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Indiana CSO Scoring System

Why is an Environmental Scoring System Needed?

106 Indiana communities have combined sewer systems - more than 10% of the nation’s total. Each year, these systems discharge more than 20 billion gallons of raw sewage, partially treated industrial waste, and storm water to Indiana’s rivers and streams through outfalls called combined sewer overflows (CSOs).

Suburban development has exacerbated the problem as many communities engaged in dramatic and often unrestrained growth. Communities gave housing and commercial developments valuable space in the combined sewer collection system that was previously reserved for storm water to handle the development’s sanitary sewage. As a result, some combined sewer systems run nearly full during dry weather and overflow with as little as one-tenth of an inch of rain.

The overflows are typically worst in the older neighborhoods of urban areas. Residents in these neighborhoods often have a lower income than the rest of the community forcing them to bear the brunt of the sewage impacts. This disproportionate impact raises serious environmental justice concerns and prompted Improving Kids’ Environment and other environmental, civil rights, and neighborhood organizations to file a civil rights complaint to EPA against one Indiana city.

Some Indiana communities have begun to voluntarily address this problem. But most have not moved past the minimum required controls. During the next ten years, the CSO communities will be required to invest more than $2,000,000,000 in public funds to reduce the impacts of combined sewer overflows on the quality of our rivers, streams and lakes.

The primary mechanism to define and guide this massive investment is a Long Term Control Plan. Each community must develop a LTCP pursuant to national and state guidance over the next five years on a staggered schedule derived from the date when their NPDES permit was renewed. The Indiana Department of Environmental Management must review and approve a plan for it to be effective.

Through this process, LTCPs play a critical role in the restoration of the Indiana’s river and streams - especially when complemented with comprehensive watershed planning that addresses agricultural runoff, septic systems, confined animal feeding operations and other non-point sources of pollution. Because of this role, the environmental groups listed above decided to undertake the enormous task of evaluating the plans as they are submitted to IDEM.

After reviewing the federal guidance, it was clear that there are few mandates and hundreds of recommendations that communities can accept or reject. While this latitude is reasonable given the wide variety of CSO communities, it is difficult to cull from the guidance which recommendations are most important for the success of the program. Therefore, the groups developed a scoring system to help communities and their residents identify the most important recommendations and give them serious consideration. A community’s LTCP score reflects those aspects of the plan and the planning process that are most likely to achieve the three goals identified above.

The scoring system is derived from EPA’s Combined Sewer Overflow: Guidance for Long-Term Control Plan published in September 1995. Indiana Code 13-11-2-120.5(2) requires that a LTCP be developed in accordance with the recommendations set forth in that publication. The scoring system relies most heavily on the Suggested Long-Term Control Plan Evaluation Checklist found in Appendix D of EPA’s Combined Sewer Overflow: Guidance for Permit Writers. This document is one of a series of documents referenced by EPA’s Combined Sewer Overflow: Guidance for Long-Term Control Plan.

Three additional items to note about the scoring system:

• Makes special accommodations for small CSO communities because of their limited resources. Communities with fewer than 10,000 residents and 5 or fewer CSO outfalls will not be expected to perform several of the water quality evaluations as well as the environmental justice analysis. If these communities perform the evaluations, they will effectively receive extra credit in their score. 60% of Indiana’s CSO communities should qualify for this special accommodation.
• Is NOT sanctioned by IDEM. This evaluation is intended to complement IDEM’s review and approval of LTCPs.
• May need to be refined when IDEM issues its guidance for the development of LTCPs as required by law by October 1, 2000.

The groups will regularly publish the results of the evaluation on the Internet and in other forms.

Please note that a high score does not constitute an endorsement of a community’s plan by any group. Instead it is a tool to help assess the potential of the plan to achieve the state’s goals.

Contact Tom Neltner at mccabe@ikecoalition.org for a hard copy or electronic copy of the complete scoring system.