INSTRUCTIONS: FORM LTCP-EZ
community to afford CSO controls.
Step Two involves determination of
a permittee financial indicator to
assess the financial capability of the
permittee to fund and implement
CSO controls. Information from both
Step One and Step Two is used to
determine affordability.
Line 15 – Affordability. Permittees
are encouraged to assess their
financial capability and the
affordability of the LTCP. Please
check the box in Line 15 if Schedule
6 – CSO AFFORDABILITY is
attached to FORM LTCP-EZ, and
enter the appropriate affordability
burden in Line 15a. Otherwise,
proceed to Line 16.
Line 15a – Affordibility Burden.
Enter the appropriate affordability
burden (low, medium, or high) from
Schedule 6 – CSO
AFFORDABILITY.
Recommended CSO
Control Plan
The LTCP-EZ Template guides
permittees through a series of
analyses and evaluations that form
the basis of a draft LTCP for small
communities. The recommended
CSO controls need to be
summarized so that the permitting
authority and other interested
parties can review them. Line 16 is
used for this purpose.
Line 16 – Recommended CSO
Control Plan. Documentation of the
evaluation of CSO control
alternatives is required (CSO
Control Policy Section II.C.4.).
Permittees that have used Schedule
5 - CSO CONTROL to select CSO
controls should bring the
information from Schedule 5 – CSO
CONTROL forward to Line 16 in
FORM LTCP-EZ. Permittees who
have completed their own
evaluation of CSO alternatives (that
is, permittees that did not use
Schedule 5 – CSO CONTROL)
need to summarize the selected
CSO control on Line16 and attach
the appropriate documentation.
Line 16a – Provide a summary of
the CSO controls selected. This
information can come from the
controls selected on Schedule 5 –
CSO CONTROL, or from other
analyses. Section 3.3.5,
Identification of Control Alternatives,
of EPA’s Combined Sewer
Overflows Guidance for Long-Term
Control Plan document, lists the
various source controls, collection
system controls, and storage and
treatment technologies that may be
viable. This document also
discusses preliminary sizing
considerations, cost/performance
considerations, preliminary siting
issues, and preliminary operating
strategies, all of which should be
discussed on Line 16a of the LTCP-
EZ Template.
Line 16b – Provide a summary of
the cost of CSO controls selected.
Project costs include capital, annual
O&M, and life-cycle costs. Capital
costs should include construction
costs, engineering costs for design
and services during construction,
legal and administrative costs, and
typically a contingency. Annual
O&M costs reflect the annual costs
for labor, utilities, chemicals, spare
parts, and other supplies required to
operate and maintain the facilities
proposed as part of the project. Life-
cycle costs refer to the total capital
and O&M costs projected to be
incurred over the design life of the
project.
At the facilities planning level, cost
curves are usually acceptable for
estimating capital and O&M costs.
When used, cost curves should be
indexed to account for inflation,
using an index such as the
Engineering News Record Cost
Correction Index.
Line 16c – Provide a description of
how the CSO controls selected will
be financed. Discuss self-financing
including fees, bonds, and grants.
Section 4.3, Financing Plan, of
EPA’s Combined Sewer Overflows
Guidance for Long-Term Control
Plan document, states that the
LTCP should identify a specific
capital and annual cost funding
approach. EPA’s guidance on
funding options presents a detailed
description of financing options and
their benefits and limitations, as well
as case studies on different
approaches municipalities took to
fund CSO control projects. It also
includes a summary of capital
funding options, including bonds,
loans, grants, and privatization, as
well as annual funding options for
O&M costs for CSO controls,
annual loan payments, debt service
on bonds, and reserves for future
equipment replacement.
Line 16d –
Describe the proposed
implementation schedule for the
CSO controls selected. The
implementation schedule describes
the planned timeline for
accomplishing all of the program
activities and construction projects
contained in the LTCP. Section
4.5.1.5 of EPA’s Combined Sewer
Overflow Guidance for Permit
Writers document (EPA 832-B-95-
008) summarizes criteria that
should be used in developing
acceptable implementation
schedules, including:
• Phased construction schedules
should consider elimination of
CSOs to sensitive areas and
use impairment.
• Phased schedules should also
include an analysis of financial
capability (see Schedule 6 –
CSO AFFORDABILITY).
• The permittee should evaluate
financing options and data,
including grant and loan
availability, previous and
current sewer user fees and
rate structures, and other viable
funding mechanisms and
sources of funding.
• The schedule should include
milestones for all major
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