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September 18, 1998

USDA-EPA Announce Draft Strategy for Animal Feeding Operations

On September 16, the U.S. Environmental Protection Agency (EPA) and the U.S. Department of Agriculture (USDA) announced a draft plan to improve water quality and reduce public health risks associated with animal feeding operations, as part of the President's Clean Water Action Plan. At AMSA’s summer conference in Colorado Springs, Colorado, EPA Director of Water Mike Cook said that the agencies were "devoting a lot of attention to animal feeding operations . . . and working on a joint strategy to come up with a much more vigorous program focusing on the big, the bad, and the many." The September 16 draft proposes a variety of voluntary and regulatory approaches, including a national expectation that all animal feeding operations develop and implement comprehensive nutrient management plans by the year 2008. EPA and USDA will take public comment on the draft strategy over the next 120 days. Copies of the strategy are available online at http://www.epa.gov/cleanwater/afo/.

AMSA Addresses Illinois Association of Wastewater Agencies

On September 17, Ken Kirk addressed members of the Illinois Association of Wastewater Agencies at their annual meeting in Grafton, Illinois. The focus of his address was the need for publicly owned treatment work (POTW) involvement in the U.S. Environmental Protection Agency’s (EPA) new water quality initiatives. Refined water quality assessment and development of a broader suite of water quality criteria are two of the major thrusts of EPA’s new initiatives, such as the Advanced Notice of Proposed Rulemaking on the Water Quality Regulation (ANPRM) and the draft Water Quality Criteria and Standards Plan - Priorities for the Future. Kirk told those assembled that POTWs can expect increased regulatory and public scrutiny arising from the implementation of newer, broader water quality criteria and assessment tools as described in these initiatives and proposals. The proposed changes will also likely evolve into more stringent permit limits for dischargers, an expanded suite of regulated pollutants in permits, and pressure from regulators and the general public for higher levels of treatment operation.

While AMSA supports water quality initiatives that ultimately lead to better decision-making, the Association is voicing significant concerns which include: 1) ensuring the adequacy of data for water quality decisions; 2) ensuring that EPA provides states with flexibility in adopting criteria and policies; 3) ensuring that water quality assessments use new criteria within a weight of evidence approach; and 4) that proportionate share responsibilities be adopted in the allocation of pollutant loading reductions. Kirk stressed the need for EPA to discuss how the water quality standards program (a regulatory approach) can be implemented in such a way that assures water quality will be attained, yet does not unfairly burden the point source community with nonpoint source pollution clean up costs. He also referenced the work that AMSA is doing in the legislative arena to reauthorize the Clean Water Act and thereby provide EPA with the authority it needs to control nonpoint sources so that the point source community will not be penalized disproportionately when a waterbody is found to be impaired.

In response to concerns expressed by Illinois wastewater agencies regarding the state’s implementation of ammonia criteria, Kirk advised the group of AMSA’s keen interest in this issue and willingness to provide assistance.


  • AMSA members and leadership will be gathering in Washington, DC next week for a Legislative Strategy Session in preparation for the new 106th Congress and the anticipated reauthorization of the Clean Water Act. This session will be part of the 1998 AMSA Fall Board & Leadership Meetings, which will be the focus of next week’s FaxAlert.