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October 22, 2004 AMSA Fax Alert

Member Pipeline - Fax Alerts - October 22, 2004

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October 22, 2004

AMSA, CSO Partnership
Collaborate with EPA to Host Workshop on UAAs
This week, AMSA and the CSO Partnership, in collaboration with EPA, hosted a timely workshop in Chicago, Ill., on how to develop work plans for conducting Use Attainability Analyses (UAAs) in combined sewer overflow (CSO) receiving waters and when to initiate them. The workshop included speakers from EPA Headquarters, Region V, states, and regional regulatory authorities. In addition, municipal officials and consultants presented strategies for implementing UAA work plans and provided overviews of successes and hurdles encountered in the UAA process. Many speakers highlighted the importance of public outreach and a watershed approach to successful UAA efforts. Among the challenging issues discussed were determining whether “existing uses” are present, the management of “sensitive areas” under the Clean Water Act and the CSO Policy, how to determine an “attainable” level of control, and processes communities can follow to answer these questions. All materials from the workshop will be posted to the AMSA website in the coming week.

Given the desire for current information on UAAs, AMSA and WERF are working together to release an update of WERF’s A Suggested Framework for Conducting UAAs and Interpreting Results (1997). AMSA expects to make the updated Framework available in Spring 2005, and to hold a series of joint UAA workshops in various national locations in the months following.

AMSA Provides EPA with
Input on Detection and Quantitation Procedures
Earlier this week, AMSA member agency representatives and staff were interviewed by an independent consultant as part of an ongoing EPA evaluation of whether a consensus can be reached on the development of detection and quantitation limits and uses of those limits in Clean Water Act programs. AMSA voiced its concerns with the Agency’s approach to developing detection and quantitation levels and provided its views on the development of a formal stakeholder process that would facilitate interaction among relevant parties to reach an overall consensus.

AMSA maintains that the current method detection limit/minimum level of quantitation (MDL/ML) approach is flawed. The Association and a broad stakeholder group sent a coalition letter to EPA on August 15, 2003 (http://www.amsa-cleanwater.org/private/legreg/outreach/2003-08-15mdl.pdf) addressing the MDL and ML procedures. Interviews of industry, laboratory, state, and municipal representatives will continue for the next few weeks after which EPA will be presented with recommendations regarding the new stakeholder process.

  • The pre-registration deadline for AMSA’s 2004 Developments in Clean Water Law: A Seminar for Public Agency Attorneys and Managers is quickly approaching. Members who pre-register by the October 26 deadline will have their names included in the participants list for the Seminar, so register today! To ensure accommodations for all registrants AMSA asks that any registrant who has reserved a hotel room but will not be staying at the conference hotel contact AMSA’s Nirah Forman, at 202/833-2672 or nforman@amsa-cleanwater.org.