About - AMSA Year in Review - 2000-2001 -
AMSA Voices POTW Interests in EPA Effluent Guidelines
As in years past,
AMSA continued to advocate on behalf of publicly owned treatment works (POTWs) nationwide
and to have dialogues with the U.S. Environmental Protection Agency (EPA) to ensure that
the Agency’s effluent guidelines are based on sound science and equitable principles.
AMSA Members are active in two critical EPA Effluent Limitation Guidelines: Metal Products
& Machinery (MP&M) and Iron & Steel.
AMSA Seeks Sound Science in MP&M Guidelines
With EPA’s January 3 Federal Register publication of its proposed
Effluent Limitations Guidelines, Pretreatment Standards and New Source Performance
Standards for the Metal Products and Machinery Point Source Category, AMSA began an effort
to counter clear inaccuracies in the science of the proposal and called on its member
POTWs to participate in a survey that would significantly enhance EPA’s data. The
MP&M proposal would establish technology-based effluent limitations for MP&M
direct discharges to receiving waters under National Pollutant Discharge Elimination
System permits, and pretreatment standards for the indirect discharge of pollutants by
MP&M facilities through POTWs.
AMSA’s review determined that the Agency’s calculation of administrative burden resulting from the rule’s implementation was vastly underestimated. The Association’s assessment also led to a conclusion that EPA’s use in the MP&M of a 1996 Agency survey of approximately 150 POTWs did not accurately characterize actual conditions.
Critically, in order to counter the outdated EPA survey and to ensure that POTW
interests were fully and fairly included in EPA’s review of the MP&M rule, AMSA
directed resources from its Technical Action Fund to conduct a new study of the same 150
POTWs surveyed by EPA in 1996. AMSA received a strong response from surveyed Members and
has moved forward with finalizing a report in anticipation that EPA find it valuable in
revising the MP&M proposal.
AMSA Testifies at Critical EPA Hearings
AMSA testified at three critical hearings held by EPA this year to garner
stakeholder comments on the MP&M rule in Washington, D.C., Dallas, Tex., and Chicago,
Ill. ,and demonstrated a common purpose between AMSA and the metal finishing industry
regarding the need for better, sounder scientific data for a rule that lowers standards by
50 to 90 percent. In April, AMSA also participated in a meeting of the MP&M Coalition,
comprised of stakeholders including industry representatives and federal agencies with a
stake in the MP&M rule.
AMSA’s successful effort in surveying POTWs, its common interests with the MP&M industry, and its development of comments that bring POTW data on this issue up-to-date go far in bringing POTW interests and concerns to EPA.
AMSA Comments on Iron and Steel Effluent Guidelines
In addition to its involvement in the MP&M Rule, AMSA issued comments on
EPA’s proposed Effluent Limitations Guidelines, Pretreatment Standards and New Source
Performance Standards for Iron & Steel. EPA filed its comments to the Iron & Steel
proposal on April 25, expressing grave concern that the Agency’s data relies heavily
on a POTW survey study that is over 20 years old. AMSA will also continue to monitor the
rule’s progress and engage with EPA on behalf of its membership.
AMSA Active on Nutrients
Throughout the year, AMSA has been active in advocating publicly owned treatment
works’ (POTW) issues with regard to nutrients. In early May 2000, AMSA submitted
comments on the U.S. Environmental Protection Agency’s (EPA) 17 Ecoregional Nutrient
Criteria Recommendation documents, issued by the Agency in February. The criteria would
cover eight ecoregions for lakes and reservoirs; eight ecoregions for rivers and streams;
and one ecoregion for wetlands.
AMSA’s Nutrient Workgroup worked assiduously in reviewing and determining the impacts
these criteria would have on POTWs across the nation. The Association’s comments
reiterated member agency concerns with EPA’s methodology and highlighted the
disconnect between beneficial uses and the regulatory burden created by EPA’s
percentile-based approach to deriving its criteria. AMSA also plans to provide input to
EPA on its Nutrient Database, which serves as the basis for the development of nutrient
criteria, when EPA makes the database publicly available.
AMSA will continue to play an active role in the nutrient criteria development process,
ensuring that POTWs voices are heard.