownandcaldwell.com/.
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