Final Comment Letter – Proposed Guidance CSO Integrated Planning

The Association of Clean Water Administrators (ACWA) submits this letter to the U.S. Environmental Protection Agency (EPA) in response to notice of available Draft Guidance for Future NPDES Permitting of Combined Sewer Systems (draft guidance). ACWA is the independent, non-partisan, national organization of state, interstate, and territorial clean water program directors (hereinafter “states”), responsible for the daily implementation of the federal Clean Water Act (CWA), including permitting of combined sewer systems.