CWEA, and its Clean Water Summit Partners, submitted comments on the revised draft of the proposed Sanitary Sewer System (SSS) Waste Discharge Requirements (WDR) Monitoring and Reporting Program (MRP) released on March 18. One key provision of concern is a new requirement to provide photographic evidence for Category 1 and Category 2 sanitary sewer overflows. This new requirement does not meet the overriding purpose of the SSS WDR, which is to reduce SSOs in order to protect the environment and human health. In fact, it will slow down spill response time. While photographs may provide useful documentation, emergency responders need to prioritize efforts to contain and clean up SSOs.

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