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February 28, 1997
EPA Releases Draft WET Strategy, AMSA Seeks Member Input
The U.S. Environmental Protection Agency (EPA) Water Office and Office of Regulatory Enforcement today released a draft National Whole Effluent Toxicity (WET) Implementation Strategy that outlines the agency's tentative plans for providing mid-course corrections to the WET program. The draft strategy is based in large part upon discussions and key issues raised during the 1995 Society of Environmental Toxicology and Chemistry WET Pellston workshop, last September's WET Stakeholder Implementation Meeting, and the recommendations of EPA regional and headquarters staff. EPA is soliciting comments on the draft by March 31, and will be seeking additional stakeholder assistance in finalizing the draft following review.
The five key issues addressed by the strategy are: 1) WET outreach and training for regulators and permittees; 2) the development of water quality criteria and standards based on good science; 3) the writing of discharge permit for WET; 4) enforcement; and 5) funding of research needs. A memorandum accompanying the draft notes that other "discrete issues" identified during the September stakeholders meeting could not be adequately addressed, and will require "additional effort to work out solutions once the draft [WET Strategy] is well underway." The memorandum further notes that other issues, such as independent applicability, cannot be easily resolved without a more "comprehensive and holistic review," which would include involvement of "respective program areas."
AMSA members will receive a copy of the draft early next week via Regulatory Alert RA 97-6, and will require a quick review period. The AMSA National Office encourages member agencies to weigh in on the issue by providing comments on the draft, and recommendations on anything that should be added. The National Office is particularly interested in gauging member feelings regarding the agency's tentative decision to address the issue of independent applicability wholly within the context of the advanced notice of proposed rulemaking (ANPRM) to revise the water quality standards regulation. AMSA has long supported the "weight of evidence" approach, and the National Office is concerned that review of independent applicability under the ANPRM will put it on a slower track than if it were addressed within the context of WET implementation. This may be especially true in light of recent efforts to derail the ANPRM from moving forward (see February 14, 1997 AMSA FaxAlert and Regulatory Alert 97-4).
The results of AMSA's 1996 Member Needs Assessment will be forwarded to the Association's membership early next week. The Member Needs Assessment Survey was conducted during the last three months of 1996 and garnered an overall response rate of 58% (considered a high level of response in the survey research industry). The analysis of the survey data reflects, overall, a very high level of satisfaction among AMSA's members with the services and support that the Association currently provides. Next month the Planning & Bylaws Committee will review the survey's key findings and make recommendations, as appropriate, to the Board of Directors. Thanks to all the agencies who shared their views with us.