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Sustainability 2014, 6(5), 2392-2412; doi:10.3390/su6052392
Article

A Point Source of a Different Color: Identifying a Gap in United States Regulatory Policy for “Green” CSO Treatment Using Constructed Wetlands

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Received: 8 February 2014; in revised form: 11 April 2014 / Accepted: 16 April 2014 / Published: 25 April 2014
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Abstract: Up to 850 billion gallons of untreated combined sewer overflow (CSO) is discharged into waters of the United States each year. Recent changes in CSO management policy support green infrastructure (GI) technologies as “front of the pipe” approaches to discharge mitigation by detention/reduction of urban stormwater runoff. Constructed wetlands for CSO treatment have been considered among suites of GI solutions. However, these wetlands differ fundamentally from other GI technologies in that they are “end of the pipe” treatment systems that discharge from a point source, and are therefore regulated in the U.S. under the National Pollution Discharge Elimination System (NPDES). We use a comparative regulatory analysis to examine the U.S. policy framework for CSO treatment wetlands. We find in all cases that permitting authorities have used best professional judgment to determine effluent limits and compliance monitoring requirements, referencing technology and water quality-based standards originally developed for traditional “grey” treatment systems. A qualitative comparison with Europe shows less stringent regulatory requirements, perhaps due to institutionalized design parameters. We recommend that permitting authorities develop technical guidance documents for evaluation of “green” CSO treatment systems that account for their unique operational concerns and benefits with respect to sustainable development.
Keywords: combined sewer overflow; constructed wetlands; green infrastructure; environmental regulation; policy; National Pollution Discharge Elimination System combined sewer overflow; constructed wetlands; green infrastructure; environmental regulation; policy; National Pollution Discharge Elimination System
This is an open access article distributed under the Creative Commons Attribution License which permits unrestricted use, distribution, and reproduction in any medium, provided the original work is properly cited.

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MDPI and ACS Style

Levy, Z.F.; Smardon, R.C.; Bays, J.S.; Meyer, D. A Point Source of a Different Color: Identifying a Gap in United States Regulatory Policy for “Green” CSO Treatment Using Constructed Wetlands. Sustainability 2014, 6, 2392-2412.

AMA Style

Levy ZF, Smardon RC, Bays JS, Meyer D. A Point Source of a Different Color: Identifying a Gap in United States Regulatory Policy for “Green” CSO Treatment Using Constructed Wetlands. Sustainability. 2014; 6(5):2392-2412.

Chicago/Turabian Style

Levy, Zeno F.; Smardon, Richard C.; Bays, James S.; Meyer, Daniel. 2014. "A Point Source of a Different Color: Identifying a Gap in United States Regulatory Policy for “Green” CSO Treatment Using Constructed Wetlands." Sustainability 6, no. 5: 2392-2412.


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