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; doi:10.3390/su6052392

Author

Zeno F. Levy ^1,* , Richard C. Smardon ²

, James S. Bays ³

 and Daniel Meyer ⁴

¹

Department of Earth Sciences, Syracuse University, 204 Geology Laboratory, Syracuse, NY 13244-1070, USA

²

Department of Environmental Studies, SUNY College of Environmental Science and Forestry, 1 Forestry Drive, Syracuse, NY 13210, USA

³

CH2M HILL, 4350 Cypress St., Tampa, FL 33607, USA

⁴

IRSTEA Lyon (National Research Institute of Science and Technology for Environment and Agriculture, former CEMAGREF), 5 rue de la Doua, CS70077, Villeurbanne 69626, France

^*

Author to whom correspondence should be addressed. 

Received: 8 February 2014 / Revised: 11 April 2014 / Accepted: 16 April 2014 / Published: 25 April 2014

(This article belongs to the Special Issue Sustainability of Wastewater Treatment Processes and Management: Past, Present and Future)

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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. View Full-Text

Keywords: combined sewer overflow;  constructed wetlands;  green infrastructure;  environmental regulation;  policy;  National Pollution Discharge Elimination System

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