Element 1 - Schedules of Compliance

Missouri Clean Water Commission regulations 10 CSR 20-6.010(7), 10 CSR 20-7.015(9)C., 10 CSR 20-7.031(11.), Section 644.051.4, RSMo and the Federal regulation 40 CFR 122.47(a) allows permits to contain schedules of compliance to give a permittee adequate time need to achieve compliance with new permit requirements such as effluent limitations.  The time granted must representative of as-soon-as-practical and shall not in any case exceed a statutory timeframe.  If the schedules are longer than one year in length, the schedule must include interim requirements and dates for their achievement, with the exception of sludge specific compliance schedules, are not to be greater than one (1) year apart. 10 CSR 20-7.015(9)(C).

Schedules of compliance may exceed the term of the permit. The department has default schedules for Publically Owned Treatment Works (POTWs) as well as private facilities and these are established generally based on whether or not any capital improvements are needed for  the existing treatment system.  In the case of POTWs, and in accordance with Section 644.145, RSMo, the department is required to make a finding of affordability for new permit requirements that would incur a new cost to rate payers.  Depending on the resulting financial burden of the new permit requirements, low, medium or high for example, the default schedules of compliance may be extended to help mitigate some of the new costs incurred.