Member Pipeline - Fax Alerts - November 12, 2004
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November 12, 2004
AMSA Provides Input to EPA on Pretreatment Issues
AMSA this week sent separate letters (http://www.amsa-cleanwater.org/private/reg_outreach.cfm) to EPA’s Office of Water (OW) and the Office of Inspector General (OIG) that provided the municipal perspective on the OIG’s final Evaluation Report, EPA Needs to Reinforce its National Pretreatment Program. EPA is required to respond to this Report by December 28, 2004. The Report found that “reductions in industrial waste discharges to the nation’s sewer systems that characterized the early years of the pretreatment program have not endured.” The Association’s letters roundly disagreed with this finding and pointed out that the OIG acknowledges neither the significant reduction of pollutants that are attributable to local limits, nor the effort put forth by treatment facilities to bring industrial users into compliance. AMSA does agree, however, with the Report’s assertion that reduced funding and staff resources at the federal level have slowed, and continue to hinder, the pretreatment program’s progress. The Association’s letters also support OIG’s recommendation that OW finalize the Pretreatment Streamlining Rule as a key component of updating the pretreatment program. AMSA again urged EPA to update the “50 POTW Study” as soon as possible, and again offered its assistance to complete the study.EPA Signs Bacteria Criteria, Incorporates AMSA Comments
EPA Administrator Michael Leavitt signed a final rule (http://www.epa.gov/waterscience/beaches/bacteria-rule.htm#final) this week establishing bacteria criteria for coastal recreation waters in 21 states. EPA was required, by the 2000 Beaches Environmental Assessment and Coastal Health (BEACH) Act, to promulgate the criteria for any state that had not developed criteria as protective as EPA's by April 2004. AMSA provided substantial comments (http://www.amsa-cleanwater.org/advocacy/comments/2004-08-09OW_2004_0010.pdf) on the proposal in August, focusing primarily on EPA's proposed uses for the single sample maximum (SSM) values that are part of the Agency’s 1986 criteria. Consistent with AMSA's comments, EPA's final rule recommends that the SSM be used only for making beach notification and closure decisions. It does not, however, preclude states from using the SSM for other Clean Water Act purposes (e.g., permitting or total maximum daily loads). The final rule, including the Agency's interpretation of the SSM, applies only to 'coastal recreation waters' in the 21 affected states – and not to inland waters (other than the Great Lakes). AMSA is pleased that EPA incorporated the Association’s comments and will continue to update members on bacteria criteria implementations.AMSA’s 2004 Law Seminar
Fosters Exchange of Ideas on Hot Topics
AMSA’s 2004 Developments in Clean Water Law Seminar took place this week in San Diego, Calif. At one of the best attended Law Seminars in years, attendees learned from the perspectives of leaders in the wastewater treatment field, citizens, reporters and regulators on a range of critical legal clean water issues, including wet weather, stormwater, construction claims, data collection and enforcement issues. One of the highlights of the Seminar was a panel examining the conflicts between the Clean Water Act and Safe Drinking Water Act, which produced a lively discussion on source water protection and other important cross-cutting issues. Materials from the Seminar will be posted to AMSA’s website next week. If you would like additional information about the program or materials please contact AMSA’s General Counsel, Alexandra Dunn, at 202/533-1803 or adunn@amsa-cleanwater.org.