Getting Going

A booklet created by a state regulatory agency provides a simple blueprint for smaller communities seeking to establish effective CMOM programs

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The U.S. EPA’s Capacity, Management, Operations & Maintenance (CMOM) program for sewer systems is not yet officially on the books, but municipalities across the nation are working on compliance with its basic provisions.


For smaller communities, the process can be intimidating. A team at the Wisconsin Department of Natural Resources Bureau of Watershed Management is striving to make it less so.


With help from an EPA grant, the bureau has published a booklet, Wisconsin CMOM, that breaks the process down into easily digestible steps. Its purpose is to help smaller communities get a start toward complying with CMOM making necessary improvements to their collection systems.


In just 25 pages, the booklet lays out the key steps to CMOM programming in logical order. They are:

• Set your goals.

• Know your organization.

• Understand your legal authority.

• Operation and maintenance.

• Design and performance standards.

• Emergency overflow response plan.

• Capacity assurance review.

• Annual self-audit/special studies.

• Compliance maintenance annual report.


Each two-page chapter provides a checklist of critical tasks. The back of the booklet lists helpful references for those seeking more detailed information.

Jack Saltes, M.S., P.E., wastewater operations engineer with the Bureau of Watershed Management, and co-author of the book with colleagues Julia Riley, Fran Keally and Hannah Fass, talked about the project in an interview with MSW magazine.



What was your key objective in creating this booklet?



Our primary aim was to help smaller communities. We knew the middle-sized communities and the large cities in our state were moving ahead and doing a pretty decent job overall with their collection systems.


It was the smaller communities we wanted to provide guidance for. About 85 percent of communities in the state have less than 1 mgd wastewater flow. In those communities, collection systems are often out of sight and out of mind. With shrinking dollars and limited staff resources, those systems may not get the attention they need. We wanted to help, but we knew we had to do it in a way that was understandable.



To what extent is the booklet specific to Wisconsin, and to what extent does it apply nationally?



It’s specific to Wisconsin only in that the back section includes a Compliance Maintenance Annual Report that our wastewater system operators have to fill out electronically each year. We wanted the booklet to help our operators complete those reports, but we also wanted it to have applicability nationally, so that operators anywhere could pick it up and at least get started and understand what CMOM is. We wrote it with the intention that it could be used in any state.



How do you envision collection system operators using this book?



We see it as an easy way to organize their CMOM work. For example, if they were to go to our Web site and print it out one page at a time, they could take the cover and the table of contents and put them at the front of a three-ring binder.


Then they could take each chapter, or step, and go through the checklists. If they have the items listed, they can include them in the binder as documentation, or note where the information can be found. For people who don’t like the hard job of keeping records, this is a simple way to pull all the information together.


We just tried to set this up in a very logical, stepwise fashion. If people have each of the elements listed in the booklet, they are well on their way to developing a CMOM program, and most important, taking care of their collection system.



What is the status of CMOM nationally?



It has not been officially enacted. In Wisconsin, we’re moving ahead even though the CMOM program hasn’t been promulgated at the federal level. As part of our SSO rules, which have been drafted, and which we hope will get into our Natural Resources code, CMOM would become a requirement.


We have aging collection systems that need work. In recent years, we have been focused on a volunteer effort to get communities to move ahead with CMOM. Assuming we codify it later this year or early next year, communities will be in good shape if they are already moving ahead with a lot of these concepts.



Why did you choose to make the booklet so simple?



Many communities found the EPA’s CMOM guidance documents intimidating. We were feeling the same way when we looked at them. CMOM was becoming a four-letter word to many operators. Our intent was to help smaller communities get their brains around what CMOM is. So we tried to simplify it and get them started.


We feel a lot of communities have already begun working with CMOM through their O&M programs. But in order to manage even the O&M piece, they need legal authority. For instance, if they’re going to have an O&M program, at some point they have to start addressing private laterals. In order to do that, they need to have the legal authority through a local ordinance or state code. And so, all the puzzle pieces need to fit together to have an effective CMOM program.



What do you see as the most compelling reason for small communities to start working on CMOM programs?



These communities have multiple priorities competing for budget dollars. One important motivator is simply that no one wants sewage in people’s basements. Operators hate calling the regulators about SSOs, but more important, they don’t want to see basements with sewage in them.


Those homeowners may be their neighbors, friends, teachers in the community, people they know. With that thought, communities have been realizing that they need to do more work on their systems and maybe start budgeting a little more money. The first step in a CMOM program is to set goals. Start small. Work some things into your budget. The key is to start doing something.



What has been the nature of the feedback you’ve received on this booklet in the months since its release in early 2010?



We’ve been very pleased. We’ve had quite a few e-mails from smaller communities about what they are doing. It’s getting them moving and doing things, and their boards are gaining more appreciation for the importance of their collection systems. It has been very gratifying to see that.



How can collection system operators get copies of this booklet?



Visit our Web site ( They can download a copy for free from there.


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