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February 23, 2001

AMSA Testifies at Hearing on Metal Products and Machinery Rule
This week, AMSA’s Pretreatment and Hazardous Waste Committee Chair, Guy Aydlett, testified on behalf of AMSA at a hearing on the proposed metal products and machinery effluent guidelines and standards rule, published in the January 3 Federal Register. The Washington, DC hearing was the third of EPA's four scheduled regional public meetings on the proposal. The Gulf Coast Waste Disposal Authority testified on AMSA's behalf last week at the second public hearing in Dallas, TX. In both sets of testimony, AMSA cited major concerns with the proposal, specifically with regard to the Agency’s estimates for POTW administrative burden, POTW and water quality benefits, baseline industrial pollutant loadings, and the achievability of the proposed standards. Many of AMSA’s comments support the concerns of the metal finishing and printed circuit board industries who also are also critical of EPA’s data gathering techniques, cost of compliance estimates, and assumptions regarding achievability of proposed standards. The proposed standards are 50 to 90 percent lower than EPA's current metal finishing effluent guidelines.

The next public hearing is scheduled for March 8 in Chicago, IL. In order to statistically assess the accuracy of EPA’s cost/benefit analysis and the rule’s impact on POTWs and industries, AMSA plans to collect additional data from the 150 POTWs EPA originally surveyed as part of the rule’s development. Additionally, AMSA has requested a 90-day extension to the public comment period which currently ends on May 3. A full copy of AMSA's testimony, along with a request for comment will be distributed to the membership next week.

AMSA Presents Regulatory Priorities to Administrator Whitman
The National Office wrote EPA Administrator Whitman on February 22 outlining the Association’s regulatory priorities. AMSA’s Regulatory Priorities for the New EPA Administration were endorsed by the Association’s Regulatory Policy Committee at the 2001 Winter Conference in San Diego earlier this month. The list highlights three issues in particular for priority attention, including infrastructure funding, TMDLs, and the proposed SSO rule. The infrastructure funding priority outlines WIN’s essential objectives and urges EPA’s full support for a long-term federal funding source for clean and safe water. AMSA also expresses its continued support for the TMDL program, while outlining several areas where the Agency should look to improve the process as well as the underlying water quality standards and listing approaches. The list also provides recommended improvements to the proposed SSO rule.

The Regulatory Priorities list details a number of other areas where improvements can be made under Clean Water Act programs. Specific recommendations are made to improve national programs relating to biosolids management, mercury use and disposal, pretreatment, water quality standards, and wet weather control. AMSA also calls attention to the need to reintegrate the Office of Enforcement & Compliance Assurance (OECA) and EPA’s National Program Offices, and to improve Regional Office coordination and responsibility. AMSA’s Regulatory Priorities for the New EPA Administration has been posted at the Clean Water Advocacy and Member Pipeline (under Correspondence & Outreach) sections of AMSA’s web site at http://www.amsa-cleanwater.org. The Priorities will also be distributed via Regulatory Alert.