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November 19, 1999
AMSA Prepares Comments for Top-Priority Regulations
This week, AMSA has been extremely active on high-priority regulatory issues. Nutrient standards and total maximum daily loads (TMDLs) have been among AMSA's top regulatory priorities this year, and they are currently at critical stages of development. The U.S. Environmental Protection Agency's (EPA) efforts to develop national nutrient criteria using an eco-region/water-body type approach raises a number of important issues for the nation's publicly owned treatment works (POTWs). Due to the wide range of potential impacts of setting numeric ranges for nutrient levels, AMSA, in a letter to EPA Assistant Administrator for Water Chuck Fox, has urged the Agency to provide a formal comment period on its draft nutrient technical guidance documents for various waterbodies (i.e., rivers and streams, lakes and reservoirs). “Given the critical importance of these documents,” which will form the basis of mandated state water quality standards for nutrients by 2003, “we believe that it is essential that a formal comment period be provided,” the letter says. The extension is necessary to adequately assess and respond to a large number of technical complexities involved in developing regional nutrient criteria. For example, AMSA expresses concern that many rivers or river segments in the nation will needlessly be identified as “impaired” based simply on nutrient concentration or chlorophyll levels. The comment period will also allow AMSA to complete the development of a more refined, more workable and less costly alternative to EPA's nutrient standards proposal. AMSA is also seeking to meet with the assistant administrator to further discuss these issues. For further information on AMSA's work to ensure a workable nutrient strategy, contact Mark Hoeke at 202/833-9106 or mhoeke@amsa-cleanwater.org.With the deadline for TMDL comments drawing near, AMSA is gearing up to submit extensive comments on the Agency's full range of proposed TMDL program changes, which include National Pollutant Discharge Elimination System regulation revisions and guidance. The TMDL comment deadline is January 22, 2000. Despite several extensions, this is a tight deadline, especially considering the breadth of proposals and the upcoming holidays. Due to the scope, potential impacts and technical nature of the TMDL proposal, AMSA is intensifying efforts to develop comprehensive comments to ensure that AMSA member agencies concerns are reflected. The National Office encourages members to comment on the proposals. Late last summer, the entire suite of TMDL proposals were distributed to the membership via Regulatory Alert 99-18, which is posted in the Member Pipeline of AMSA's web site, www.amsa-cleanwater.org. Look for further information on the coordination of AMSA's comments. Contact Lee Garrigan at 202/833-4655 or lgarrigan@amsa-cleanwater.org with any questions.
AMSA Delivers Strong Pretreatment Streamlining Response
A number of AMSA member agencies furnished EPA with comments on the Agency's pretreatment streamlining proposal, demonstrating broad support for the points raised in a jointly developed AMSA/Water Environment Federation issue paper. AMSA extends its thanks to all the agencies that submitted comments and helped to develop the issue paper.Correction . . .
AMSA members will soon receive Regulatory Alert 99-21, which contains the recently finalized POTW MACT regulations. The October 29 Fax Alert mistakenly reported that the regulations would be distributed via RA 99-20.