Member Pipeline - Regulatory - Alert (RA 00-4)
To:
Members & Affiliates
From:
National Office
Date:
January 26, 2000
Subject:
AMSA Comments To EPA On Proposed TMDL Rules
Reference:
RA 00-4
POTWs Respond to EPA on Draft TMDL Regulations
In August 1999, the U.S. Environmental Protection Agency (EPA) proposed significant changes to the regulatory requirements for establishing Total Maximum Daily Loads (TMDLS) under the Clean Water Act (CWA) Section 303(d). On January 20, 2000, AMSA submitted comments to EPA on its Proposed Revisions to the Water Quality Planning and Management Regulation and its Proposed Revisions to the NPDES Program and Federal Antidegradation Policy.AMSA's written comments were jointly developed by staff and members from several AMSA committees. We appreciate their leadership and willingness to work on these comments. The TMDL proposal marks a significant change in emphasis for the national water program and accelerates an ongoing trend from technology to water quality-based approaches.
AMSA's remarks are supportive of EPA's inclusion of equitable controls on both point and nonpoint sources in the proposed rule. However, major concerns are expressed regarding the expansion of EPA's role at the state and local levels and the Agency's failure to first address the necessary revisions to the Water Quality Standards Program. AMSA's comments also question EPA's authority to expand the required listing of waters under Section 303(d) to include threatened waters, fish advisories, antidegradation, and other inappropriate conditions.
AMSA plans to continue its discussions with EPA as the Agency moves toward finalizing the TMDL regulation (targeted by the Agency for end of June 2000). AMSA also will take every opportunity to provide expert testimony on the TMDL program to Members of Congress through personal visits and Committee hearings.
Attached is a copy of AMSA's TMDL comments and the EPA transmittal letter.
If you have any questions on AMSA's comments to EPA, please contact either:
Norm LeBlanc,757/460-4243, nleblanc@hrsd.dst.va.us, Chair, AMSA Water Quality Committee
or
Lee Garrigan, 202/833-4655, lgarrigan@amsa-cleanwater.org, AMSA Government Affairs
An electronic version of the TMDL proposed regulations is available via the internet at: http://www.epa.gov/OWOW/tmdl/index.cfml
To contact EPA, call:
Hazel Groman, 202/401-4078, U.S. EPA, Office of Wetlands, Oceans and Watersheds
Attachments:
January 19, 2000 Letter to EPA(PDF Format) AMSA Comments on Proposed Rule, 40 CFR 130 For these downloadable files, you must have the Acrobat Reader. If you don't have the Acrobat Reader, click on the icon below to download a copy. After you download and install a copy, return to this page and click on the links above for the downloadable files.
