Lowell has a combined sewer system that discharges to the Merrimack and Concord Rivers and Beaver Brook. During wet weather, the system has frequent sewer overflows into basements and on to streets. A $76 million Phase 1 CSO abatement program has reduced but not eliminated the problem. The Order requires the City to 1) propose and, upon approval, implement a Phase 1A CSO abatement program 2) develop a final Long-Term Control Plan and 3) conduct a CMOM assessment of its collection system.