Member Pipeline - Fax Alerts - January 13, 2006
Click Here
for the FaxAlert ArchiveJanuary 13, 2006
NACWA Raises Concerns
with Revival of Performance-Based Systems
NACWA sent a letter (http://www.nacwa.org/getfile.cfm?fn=2006-01-13pbms.pdf) to EPA’s Office of Science and Technology Director, Ephraim King, this week raising concerns regarding the Agency’s potential revival of Performance-Based Measurement Systems (PBMS) for Clean Water Act (CWA) programs. EPA’s current approval process for analytical methods in 40 CFR Part 136 allows all stakeholders, specifically those who will be responsible for using and interpreting the results from analytical methods, to review and comment on the procedures, how they were validated, and how they will be implemented. A PBMS approach does not provide the stakeholders, whose compliance status relies on the performance of the method, adequate opportunity to understand, comment on, or question that method. NACWA argues that there are better ways to improve and streamline existing approval procedures than implementing a PBMS-type approach.NACWA suggests potential solutions to the concerns expressed that would include the creation of more formal and robust protocols for both method development/validation and for determining if the methods meet their intended uses. The Association also expressed concern with the level of sophistication required of end users, specifically clean water utilities, to adequately analyze laboratory results from a PBMS method. NACWA noted that a large number of small utilities across the country do not have the analytical expertise or equipment needed to review laboratory data or proposals to ensure that only data meeting method standards are used for permit compliance. The Association will continue to work with EPA on the PBMS issue if the Agency elects to pursue it further and seek additional public comment.
Member Agencies Encouraged
to Copy National Office on Peak Flow Policy Comments
NACWA’s small negotiating group on peak wet weather flows met this week by conference call under the leadership of Blending Issue Leader Dave Williams, NACWA Board member and director of wastewater at the East Bay Municipal Utility District, Oakland, Calif. The group confirmed NACWA’s plans to submit a brief comment letter to EPA on the Agency’s peak wet weather flow policy by the January 23 deadline. The comment letter will be filed jointly by NACWA and the Natural Resources Defense Council (NRDC) to thank the Agency for proposing this compromise agreement and to support its ultimate finalization. The comment letter will acknowledge that both NACWA and NRDC are aware of changes and clarifications that will be brought to the Agency’s attention through the comment period which could enhance the proposal’s clarity and ensure smoother implementation over time. The letter will reiterate both organizations’ commitment to working with EPA to respond to such comments or clarifications, and to move towards a final policy.To facilitate NACWA’s follow-up with EPA, member agencies planning to comment on EPA’s proposed policy are encouraged to send a copy of their letters to NACWA’s General Counsel, Alexandra Dunn, at adunn@nacwa.org. Next steps for the Association on this important issue will be discussed at NACWA’s 2006 Winter Conference in Palm Desert, California during the Facility & Collection System Committee meeting on Tuesday, January 31.
Winter Conference Approaches – Visit www.NACWA.org for the Most Up-to-Date Agenda
NACWA’s 2006 Winter Conference is fast approaching. The conference, Improving Knowledge Management in Today’s Utility, will take place January 31 – February 3 at the J.W. Marriott in Palm Desert, Calif. Please note that there have been a few small schedule changes made to the final day of the program. On Friday, February 3, the Legislative Policy Committee Meeting will now begin at 8:00 am and General Session III will now begin at 9:30 am. The conference will adjourn at 11:30 am. Please visit NACWA’s Conference & Meetings (http://www.nacwa.org/meetings/06winter/) webpage for more information on the conference.