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Broad municipal coalition urges EPA to finalize wastewater blending guidance

WASHINGTON, DC, Jan. 24, 2005 -- A broad coalition of over 20 national and state organizations representing municipal interests, including the U.S. Conference of Mayors, the National League of Cities, the National Association of Towns and Townships and the Association of Metropolitan Sewerage Agencies (AMSA), joined together to urge the U.S. Environmental Protection Agency to finalize its Nov. 7, 2003 wastewater blending policy.

For more information on this topic, background can be found at the EPA website:
-- www.epa.gov/water/waternews/2003/111203.html
-- http://cfpub.epa.gov/npdes/cso/blending.cfm

The coalition letter (see below) comes in response to mischaracterizations of EPA's blending policy. Contrary to such mischaracterizations, which often tout the policy as an "environmental rollback" (such as from the Clean Water Network: www.cwn.org/cwn/issues/sewage/index.cfm) blending has been an accepted, environmentally sound, practice used by the nation's public treatment utilities for over 30 years. Municipalities use blending as a component of their wet weather management strategies to ensure that excess flows from heavy rains and snowmelt receive the greatest treatment possible under extreme wet weather conditions.

Blended effluent fully meets Clean Water Act permit requirements, protects public utility infrastructure from "washout," and prevents the release of untreated sewage into the environment and sewer backups into homes and businesses. In fact, a final blending policy will increase permitting consistency and make more information publicly available -- far from a rollback. A final policy also will recognize that already scarce public resources must be used to support meaningful, environmentally beneficial water protection efforts at the local level.

A final national blending policy affirming this critical practice is essential to communities across the country to provide treatment for unpredictable, exceptionally heavy precipitation and prevent the discharge of untreated sewage.

Also attached to this e-mail is AMSA's Fact-Fiction one-pager. This one-pager is intended to set the record straight on the need for blending and the environmental and public health safeguards that this long-standing practice provides.

About AMSA
Washington-based Association of Metropolitan Sewerage Agencies is a national trade association representing hundreds of the nation's publicly owned wastewater treatment utilities. AMSA members serve the majority of the sewered population in the United States and collectively treat and reclaim over 18 billion gallons of wastewater every day. AMSA members are environmental practitioners dedicated to protecting and improving the nation's waters and public health.

***

The Honorable Michael O. Leavitt
Administrator
U.S. Environmental Protection Agency
Ariel Rios Building
Mail Code 1101A
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460

Jan. 21, 2005

Dear Administrator Leavitt,

The organizations below strongly support a final U.S. Environmental Protection Agency (EPA) Clean Water Act (CWA) blending policy. A national blending policy is essential to the cities across the country that use blending to manage and provide clean water treatment to unpredictable, exceptionally heavy rain and snow melt. As EPA knows, blending has been used by municipalities for decades to treat significantly increased wastewater volumes in wet weather, avoid serious adverse impacts on plant operations, and protect public health and water quality.

Activist groups are mischaracterizing EPA's November 7, 2003 blending proposal as an "environmental rollback" to further their agenda, which is consistently critical of EPA. Distorting the facts, these groups have called blending the "release of raw sewage," a threat to Americans and our nation's water resources, a reduction in CWA protection, and a departure from historic EPA practice.

The truth is that the blending policy only allows discharges that fully meet water quality standards set out in a public utility's CWA permit. Furthermore, blending protects public utility infrastructure, and prevents sewer backups into homes and businesses. A final blending policy will increase permitting consistency and make more information publicly available on a long-standing, EPA-approved wet weather management practice ¿ far from a rollback. A final policy also will recognize that already scarce public resources must be used to support meaningful, environmentally beneficial water protection efforts at the local level.

We urge you to finalize a national blending policy as soon as possible based on the sound water quality and public health considerations that have supported this wastewater management practice for decades.

Sincerely,
AMERICAN PUBLIC WORKS ASSOCIATION
ASSOCIATION OF METROPOLITAN SEWERAGE AGENCIES
CSO PARTNERSHIP
NATIONAL ASSOCIATION OF COUNTIES
NATIONAL ASSOCIATION OF TOWNS AND TOWNSHIPS
NATIONAL LEAGUE OF CITIES
THE U.S. CONFERENCE OF MAYORS
THE WATER ENVIRONMENT FEDERATION
ASSOCIATION OF OHIO METROPOLITAN WASTEWATER AGENCIES
BAY AREA CLEAN WATER AGENCIES, CA
CALIFORNIA ASSOCIATION OF SANITATION AGENCIES (CASA)
COALITION OF GREATER MINNESOTA CITIES
FLORIDA WATER ENVIRONMENT ASSOCIATION UTILITY COUNCIL
MARYLAND ASSOCIATION OF MUNICIPAL WASTEWATER AGENCIES
MINNESOTA ENVIRONMENTAL SCIENCE & ECONOMIC REVIEW BOARD
NEW ENGLAND WATER ENVIRONMENT ASSOCIATION
NEW JERSEY ASSOCIATION OF ENVIRONMENTAL AUTHORITIES
NEW JERSEY WATER ENVIRONMENT ASSOCIATION
PENNSYLVANIA MUNICIPAL AUTHORITIES ASSOCIATION
SOUTH CAROLINA WATER QUALITY ASSOCIATION
TENNESSEE ASSOCIATION OF UTILITY DISTRICTS
TENNESSEE MUNICIPAL LEAGUE
TENNESSEE WATER QUALITY MANAGERS ASSOCIATION
TEXAS ASSOCIATION OF METROPOLITAN SEWERAGE AGENCIES
Tri-TAC (A TECHNICAL ADVISORY COMMITTEE SPONSORED BY LEAGUE OF
CALIFORNIA CITIES, CASA, & CALIFORNIA WATER ENVIRONMENT ASSOCIATION)
VIRGINIA ASSOCIATION OF MUNICIPAL WASTEWATER AGENCIES
WEST VIRGINIA MUNICIPAL WATER QUALITY ASSOCIATION