Capacity, Management Operation, and Maintenance (CMOM), an EPA requirement, will become part of NPDES permit requirements. CMOM is priority news for sewer agencies. Regulations will require that collection systems be actively managed, conditions assessed with full documentation, and measurement of planned versus actual procedures for repair, upgrades, etc. In addition, agencies must evaluate their needs and put in place a technical and financial commitment for a long-range system asset rehabilitation and replacement program.

Documentation will be required, and reported annually, in order to apply for an NPDES permit.

To avoid hefty fines, your CMOM plan should include:

•Complete inventory of sewer system assets
•Guidelines and documentation for determining the condition of these assets.
•Procedures for determining short-term and long-term repair and upgrade needs with documentation of work completed versus work planned.*
•Summary of planned needs for long-range system asset rehabilitation and replacement. Also, documentation of technical and financial commitment to do the job correctly.*

*Note: This is where regulators will be looking, and is referred to as "long-term spill mitigation". You'll need proof of your agency's ability to plan and manage your system effectively for the long-term. This is so that it has adequate capacity and remains in good condition over the long haul.