A Risk-Assessment Based approach to investigating and addressing unauthorized discharges and spills is consistent with the Industry Standard approach and provides a sustainable means of investing in the works necessary to mitigate the risk of measurable impacts to the community and the environment. [...] The implementation of the program and the timelines to meet the established goals at a system- wide level must consider the prioritization of efforts and the corresponding allocation of resources based on meeting the goals and deriving the greatest benefit in a manner that is affordable to the community and sustainable by the operating entity. [...] It is important that the terminology and the scope of the definitions be well defined to be able to classify those types of discharges that fall within the scope of the program and thus the control techniques that will be employed. [...] Critical to its successful implementation and operation is the establishment of a program governance structure that identifies and assigns both accountability and responsibility for each of the key roles that are necessary to lead and support the Planning, Implementation and Operation of a program. [...] The initial focus of the program could be to implement more robust communication protocols between other programs, as they relate to identifying and correcting sources of spills and unauthorized discharges, and to recommend and oversee expansion of the combined sewer and separated sewer inspection programs described above.
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