Common use of Superior Environmental Performance Clause in Contracts

Superior Environmental Performance. MSD proposes to better manage its pretreatment program through a holistic watershed approach, leading to improved pollutant loading trends in the watershed. MSD will develop a specific strategy to achieve SEP which includes additional monitoring and pollutant source identification, pollution prevention outreach, education and technical assistance, and reinvestment of cost-savings in watershed based improvements. Specifically, MSD will establish a baseline for pollutant loadings using existing pollutant data and data collected during the first phase of the project. MSD is not requesting regulatory flexibility until an agreed upon baseline has been developed. Once the baseline is established, MSD will develop loading projections and reductions, performance measures, and redevelop its pretreatment program. EPA will work with MSD to develop and articulate more specifically the environmental benefits associated with the flexibility considered in MSD’s proposal (e.g., pollution prevention measures, and other environmental improvements). The final phase of the project will be the new pretreatment program implementation and evaluation. MSD’s strategy for SEP will provide the basis for: • a premise for prioritizing resources according to environmental benefits; • a more holistic understanding of the environmental stressors on the watershed; • opportunities for expanded and meaningful pollution prevention; • potential opportunities to partner with industry to focus on water quality improvements; • permanent flow monitoring in the sewer collection system which will enhance planning and operations; and • stream sampling information which MSD can use to determine WWTP impact to the stream.