Search
January 30, 2004 AMSA Fax Alert

Member Pipeline - Fax Alerts - January 30, 2004

Click Here
to see previous Fax Alerts

January 30, 2004

Deadline Approaches on
Blending Guidance, Members Urged to Comment
AMSA urges members to submit their pro-blending guidance comments to EPA by the February 9, 2004 deadline. The Association continues to offer online comments that can be sent to EPA at the “click of a button” (http://www.amsa-cleanwater.org/temp/epa_comment.cfm).  This new submittal process has been an effective means for members to comment, with over 50 member agency representatives submitting the online letter. AMSA would like to increase this number and encourages members to send this information to their staff, and other like-minded stakeholders for direct submission to EPA’s comment docket. AMSA also continues to offer its official comments (http://www.amsa-cleanwater.org/private/legreg/outreach/2003-01-09BlendingComments.doc) for member use, available in Microsoft Word format so members can “cut and paste” from the document in whole or in part. For more information on the blending guidance please see AMSA’s Jan. 21 Special Edition FaxAlert at www.amsa-cleanwater.org/private/faxalerts/012104se.cfm.

AMSA Provides Support
to EPA on Addition of Biosolids to Compost Definition
AMSA provided comments (http://www.amsa-cleanwater.org/private/legreg/outreach/2004-01-30RCRA.pdf) this week in support of EPA’s Comprehensive Procurement Guideline V and Recovered Materials Advisory Notice V, which propose a revision of the current compost designation to include biosolids. Under the Resource Conservation and Recovery Act, Class A biosolids would be placed on the federally endorsed list of products the federal government can purchase. AMSA members who generate Class A biosolids would have a new potential buyer – the federal government. This action shows continued federal support for the land-application of biosolids and is in accordance with EPA’s recent response to a July 2003 National Research Council report (see AMSA’s July 11 FaxAlert at http://www.amsa-cleanwater.org/private/faxalerts/071103.cfm) in support of land-application of biosolids and the Agency’s rejection of a petition for a moratorium on the land-application of biosolids proposed by the Center for Food Safety.

AMSA Files Opening Brief in Whole Effluent Toxicity Case
Today, AMSA filed its opening brief (http://www.amsa-cleanwater.org/private/littrack/) in the case challenging EPA’s November 19, 2002 final whole effluent toxicity (WET) test methods, Edison Electric Institute (EEI) et al. v. EPA. In its detailed filing, AMSA demonstrates that EPA approved its chronic WET methods knowing they are inaccurate and unrepresentative of real-world “instream” conditions. It also shows that EPA failed to ensure that chronic WET tests can be used reliably in permitting and enforcement. While AMSA notes that chronic WET tests can be useful tools for gathering information, until the tests are fully validated EPA should be allowed to require their use only as screening methods. In asking the court to take the chronic WET tests and aspects of the acute tests off the books, AMSA also seeks to have EPA ensure, for all WET methods (acute and chronic), that it accounts for dilution and duration of exposure when using the methods to predict instream effects. Briefing in the case will continue through June 29 after which the case will be argued before the court. AMSA is supported in its efforts by publicly owned treatment works (POTWs) coalitions in Virginia, West Virginia, Maryland, South Carolina, California, and Texas.

  • AMSA submitted comments (http://www.amsa-cleanwater.org/private/legreg/outreach/2004-01-30EPW.pdf) to the Senate Committee on Environment and Public works on the adequacy and efficacy of the Clean Water Act state revolving loan fund (SRF) program. AMSA’s comments propose that EPA revise the application and funding process, increase the term to pay back SRF loans, and streamline and improve the loan contract approval time.
  • AMSA wishes all those traveling to Los Angeles for the 2004 Winter Conference a safe trip. We look forward to seeing you there.