Member Pipeline - Fax Alerts - October 28, 2005
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for the FaxAlert ArchiveOctober 28, 2005
EPA Applauds NACWA
and NRDC Collaboration on Joint Blending Guidance
As announced earlier this week via a Special Edition Fax Alert and press release, NACWA and NRDC delivered a draft final guidance and an accompanying cover letter to EPA’s Assistant Administrator (AA) for the Office of Water, Benjamin Grumbles, addressing the complex and controversial issue of wet weather flow diversions. All relevant NACWA documents on this issue are available on the Association’s Regulatory Correspondence & Outreach webpage (http://www.nacwa.org/private/reg_outreach.cfm). Significantly, AA Grumbles was quoted in the trade press (http://www.nacwa.org/advocacy/news.cfm) supporting the work by both organizations saying that, “[EPA] will review the Guidance carefully” and that “personally, I am pleased with what I have seen so far.” The NACWA/NRDC agreement provides EPA with a sound path forward on an issue that had become highly politicized and appeared to have reached an unfortunate impasse. The Guidance on Peak Wet Weather Flow Diversions would benefit the nation’s water quality by minimizing clean water agencies’ reliance on peak wet weather flow diversions as a long-term wet weather management approach to the maximum extent feasible, taking into account economic, engineering and other real-world factors.NACWA believes that the joint Guidance provides much-needed national consistency on wet weather flow diversions and offers significant additional environmental and water quality benefits. The Guidance asserts that the need to use peak wet weather flow diversions can be eliminated from many systems in a variety of ways, such as enhancing storage and treatment capacity and reducing sources of peak wet weather flow volume. The Association believes that the Guidance’s enhanced public notice provisions will improve the understanding and knowledge of peak wet weather flow diversion practices at public utilities. NACWA and NRDC will work with EPA to finalize the Guidance. If you have any questions regarding the Guidance, contact NACWA’s General Counsel, Alex Dunn at adunn@nacwa.org or 202.533.1803.
NACWA Announces Release
of Financial Capability and Affordability White Paper
NACWA released its much-anticipated Financial Capability and Affordability in Wet Weather Negotiations White Paper this week. The White Paper provides an in-depth review of existing EPA guidance on affordability-related issues and recommends modifications to existing policy and practice on wet weather compliance and its financial impacts. Through detailed case studies, the White Paper also provides information for, and guidance on, affordability negotiations and details viable approaches for reducing the financial impacts of wet weather projects on low-income households. As the White Paper's Executive Summary states "When short implementation schedules are coupled with a zero overflow philosophy, many public utilities find it all the more essential to make affordability and financial capability arguments. This White Paper reviews a broad sampling of clean water agency wet weather negotiations and highlights various techniques for making successful affordability arguments." This document demonstrates the continued effectiveness of NACWA's Targeted Action Fund (TAF) and can be downloaded from the Association's website (http://www.nacwa.org/getfile.cfm?fn=2005-10NACWAWhitePprFinCapAff.pdf). A special thank you is owed to the contributors of the White Paper's nine case studies and to Association members who helped review this key resource. NACWA will be sending a Member Update to the membership next week with further details on this and other documents the Association is working on.Make Plans to Attend
NACWA’s November 1st Hot Topics Breakfast at WEFTEC
NACWA invites its members to attend the 2005 Legal & Regulatory Hot Topics Breakfast on November 1 from 8:00-10:00 am at the Renaissance Washington, D.C. Hotel during WEFTEC. Discussions will focus on several legal and regulatory topics in the national spotlight, including blending, EPA’s pretreatment streamlining rule and sanitary sewer overflows. NACWA also invites members to stop by the Association’s booth (#5325) during WEFTEC to learn more about the Association’s latest clean water initiatives and peruse a wide variety of NACWA publications.