History

In 1997, the U.S. Environmental Protection Agency (EPA) initially cited more than 50 communities in the Allegheny County Sanitary Authority (ALCOSAN) service area for sewage overflows that violate the federal Clean Water Act of 1972. The EPA and the U.S. Department of Justice threatened litigation or administrative action against these municipalities and ALCOSAN that would total $275 million in penalties.

To address this critical issue, ALCOSAN and the Allegheny County Health Department (ACHD), in a unique partnership, joined forces to create the 3 Rivers Wet Weather Demonstration Program (3RWWDP) in 1998 to help the 83 ALCOSAN municipalities address the region's sewage overflow problem.

Since its inception, 3RWW has assisted communities in a variety of ways, including investing $10.5 million in 33 innovative sewer-related projects throughout Allegheny County.  In the first five years, much of the funding was used to support technology demonstrations such as pipe bursting, trenchless technologies, stream removal and sewer separations that other communities could model. 

Since then, 3RWW has also focused its resources and support on building consensus, working with the regulatory agencies on behalf of municipalities, encouraging cost-effecive, strategic multi-municipal projects, and creating benchmarks, guidance, templates, and interative tools for communities to reach consent order compliance.  Through our regional approach to problems, 3RWW has saved more than $70 million for the ratepayers of southwestern Penn­sylvania, while providing invaluable tools to support a long-term viable solution to the problem. 

Here are some of the milestones 3RWW has accomplished since our founding:

• 1998-2000: Municipal Demonstration Grants
  3RWW granted municipalities funding to complete projects that demonstrated and benchmarked new and cost-effective sewer technologies such as trenchless techniques for sewer rehabilitation.  In total, 3RWW supported 33 demonstration projects.

• 2001: The Development of Basin Groups
  The Eastern, Northern and Southern Basin Groups were formed to help educate municipal officials, encourage communities to share resources and explore regionalization options. The formation of these groups resulted in an open dialogue with the regulatory agencies regarding an administrative consent order to comply with the Clean Water Act.

• 2002-2003: Consensus-Building Process for Municipal Consent Orders
  Over an 18-month period, 3RWW held 150 meetings of solicitors, engineers and elected officials, as well as smaller core representative stakeholder groups regarding a consensus-based version of the municipal consent orders.  The consent order, ultimately negotiated between municipalities and three regulatory agencies, included no penalties for past violations, its requirements and deadlines were consistent and feasible across all communities, and it set the foundation for regional approaches to managing the municipal sewage collection system throughout Allegheny County.

• 2004-2015: Regional Compliance with Municipal Consent Orders
  In early 2004, all 83 communities signed municipal consent orders requiring assessment and repair of their sewer systems.  While the order requirements and deadlines were consistent for all communities, no protocols were defined for approach or method of compliance. 3 Rivers developed Basin Engineers’ and Managers’ Groups to define engineering protocols and to continue exploring and implementing inter-municipal strategies to the wet weather problem. 3RWW led the way with regional compliance approaches. At the request of the communities, 3RWW also created the Feasibility Study Working Group to create Feasibility Study Guidelines for municipalities to use in developing their own feasibility studies as required by the consent orders.  

• 2013-2015: Sewer Regionalization Implementation Committee
  3 Rivers managed a multi-disciplined stakeholder committee to develop the principles and template agreement for regionalization of the major multi-municipal trunk sewers.  In 2015 communities and ALCOSAN began the negotiations for the transfer of trunk sewer ownership to ALCOSAN.

• 2014-present: 3 Rivers Wet Weather Working Group
  As the Feasibility Study Working Group (FSWG) completed its technical tasks related to the municipal feasibility studies required under the municipal consent orders, 3RWW created the 3 Rivers Wet Weather Working Group (3WG) to provide a forum for municipal managers, elected officials and engineers, ALCOSAN and the regulatory agencies to discuss and solve non-technical issues related to regionalization of the sewage infrastructure (trunk sewers) and achieving water quality requirements. The 3WG meets regularly and continues to provide a platform for discussion, education, and outreach related to wet weather challenges communities face.

• 2015-2018: Phase I Interim Municipal Consent Orders
  In late 2015, municipalities signed the Phase I Interim Municipal Consent Order, which required communities to complete source reduction studies, including the evaluation of green infrastructure as a source reduction technique.  Municipalities also had to plan and implement a source reduction project and begin regionalization discussions regarding the transfer of municipal trunk sewers to ALCOSAN’s ownership. To assist municipalities with compliance, 3RWW created a Consent Order Working Group to help develop a consistent approach toward compliance and to create a template for the Source Reduction Study.  In anticipation of the next phase consent order, 3RWW also created the Source Flow Reduction and Flow Target Subcommittee (SFRFT) to develop municipal consensus on flow reduction strategies and flow targets that were “technically achievable, economically affordable, reasonably quantified, and enforceable.” Using local flow data and engineering methodologies, the Subcommittee created the “Gold Line Standard,” by which communities could compare their flows to a threshold flow target.

• 2018-2021: 3RWW Consent Order Negotiations Subgroup
  As the Phase I Interim Municipal Consent Orders were slated to expire on June 1, 2018, 3RWW created a Consent Order Negotiations Subgroup of engineers and municipal representatives to work closely with the regulatory agencies in negotiating a viable Phase II Municipal Consent Order to continue the region’s progress on flow reduction and regionalization. Through the negotiation process, the regulatory agencies agreed to use the Gold Line Standard developed by the 3RWW SFRFT Subcommittee as the compliance metric for the Phase II consent orders rather than a generalized national standard. 3RWW used its online Sewer Atlas to create technical exhibit documents for each ALCOSAN municipality’s overflow structures measuring their community’s flows against the Gold Line Standard. These Exhibits were developed and shared with municipalities in advance of being included with the upcoming Phase II Consent Orders.

• 2021-2026/2027: Phase II Municipal Consent Orders
  In 2021, municipalities signed their Phase II Consent Orders, which require the separate sewer communities to actively reduce inflow and infiltration and eliminate sanitary sewer overflows while combined sewer communities must reduce stormwater flows in their systems. The orders also encourage communities to transfer ownership of multi-municipal trunk sewers to ALCOSAN.  3RWW created a Separate Sanitary System (SSS) Subcommittee and Combined Sewer System (CSS) Subcommittee to assist municipalities with their system-specific compliance requirements by providing several templates for the communities to use in meeting the orders’ requirements (i.e. affordability calculation tool and SSO Elimination Plan). 3RWW also continues to host multi-municipal groups to facilitate consensus on the most cost-effective compliance methods for the Phase II consent orders.

• 2024-present:
  Compliance work has continued on the Phase II Consent Orders. 3RWW also continues to host its annual sewer conference in November each year.  Since the first conference in 1999, this two-day educational event has grown from 100 attendees and a dozen exhibitors to nearly 500 municipal officials, engineers, managers, public works directors and wet weather experts who attend and 100 exhibitors who share their products and services. In addition, each year more than 25 local, regional, and national speakers share their expertise and case studies for solving the wet weather issue.