The Water Environment Federation (WEF) provided comments on the U.S. Environmental Protection Agency’s national enforcement initiatives for fiscal years 2014 to 2016. WEF supported these six initiatives, particularly the first priority to prevent sewer overflows. WEF applauds the agency’s integrated planning and permitting efforts, and encourages development of additional guidance on sanitary sewer overflows and peak treatment.

However, WEF advocates reducing overflows through a workable, affordable integrated permitting approach that uses National Pollutant Discharge Elimination system permits, rather than enforcing wet weather violations and regulating via consent decrees.