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November 5, 2004 AMSA Fax Alert

Member Pipeline - Fax Alerts - November 5, 2004

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November 5, 2004

AMSA Provides Input to GAO on Unfunded Mandates
This week, AMSA provided the Government Accountability Office (GAO) with input on how the Clean Water Act (CWA) and EPA's development of regulations thereunder, result in unfunded mandates on clean water agencies at the local level. At the request of Congress, GAO is investigating the effectiveness of the Unfunded Mandates Reform Act (UMRA) in preventing and addressing such mandates. AMSA's members noted that because promulgating agencies essentially "self-certify" under UMRA, economic impacts on local governments are frequently underestimated. The AMSA participants highlighted various EPA programs, such as the stormwater program, which lead to high costs at the local level. Following an expert forum to be scheduled in the coming months, GAO plans to issue a report to Congress to present its findings by February 2005. Member agency personnel with additional input for GAO on the impact of UMRA are encouraged to contact GAO Senior Analyst Tim Bober at 202/512-4432 or bobert@gao.gov. AMSA will keep the membership appraised of future developments.

Wastewater Emergency Response Plan Guidance Released
EPA has announced the release of a new Wastewater Emergency Response Plan Guidance Document. Developed by the Water Environment Research Foundation (WERF), this tool will assist wastewater systems in the preparation of Emergency Response Plans (ERPs). It is intended to help wastewater systems organize their planning efforts, and provide a reference for the types of information and data that should be included in an ERP. Future plans call for the development of an ERP software module for wastewater as an enhancement to the AMSA-developed Vulnerability Self Assessment Tool (VSAT™). The ERP Guidance Document is available for download on AMSA’s website at http://www.amsa-cleanwater.org/pubs/2004-10WastewaterERP.pdf.

Interested AMSA members were provided an overview of the ERP Guidance Document on a conference call which took place this afternoon. Members of the Association's Security & Emergency Preparedness Committee also focused their attention on wastewater security priorities for the 109th Congress and considered security-related questions for inclusion in AMSA's 2005 Financial Survey.

AMSA Comments on
EPA’s Examination of Risk Assessment Practices

This week AMSA provided EPA with comments (http://www.amsa-cleanwater.org/private/reg_outreach.cfm) on the Agency’s Staff Paper, An Examination of EPA Risk Assessment Principles and Practice. The Paper reviewed EPA’s current methods for conducting risk assessments and is the first step in a multi-step process to engage interested stakeholders in dialogue regarding the Agency’s risk assessment principles and methodologies. In its comments, AMSA reemphasized several points raised by other stakeholders, including that EPA relies too heavily on default values and tends to multiply uncertainty factors resulting in an overestimation of risk. The Association urges EPA to maintain an ongoing and open dialogue with stakeholders on matters of risk assessment and risk management as many stakeholders are affected by the final results. AMSA will continue to work with EPA as it moves to improve the existing risk assessment methodologies.


  • Applications are now being accepted for the Water and Wastewater Leadership Center, scheduled for February 13-25, 2005 at the Kenan-Flagler Business School, University of North Carolina – Chapel Hill. The deadline to submit applications is Friday, December 3. Class size is limited so apply today. For more information on the Leadership Center, visit AMSA’s website (http://www.amsa-cleanwater.org/meetings/leader/).