Member Pipeline - Fax Alerts - December 18, 2003
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December 18, 2003
The Honorable Bill Frist
U.S. Senate
431 Dirksen Senate Office Building
Washington, DC 20510-4205VIA FACSIMILE and REGULAR U.S. MAIL
RE: EPA's PROPOSED WASTEWATER BLENDING POLICY
Dear Senator Frist:
On behalf of the Association of Metropolitan Sewerage Agencies (AMSA), I write to urge you to support the U.S. Environmental Protection Agency's (EPA) November 7 proposed national blending policy. A final national policy is essential to many of AMSA's nearly 300 publicly owned wastewater treatment agencies (POTWs) who treat wastewater for the majority of the U.S. population.
While some organizations are mischaracterizing the proposal as an environmental rollback to further their own agendas, the attached fact sheet shows that EPA's proposal is in fact an environmental step forward. Blending ensures that during periods of heavy rain, excess wastewater flows receive treatment in full compliance with POTW Clean Water Act permit requirements. Blending protects POTW biological units from washout, and homes and businesses from sewer backups, both of which have adverse environmental and public health consequences. The groups advocating a blending prohibition have no regard for the negative environmental impacts and the $100 to $200 billion dollars in unnecessary costs that their approach would impose on our nation's communities.
I hope that you will support EPA's proposed blending policy, and that you will help ensure its finalization in 2004. Thank you for your consideration. Please contact me at 202/833-4653 with any questions regarding this important matter.
Sincerely,
Ken Kirk
Executive Director
EPA's Proposed Blending Policy: The Facts
FICTION: Blended sewage does not meet current statutory or regulatory requirements.
FACT: Blended effluent must meet all of a wastewater treatment plant's (also called a POTW) permit limits.FICTION: EPA's proposal relaxes restrictions on discharging inadequately treated sewage into waterways during rain events.
FACT: EPA's proposal does NOT change any regulations. Blending POTWs must at all times meet EPA's current technology-based "secondary treatment" standard. CWA ยง301(b)(1)(B); 40 CFR Part 133.FICTION: Blending is dangerous because it would allow sewage-infested wastewater to be discharged without removing most of the pathogenic organisms and other pollutants.
FACT: POTWs disinfect wastewater before discharge, which is the step that kills the pathogens that could lead to waterborne illness. EPA's proposed policy is clear - blended effluent should be disinfected and POTWs should monitor for bacteria.FICTION: Allowing polluters to discharge inadequately treated sewage into our nation's waters will have adverse, long-term environmental consequences.
FACT: Blending is a water quality safeguard. Without blending, POTW treatment units will "wash out," leading to immediate and adverse water quality impacts, or increased sewage backups.FICTION: EPA is lifting the requirement that facilities fully treat sewage, and will allow more viruses and parasites in the water Americans drink and swim in.
FACT: EPA's proposed policy restates more than 30 years of federal policy toward blending, and clears up confusion resulting from inconsistent approaches to blending across the country. EPA's proposal clarifies how permitting authorities should document blending at POTWs and captures the "best practices" in use by state agencies and POTWs today.FICTION: More Americans would get sick from waterborne illnesses because of this indefensible and illegal policy change.
FACT: EPA's policy must be finalized to provide national consistency and to further water quality. This long-standing wet weather policy is entirely legal and meets all permit requirements.We urge your support of a final EPA blending policy.
For more information, contact AMSA's Ken Kirk, Chris Hornback,
or Alexandra Dunn at 202/833-2672.