Member Pipeline - Regulatory - Alert (RA 01-11) - Sample Letter and Helpful Hints
G. Tracy Mehan, III
Designee, Assistant Administrator for Water
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
7th Floor, ICC Building, Mail Code: 4203M
Washington, DC 20460
RE: SANITARY SEWER OVERFLOW REGULATIONS
Dear Mr. Mehan:
On behalf of the [Name of Agency], I write to encourage the U.S. Environmental Protection Agency’s (EPA) Office of Water to take the steps necessary to develop proposed regulations for sanitary sewer overflows (SSOs) that meet the demand for stricter collection system requirements and acknowledge the true challenges inherent in reducing overflows. We agree that SSOs must be controlled and that a federal rule establishing requirements for collection system management will greatly reduce the current number of overflows. However, the draft proposed rule signed by Administrator Browner in January 2001 and awaiting your review is flawed and should not be published in its current form. We urge you to work with municipalities and other stakeholders to craft regulations that better balance solutions to the problem with the anticipated costs of compliance.
While we believe new SSO regulations will improve the baseline of sewer collection system operation and maintenance, we cannot support regulations that impose requirements which we are not capable of meeting even under the most ideal conditions. The prime example of such a requirement is the draft proposal’s absolute prohibition on overflows. Fashioning a regulation that prohibits all overflows outright is incongruous with the Agency’s acknowledgment that some types of overflows are unpreventable even in the best-run and maintained systems. The extremely limited defenses in the draft proposal do not acknowledge the ultimate impossibility of eliminating all overflows. This requirement will place all municipalities in immediate and irreversible noncompliance. Furthermore, the costs of attempting to comply with an absolute prohibition have not been adequately accounted for in the current proposal. [Insert comments on how the draft proposed rule would impact your agency in terms of cost or compliance.]
It is not necessary for EPA to start from ground zero on SSO regulations. The draft proposal contains a number of sound principles that, with adjustment, could form the basis for an effective and environmentally beneficial SSO control program. Rather than proceed with a rule that is flawed at the outset, we believe a far better approach is to develop a true consensus among stakeholders on a more sound SSO regulatory package.
Thank you for your consideration. I encourage you to work with the Association of Metropolitan Sewerage Agencies (AMSA) and other municipal organizations on workable alternatives to the current draft proposal. I can be reached at [phone number and email].
Sincerely,
[Name and title]
Sample Letter to Congress -
Helpful Hints
- Internet:
Use the instructions in the Regulatory Alert to access a copy of the letter and a summary of the bill through Congressional Connection. Use Congressional Connection for addresses, phone, fax and email addresses of your delegation.
- Format:
Adjust the Sample Letter according to the bracketed options, in bold typeface. Try to keep the content of the letter to one (1) page, if possible.
- Recipients:
Copies should be sent to both of your Senators and your Representatives in the House. Copies should be sent to your elected official if appropriate.
- Copies:
Fax your signed letter to Greg Schaner at 202/833-4657 or by email at gschaner@amsa-cleanwater.org for tracking.
- Best Results:
For most effective results, send duplicate copy through email or fax. If possible, place a follow-up call to the staff contact on environmental matters in your Representative’s Washington, DC office to discuss the letter is encouraged.
- Questions?:
If you have any questions, please call Greg Schaner at 202/296-9836.