Member Pipeline - Regulatory - Alert (RA 00-23)
To: Members & Affiliates From: National Office Date: November 14, 2000 Subject: EPA REQUEST FOR COMMENTS ON COSTS OF TMDLS Reference: RA 00-23 Action Please By:
December 30, 2000The Environmental Protection Agency (EPA) plans to publish a request for comments on the costs associated with the TMDL program in an upcoming Federal Register notice during the week of December 4, 2000. Congressional Committee Reports accompanying EPA's appropriations for fiscal year 2001 direct EPA to conduct a comprehensive assessment of State and regulated community costs related to TMDLs, to solicit comments on these costs, and to present the results of the study to Congress within 120 days of the signing of the appropriations bill. The information submitted in response to EPA's upcoming Federal Register notice will be used by EPA in the development of the report that the Agency must send to the Congress.
Attached is an advance copy of the Notice of Request for Comments; the disclaimer states that respondents should refer to the official version of the notice when it is published in the Federal Register.
Due to the short comment period — 30 days after the date of publication — we are sending you this notice in order to give you as much time as possible to respond to EPA.
According to the notice, EPA is seeking information on the costs to the regulated community for complying with TMDLs, including any savings that may result from more cost-effective pollution control approaches developed through the TMDL process. Some of the costs identified by AMSA's TMDL Workgroup include costs associated with the up-front science, data collection, the decision-making process to resolve difficult technical and policy issues, regulatory costs, and legal costs. Cost estimates can reflect real or potential TMDLs. In submitting potential costs, POTWs have an opportunity to discuss specific cost savings that can be achieved by using alternative approaches.
Comments should be submitted directly to EPA in accordance with the instructions in the Federal Register notice. A copy of your comments also should be sent to AMSA's Lee Garrigan either by mail or through electronic mail at lgarrigan@amsa-cleanwater.org
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