CMOM - Capacity Management Operations and Maintenance

The U.S. EPA continues to develop proposed National Pollutant Discharge Elimination System (NPDES) permit requirements for capacity, management, operation and maintenance (CMOM) programs for municipal sanitary sewer collection systems. Primary goals of CMOM are as follows.

1. Better manage, operate, and maintain collection systems
2. Investigate capacity constrained areas of the collection system
3. Reduce and/or Eliminate sanitary sewer overflow (SSO) events

The goals of both CMOM and GASB 34 are to push utilities towards better stewardship of public assets. This is the prime intent of asset management, so the intent of both initiatives is consistent with a good asset management program. The difficulty lies in the way which both are being applied in the field. In the case of CMOM, its provisions are being applied to reduce or eliminate sewer overflows (SSO's) as the nature of the rule indicates. The problem is that the tendency will be to focus on the elimination of the immediate problem (the SSO) as quickly and cheaply as possible. This is also by nature contradictory of a good asset management approach.

A good asset management program, by definition is a long term program. The four key elements should be.

1. Attain and sustain a desired level of service.
2. For the long term of the asset.
3. For the lowest cost.
4. For the lowest risk.

What are Sanitary Sewer Overflows (SSO's)?

A sanitary sewer overflow can spill raw sewage into basements or out of manholes and onto city streets, playgrounds and into streams, before it can reach a treatment facility. It is defined as anytime sewerage leaves the system for any reason.

http://cfpub.epa.gov/npdes/docs.cfm?document_type_id=3&view=Factsheets%20and%20Outreach%20Materials&program_id=4&sort=name