IDEM was required to publish by Oct. 1, 2000, final guidance to help communities develop CSO Long-Term Control Plans. On Oct. 2, the agency issued the guidance in draft form and accepted comments until Dec. 1. The guidance helped clarify the issues surrounding existing uses and use attainability analysis — but the answer was not what municipalities with CSOs wanted to hear.

IKE submitted extensive comments generally supporting the document but raising serious concerns about the complete absence of a requirement to include the public in the process of developing a LTCP. Matt Rueff reported that the guidance should be finalized in early March.

On Dec. 20, EPA issued guidance that is similar to IDEM’s but focused on the relationship between LTCPs and water quality standards. However, the guidance did not resolve critical issues surrounding existing recreational uses. The delays and confusion continue to make it tough on CSO cities that desperately need clear and final guidance.