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separated system is not combined with sewage any overflows only contain stormwater and do not <br /> create the potential health hazards that this investment is intended to reduce.The other option is to <br /> build a containment basin and return the stormwater to the combined sewer system that contains <br /> wastewater. <br /> The preferred option for SDD is for the City to pipe the stormwater to a permitted stormwater discharge <br /> point keeping the separated stormwater out of the sewer system.If the stormwater system does not <br /> discharge to the sewer system,the connection to a stormwater discharge point would be part of the <br /> City's MS4 permit and would not be regulated by SDD's pretreatment program as no treatment would <br /> be required. <br /> The other option is similar to the residential sump pump connections described above on a much larger <br /> scale which,SDD does not encourage or support.If the storage and reintroduction plan is selected,SDD <br /> would need to provide a permit to the City.Because of the volume of water involved this permit would <br /> be subject to SDD's pretreatment ordinance and would require the City to test and treat the stormwater <br /> to prevent pollutants such as oils and chlorides and other constituents such as nutrients from entering <br /> the sewer system at the detention basin discharge point. <br /> Currently the cost of transporting and cleaning stormwater introduced to the collection system is not <br /> billed to anyone directly because there is no mechanism for recording the volume of water. If a <br /> detention basin is constructed there would now be a discharge point where the water can be measured, <br /> and the City's stormwater utility would be billed for the amount of water entering the system.There <br /> would be no SDD fees if the stormwater remains separated. <br /> Regarding the USEPA Consent Order,it is my understanding that City has submitted a plan to address <br /> the issues,however the USEPA has not responded to the City's plan.The goal of the Basin 5/6 project is <br /> to reduce backups and overflows by controlling stormwater.The best way to do this is to remove the <br /> stormwater from the system and route it to a stormwater discharge point.There is a very real possibility <br /> that the USEPA could object to the storage and reintroduction option after the project is completed and <br /> still require the stormwater to be routed to a MS4 discharge point. <br /> I look forward to hearing from you regarding the City's plan to address this matter. <br /> Respectfully, <br /> I <br /> Kent D.Newton,CPFO <br /> Sanitary District of Decatur <br /> Executive Director/CFO <br />