Executive Summary

Today, the United States is the richest and most powerful nation in the world. Across the globe, government leaders and concerned citizens look to this country as a model of technological advancement and effective infrastructure management.

Let's hope they're not looking too closely at our sewage collection system. These pipes, some as much as 200 years old, carry enough raw sewage to fill the Great Lakes about every four months.¹ Laid end to end, the pipes that carry raw sewage from America's homes, businesses, institutions, and industries would stretch to the moon and back -- twice.² But in too many communities across the land, pipes are broken or leaking, systems are overloaded, and treatment is sometimes bypassed. The result is that in this most technologically advanced nation on the face of the planet, raw sewage backs up into people's homes with disturbing frequency, and is routinely permitted to flow into bodies of water that are sources of drinking water.

Theoretically (and by law), all this raw sewage, with its cargo of infectious bacteria, viruses, parasites, and a growing legion of potentially toxic chemicals, gets treated in wastewater treatment plants. But in reality, this aging, often neglected, and sometimes insufficient network of pipes releases untreated or only partly treated sewage directly into the environment.³ The average age of collection system components is about 33 years, but some pipes still in use are almost 200 years old.^4,5

Ironically, the nation at the forefront of the information age has about as clear a view of the quantity of raw sewage that leaks, spills, and backs up each year as we do of the sewage pipes buried beneath our feet. In the face of woefully inadequate data on the frequency and volume of sewage overflows, the Environmental Protection Agency's best guess is that every year, for every county in the United States, enough untreated sewage overflows to fill both the Empire State Building and Madison Square Garden.⁶ These raw sewage overflows, occurring primarily during wet weather, spill into our recreational and drinking water, into groundwater, and directly onto private property, often in the form of basement backups.

Health experts in government, academia, and the private sector voice concern over lack of information and potential health impacts, particularly for the most vulnerable in our society (young children, the elderly, the immuno-suppressed, etc.) who are more susceptible when exposed to the mix of infectious organisms and toxic chemicals in untreated sewage. The problem is compounded by the rise of antibiotic-resistant "superbugs," emerging infectious organisms (such as SARS) that can be transmitted through sewage, and increases in the release of myriad toxic industrial chemicals into sewage collection systems. While there's disagreement over whether the numbers of people made sick every year from waterborne diseases in the United States are in the hundred thousands or millions, there is wide agreement that not enough information is being collected to protect public health.

This problem is bound to worsen as: (1) population growth puts added pressure on sewage collection and treatment systems already operating at or above design capacity; (2) urban sprawl creates more land area impervious to stormwater, further aggravating insufficiencies and weaknesses in the collection system during wet weather; (3) climate change increases the frequency and severity of storms in some areas; and (4) proposed changes to existing laws expose more people to untreated sewage.

Recommendations

Lack of engineering solutions is not the primary obstacle to fixing the problem of sewer overflows. Rather, what is needed is political will, enforcement of existing laws, adequate information, and billions of dollars to improve the integrity and capacity of the wastewater system infrastructure. While the costs of correcting this problem are high, ignoring it will be even more costly. Sewage overflows already cost billions every year in cleanup, emergency repair, lost tourism revenue, lost productivity, and medical treatment.

Increase federal funding for wastewater infrastructure and enforcement: Federal funding for wastewater infrastructure received the largest cut of any environmental program in President Bush's budget proposal for fiscal year 2005. The president is cutting funding while needs are spiraling out of control. The federal government should greatly increase its contribution to water infrastructure needs through a clean water trust fund. Just as a trust fund exists for highway and airport expenditures, the government should establish a trust fund for clean water. Until a trust fund is in place, funding should be increased substantially for the Clean Water State Revolving Fund -- a program with an impressive track record of low-interest loans to localities for clean water projects -- and for grants to assist communities in controlling combined sewer overflows.⁷

Enforce current sewage treatment plant requirements instead of allowing wet weather discharges of inadequately treated sewage: Sanitary sewer overflows are illegal, yet the EPA estimates that the number of these overflows is growing.⁸ Instead of weakening environmental standards through its recently proposed policy changes, which would allow sewage to bypass certain treatment processes, the Bush administration should enforce the Clean Water Act to protect public health and the environment. Only when sewer operators know that the administration will enforce the law will they have an incentive to invest in solutions.

Fully fund and implement the federal BEACH Act of 2000: Beach closures and advisories due to high bacterial levels are at record high numbers across the United States. The Beaches Environmental Assessment and Coastal Health Act of 2000 (BEACH) requires that by April 2004, states with coastal recreational waters adopt the EPA's recommended water quality standards for bacteria and requires the EPA to update its pathogen standards by October 2005.⁹ The EPA should establish water quality criteria for pathogenic viruses Cryptosporidium, and Giardia, as their presence is not well correlated with bacteria-based health standards in drinking and recreational waters and they are a leading cause of waterborne illness in the United States.

The BEACH Act also authorizes $30 million per year for state grants for monitoring and public notification, yet the EPA has provided only $10 million in annual grants since 2001 due to inadequate congressional funding. The BEACH Act should be fully funded and grants should be used for identification of beachwater contamination sources, as well as for monitoring and public notification.

Promulgate provisions of the sanitary sewer overflow (SSO) rule: In January 2001, the Bush administration announced it would set aside for further review a proposed regulation designed to keep bacteria-laden raw sewage discharges out of America's streets, waterways, and basements and make public reporting and notification of sewer overflows mandatory. The rule was based on consensus recommendations of a federal advisory committee that studied the matter for five years. The EPA still has not completed its review of the SSO rule. The agency should issue rules consistent with the recommendations of the federal advisory committee.

Require monitoring and public notification: While the EPA has the legal authority to move forward with regulations to require monitoring and reporting of raw sewage overflows, it has not done so. Therefore, NRDC and EIP urge passage of legislation introduced in Congress by Rep. Timothy Bishop (D-NY), the Raw Sewage Overflow Community Right-to-Know Act (H.R. 2215), which would force the EPA to require sewer operators to set up a program to monitor for sanitary sewer overflows and notify the public and public health authorities of raw sewage discharges.

Create a national "Sewage Release Inventory": The EPA's Toxics Release Inventory is a public database of toxic chemical releases by certain industries. A similar database of sewage releases could spur significant, voluntary reductions in raw sewage releases by making public the quantity, frequency, and impact of sewage overflows from particular sewer authorities.

Sewage authorities, local governments, and states with the highest number and volume of overflows nationally or regionally would likely be spurred to action to get out of the public spotlight. Conversely, others might be inspired by the opportunity for public recognition of good performance.

Adopt water quality standards for nutrients: Nutrients input from human sewage are implicated as a major source of harmful algae blooms in waters at our nation's bay and estuarine beaches. The EPA should require states to adopt water quality standards for nutrients, set water quality-based effluent limits for sewage treatment plants on the basis of narrative and numeric standards, and require biological nutrient removal to limit nutrient discharges into impaired waters.

Fill the data gaps: The American Society of Microbiologists concluded in 1999 that a database of information on exposure to waterborne pathogens, which would include the frequency of sewer overflows, pathogens present in the sewage, and disease outcomes of exposed individuals, is necessary to assess risk, but no such database exists. The EPA and Centers for Disease Control should work together to fill that gap with comprehensive data from across the country, new analysis and epidemiological studies, a publicly available, searchable database, and a public education campaign. Lack of adequate information on waterborne disease is putting people at risk.

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Notes

1. The EPA reports U.S. average daily sewage flow equals 50 trillion gal x 365 days = 18,250 trillion gal/year. Great Lakes occupy 5,652 miles3 or 6,224 trillion gal (www.greatlakes-seaway.com/en/navigation/cruises_facts.html) = 0.34 years to fill Great Lakes with sewage.

2. The EPA estimates ~500,000 miles of municipal pipes and ~500,000 miles of private pipes connected to municipal systems: U.S. EPA, Notice of Proposed Rulemaking, National Pollutant Discharge Elimination System (NPDES) Permit Requirements for Municipal Sanitary Sewer Collection Systems, Municipal Satellite Collection Systems, and Sanitary Sewer Overflows (January 4, 2001) (note: there are no official page citations available since this proposal was not published), p.17; average distance from earth to moon is ~240,000 miles.

3. For this report, sewer overflows include all dry and wet weather releases of sewage into the surrounding environment from anywhere in the sewage collection system prior to the headworks of the publicly owned treatment works.

4. U.S. EPA, Notice of Proposed Rulemaking, op. cit., January 4, 2001, p. 25.

5. U.S. EPA, The Clean Water and Drinking Water Infrastructure Gap Analysis, Office of Water, EPA-816-R-02-020, September 2002, p. 8.

6. The EPA estimates 1.26 trillion gal discharged from CSOs alone annually. National Association of Counties counts 3,066 U.S. counties; Madison Square Garden = ~13.7 million ft3 or 102.86 gal (www.praxair.com/ praxair.nsf/0/cabd4f9cc57eccbe852565b00075aa23?OpenDocument); Empire State Bldg = ~37 million ft3 or 276.78 million gal (www.esbnyc.com/ tourism/tourism_facts.cfm).

7. 33 U.S.C. 1381 et seq.; 33 U.S.C. 1301.

8. Personal communication with Kevin DeBell, U.S. EPA, December 2003.

9. Beaches Environmental Assessment and Coastal Health Act of 2000 (P.L. 106-284 (October 10, 2000).