The City of Pittsfield, MA's NPDES permit contains water quality based imits for total phosphorus and total aluminum which the existing treatment system cannot meet. In addition, the City has had some sanitary sewer overflows from its collection system. The administrative order requires the City to submit a plan and to propose an implementation schedule for meeting the phosphorus and aluminum limits, and to conduct a Capacity, Management, Operation and Maintenance (CMOM) evaluation to its sewer system.