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Tonawanda Consent Order Compliance The challenge Client The Town of Tonawanda (Town) owns, operates, and maintains its Town of Tonawanda sanitary sewer collection system and a wastewater treatment facility (WWTF). The Town’s sanitary sewer system experiences significant Location increases in flow during wet weather events, which has in part been attributed to inflow and infiltration (I/I) into the sanitary sewer system. Tonawanda, New York, USA These excess wet weather flows can result in sanitary sewer overflows (SSOs) to Ellicott Creek and Two Mile Creek. The Town entered into an Order on Consent (Order) with the New York State Department of Environmental Conservation (NYSDEC) in May 2012 (Consent Order R9-20110315-9) to address the abatement of SSOs and has completed several projects as required in Schedule A of the Order. In October 2022, a Revised Schedule A for the Order (Appendix A) was executed that included several new requirements to further address I/I and SSO abatement in the Town’s system. As part of the revised Order, the Town was required to submit an approvable work plan and schedule for conducting a system-wide I/I study of the sewer system, which served as the basis for developing the multi-phase Sanitary Sewer Evaluation Survey (SSES) and Corrective Action Plan (CAP) to address SSO reduction. The Power of Commitment Page 178 of 301