CMOM Services
 Will CMOM Affect Your Utility?
Some collection system sanitary sewer overflows (SSOs) are unavoidable, but many are caused by inadequate operation or maintenance, inadequate system capacity, and outdated system design and construction. The new Capacity, Management, Operation, and Maintenance (CMOM) regulations, proposed by EPA under the Clean Water Act’s NPDES program, will provide a framework for municipal sanitary sewer system owners to address problem areas leading to SSOs.
If your public utility has an NPDES permit, you may be affected by the CMOM rule. Collection systems that operate as satellites to NPDES-permitted systems will also be impacted – directly regulated under the Clean Water Act for the first time.
CMOM Impacts
 In essence, the CMOM rule prompts collection system owners to develop a program that includes ongoing planning, continual review, and analysis, as well as preventive maintenance to mitigate the causes of SSOs. Activities required for CMOM compliance include:
- Sanitary sewer evaluations
- CCTV condition assessments
- Flow monitoring
- Hydraulic modeling
- Computerized maintenance management systems (CMMS)
- Security and vulnerability analyses
- Information systems and technology
- Collection system master planning
- Capital improvement programs
- Ordinance development/updates
- Finance, rates, fees, and funding alternatives
Primary Requirements of CMOM
- General standards for the proper management, operations, and maintenance of wastewater collection systems
- Program audits
- Comprehensive management program
- Overflow response plans
- System inventory
- System evaluation
- Capacity assurance plan
- Communications related to NPDES and annual reporting
Related Internet links:
http://cfpub.epa.gov/npdes/sso/ssorule.cfm
http://www.cmom.net
 Preparing for CMOM
Since our beginning in 1960, PBS&J has prepared annual reports and utility audits for collection system projects that formed the basis for the proposed CMOM rule. PBS&J has the experience to assist you with your CMOM compliance efforts with comprehensive services that include:
- GIS-based mapping of utility infrastructures
- Hydraulic system capacity modeling
- Needs assessment
- Cost estimation
- GASB Statement 34 asset management compliance
- NPDES program development, implementation, and reporting
- Program monitoring
- Overflow response planning
- Public notification assistance
- Financial planning
- Rate studies
- Database management
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