The City of Virginia Beach (City) began working with Brown and Caldwell on the development of a Management, Operations and Maintenance (MOM) program in 2004. In September 2007, the City entered into a Special Order by Consent (SOC) with the Virginia Department of Environmental Quality (VA DEQ), Hampton Roads Sanitation District (HRSD) and 13 other localities in the HRSD service area. HRSD owns and operates the interceptor sewer system that transmits wastewater from 13 localities in the Hampton Roads area to one of 9 wastewater treatment plants in the area. The SOC required submittal of a documented MOM Program to VA DEQ in December 2008. In an effort to obtain regional consistency and provide for mutual accountability, the City, in conjunction with HRSD and the localities, agreed to incorporate regional consistencies into their MOM Programs (including SSO response protocols and wet-weather operations).