Cahokia Heights

The Department of Justice and the U.S. Environmental Protection Agency have announced a settlement with the City of Cahokia Heights, Illinois, resolving Clean Water Act violations resulting from the City’s operations of its sanitary sewer system. Please see this linked press release for more information.

The complaint and proposed consent decree have been posted on the Justice Department’s website. The proposed consent decree is subject to a 60-day public comment period. Any comments on the proposed consent decree should be submitted in accordance with the instructions provided in the pertinent Federal Register notice, which will also be posted on the Justice Department’s Proposed Consent Decree website.
 

Cahokia Heights (population 17,894) is a city in St. Clair County, founded (May 2021) by the merger of the Villages of Cahokia, and Alorton and the City of Centreville. Parts of Cahokia Heights and the surrounding area currently experience significant flooding and sewage backups following heavy rain events and instances of dry-weather sanitary sewer overflows. These problems are due to a combination of natural causes, urban development, and the ineffective operation and longstanding lack of maintenance of older sewer collection and transport systems serving the area.

Cahokia Heights is located within the lower elevations of an urbanized watershed that quickly delivers water from its upland bluffs. Once waters enter the bottomland there is limited opportunity for the water to recede when areas downstream experience high water levels or flooding. The Centreville/Alorton wastewater collection and transport systems, built in the 1980s, discharge stormwater and sewage either to the East St. Louis Collection System or through the Cahokia Lift Station, with both discharges ultimately being received at the American Bottoms wastewater treatment plant.  The Centreville and Alorton wastewater collection and transport systems are old, undersized, and have been poorly maintained. Many of the lift stations are in need of renovation. The City of East St. Louis is a combined sewer community, and it does not have capacity to accept wastewater flows from Cahokia Heights during substantial storm and flood events. The local terrain, poor condition and interrelationship of the wastewater collection and transport system, and the delivery of substantial stormwater runoff from the watershed cause hydraulic loading to the wastewater collection and transport system during periods of significant rainfall. This causes sewer backups while the area is flooded. In addition, dry-weather sanitary sewer overflows appear to be caused by deteriorating infrastructure in the wastewater collection and transport system.

The Federal Clean Water Act (CWA) provides for regulation of wastewater discharges. The National Pollutant Discharge Elimination System (NPDES) was created in 1972 through the CWA to address water pollution.  The NPDES program was delegated to the states by US EPA, with Illinois receiving delegation on October 23, 1977.  Additionally, in Illinois, the Illinois Environmental Protection Act (Act) contains provisions which incorporate the federal NPDES requirements to regulate wastewater discharges to Illinois streams and lakes. Illinois EPA’s NPDES program requires permits for, among other things, the discharge of treated municipal effluent, treated industrial effluent, coal and non-coal mining discharges, Concentrated Animal Feeding Operations (CAFO's), public water supply treatment plant discharges, pesticide discharges, and industrial and construction stormwater. The NPDES permits establish the conditions under which discharges may occur and establish monitoring and reporting requirements for these discharges.  The Illinois EPA routinely inspects NPDES permitted facilities to determine compliance with applicable State and Federal laws, rules, and regulations.  

It is important to note that Illinois EPA’s NPDES permitting authority does not extend to collection-only systems (i.e., sewer systems that are designed and constructed to only collect and transport influent wastewater), such as Cahokia Heights’ collection-only system. These collection-only systems that collect and transport wastewater, but are not designed to discharge wastewater to Illinois waters, are not subject to NPDES permitting requirements. Implementation of the Federal and State laws also includes technical and financial assistance to support operation and maintenance of municipal wastewater treatment plants.

Surface water flow is not directly regulated under the CWA; however, the CWA does provide technical and financial assistance for development of watershed management plans to help improve implementation of nonpoint source pollution prevention efforts and stormwater management within a watershed.

Additional State and federal programs also provide technical and financial assistance to local government to support construction and improvements of municipal wastewater collection transport treatment systems.

Other State and federal agencies have a role in maintaining waterways, responding to flooding and other emergencies, and provide funding for local government improvements. Importantly, responsibility for development and maintenance of storm and sewer water collection and disposal systems is a function of the local municipality, either directly or through contracting with a private entity. User fees are the primary funding mechanism for development and maintenance of the systems. 

Similarly, the Illinois EPA and other state Agencies have regulatory authority provided by the Safe Drinking Water Act and the EPA to regulate, permit, enforce against and provide technical and financial assistance for drinking water production.

The Illinois EPA has been conducting frequent inspections, and complaint investigations, and attending community meetings to better understand the current conditions and the level of technical and financial assistance that will be needed to assist and provide support to improve the wastewater collection and transport system within the City of Cahokia Heights. The Illinois EPA has also assisted in and continues to coordinate with State, federal and local agencies who may have authority or resources to assist in improving the wastewater collection and transport system and reducing the impact of stormwater runoff from heavy rain events.  While the Illinois EPA understands that the problems with the wastewater collection and transport system have developed through long-term neglect and will not be completely fixed immediately, the Illinois EPA has also taken enforcement action against the City of Cahokia Heights, via a referral to the Illinois Attorney General’s Office, for violations of the Illinois Environmental Protection Act and Illinois Pollution Control Board regulations related to sanitary sewer overflows.  Additionally, the Illinois EPA is coordinating its enforcement activities with the enforcement being undertaken by the United States Environmental Protection Agency.

Illinois EPA has issued two grants that will have a positive impact on the City of Cahokia Heights. The projects will assist with wastewater infrastructure restoration and rehabilitation and with watershed planning to identify best management practices to reduce stormwater impacts within the watershed.

The Wastewater Collection and Transport Infrastructure Rehabilitation and Restoration Project (Project) will fund three discreet components to improve the quality of life, within the municipality of Cahokia Heights.

PROJECT COMPONENTS

PROJECT REQUIREMENTS

Support the elimination of Sanitary Sewer Overflows (SSO),

Reduce or eliminate system surcharging,

Eliminate wastewater service backups,

Reduce operation and maintenance costs, and

Increase reliability and continuity of wastewater service.

PROJECT OUTPUTS

Implementation of the Construction Activities Strategy

• Rehabilitation and/or restoration of approximately 35 lift stations
  
• Rehabilitation and/or restoration of approximately 5,800 linear feet of impaired sewer line
• Repair of approximately 1,500 linear feet of pipe repair
• Construction of approximately 5,800 linear feet of Cured in Place Pipe Liner
• Slip lining of approximately 3,500 linear feet of the City's main trunk line

Implementation of the Outreach Program Strategy

• Webpage
• Meetings

PROJECT OUTCOMES

Improved collection and transport of existing and future wastewater flows within the City of Cahokia Heights during both dry and wet weather conditions

Compliance with regulatory requirements for reserve capacity and prevention of prohibited SOSs, and

Improved customer wastewater service, including the reduction of frequency and duration of system surcharge events that cause basement or service backups

City of Cahokia Heights Townhall #5

September 26, 2024 6:00pm

Agenda

City of Cahokia Heights Townhall #4
June 27, 2024 6:00pm
Agenda

City of Cahokia Heights Townhall #3
March 27, 2024 6:00pm
Agenda

City of Cahokia Heights Townhall #2
September 27, 2023 6:00pm
Agenda

City of Cahokia Heights Townhall
July 13, 2023 6:00pm
Agenda

Contact: Community Outreach Team
618-332-4207
communityoutreach@cahokiaillinois.org

Draft Construction Activities Strategy (CAS)

CAS comments-Illinois EPA transmittal letter (01-26-2023)

Final Approved Construction Activities Strategy (CAS)

CAS Approval letter (03-09-2023) 

Draft Operation & Maintenance Plan (O&M)

O&M comments-Illinois EPA transmittal letter (03-09-2023)

Draft O&M Plan (version 2)

Draft O&M Plan appendices 

O&M (v2) comments-Illinois EPA transmittal letter (04-17-2023)

Final approved O&M Plan

Final approved O&M appendices 

Illinois EPA approval letter of O&M Plan (04-18-2023)

Draft Outreach Program Strategy

Final Approved Outreach Program Strategy (OPS)

Illinois EPA approval letter of OPS (03-16-2023)

The Prairie du Pont/Judy's Branch Watershed-Based Plan Development and Pilot demonstrative Best Management  Practices Implementation Project (Project) will develop a watershed-based plan (Plan) for the approximate 95,000-acre project area which includes the Prairie du Pont watershed and the St. Clair County portion of the Judy's Branch watershed. The Plan will be designed to improve water quality by controlling nonpoint source pollution. The Plan will be consistent with the 2013 US EPA watershed-based plan guidance and current watershed planning principles. The development of the Plan includes a significant outreach and information program which includes implementation of pilot demonstrative best management practices (BMP) for 1) traditional stormwater runoff control (TSRC) and 2) minor sewer system infrastructure issues (MSSI). The outreach and information program includes community-based efforts such as training, displays, and workshops, along with technical assistance.

The Plan will help to identify stormwater runoff control opportunities to reduce flood events in the watershed (home of Cahokia Heights and part of East St. Louis). The Plan will comply with State and federal guidelines to improve the chance to secure future technical and financial assistance from private, State, and federal organizations to implement the Plan once completed. A local Watershed Planning Committee (Committee) has been established - this Committee reflects the 'personality' of the watershed - including members of local active citizen groups and local, State, and federal entities, as appropriate. A Technical Advisory Committee (TAC) has been created to support the Committee in the development of the Plan. The TAC will make recommendations regarding the development of the Plan's watershed resource inventory and the types of BMPs, including specific techniques and construction requirements, cost estimates, BMP lifespan, and operation and maintenance needs.

The Plan will document the existing watershed conditions (natural resources, land use, stakeholder concerns, etc.) and identify BMPs, activities, and programs that the watershed stakeholders are willing to support that can be implemented to help manage stormwater to reduce 1) the number of flood events, and shorten their duration, and 2) the Infiltration and Inflow (I&I) pressure on the wastewater collection and transport system(s). The Plan must include, at a minimum, nine specific elements required in US EPA's watershed-based plan development guidance, including site-specific BMP recommendations, an implementation schedule, and identification of potential partners and funding sources to pursue to implement the Plan's recommendations. The Project goal is to create the most optimal and cost-effective Plan to address the watershed's stormwater runoff and flood event issues.

The second part of the Project is the implementation of demonstrative BMPs to reduce stormwater runoff and repair the wastewater collection and transport infrastructure.

PRAIRIE DU PONT PROJECT OUTPUTS

Implementation of Outreach and Information Strategy

Watershed-based plan that meets USEPA's nine required elements

• Watershed Resource Inventory
• Executive Summary
• Watershed-Based Plan Evaluation

PRAIRE DU PONT PROJECT OUTCOMES

Future implementation of the watershed-based plan recommendations

Reduced stormwater runoff and annual pollutant loadings to Prairie du Pont Creek and Judy's Branch

Inspection Report  (2-2-2021)

Inspection Report (2-24/25-2021)

Inspection Report  (3-14-2022)

Inspection Report (6-9-2022)

Violation Notice  (5-12-2021)

Violation Notice  (9-01-2022)

Final Report: Cahokia Heights & East St. Louis Flood Hazard Analysis

Pollution Complaint

Freedom of Information Act (FOIA) request

Environmental Justice

Barb Lieberoff

Community Relations Coordinator
Office of Community Relations
217-524-3038