Member Pipeline - Fax Alerts SpecialEdition - December 15, 2003
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December 15, 2003
AMSA Urges Members to Participate in Call on Blending Comments
With the U.S. Environmental Protection Agency (EPA or the Agency) seeking comments on its November 7 proposed blending policy by January 9, 2004, it is critical that AMSA members speak with one voice in support of this guidance. To this end, AMSA would like to invite members to participate in a conference call regarding the blending guidance this Thursday, December 18 at 2:00 p.m. AMSA asks that you e-mail Chris Hornback at chornback@amsa-cleanwater.org for the conference call-in number and passcode.Unless AMSA members demonstrate unequivocally that overall the blending policy is an environmental step forward for their communities, they will be faced with a situation where the guidance does not get finalized — an outcome that could be used to show that the Agency opposes blending. This interpretation could lead to a crackdown on blending by states and EPA Regions which could cost publicly owned treatment works (POTWs) nationwide hundreds of billions of dollars. As part of this conference call AMSA will describe what is at stake should the effort to finalize the blending guidance be defeated and will inform and update members on the Association’s comment initiatives and the need for broad member participation.
AMSA has been a consistent and vocal supporter of the general concepts contained in the proposed policy because they clearly restate EPA’s long-standing but unwritten policy that blending is a legal and environmentally sound practice for managing peak wet weather flows at POTWs. Once the Association received an early version of the draft guidance, it provided an overview of it to the Wet Weather Committee immediately via listserv on November 4. That same day, AMSA distributed a Special Edition FaxAlert to the membership on the blending issue, as well as a press release that was instrumental in voicing the views of POTWs in local, city, and national media. A detailed overview and list of questions for member input into AMSA’s comment effort was distributed to members via Regulatory Alert 03-14. AMSA has received a variety of member comments and input both from members that blend as well as from members that do not currently blend but want to see the guidance become final because it will ensure their ability to blend should they need to do so in the future. For this reason, AMSA invites members that currently blend and those that do not but may choose to blend in the future to participate in the conference call.
Both the quantity and quality of AMSA and POTW comments will play a critical role in making sure EPA finalizes the blending guidance. AMSA believes that members should voice their support in their comments for the guidance’s clarification that blending is not a prohibited bypass and can be authorized in a Clean Water Act permit if six key “principles” are followed. AMSA is aware that members have specific concerns with the some of the principles that they must voice within their individual comment efforts. These concerns, however, must be made within a clearly enunciated overall support of the guidance. POTW comments also need to focus on the potentially significant costs to their communities should the blending guidance not go forward or be left open to differing Regional interpretations.
Again, this key conference call will be held on December 18 at 2:00 pm Eastern Time. AMSA asks that you e-mail Chris Hornback at chornback@amsa-cleanwater.org for the conference call information.