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10
Energy Recovery & the Water
Resources Utility of the Future
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NACWA continued its aggressive
legal advocacy efforts against the
U. S. Environmental Protection
Agency’s (EPA) new sewage sludge
incinerator (SSI) rule – which
threatens the ability of utilities to
pursue innovative energy produc-
tion and recovery projects with
their SSI units. NACWA’s brief in
the litigation challenges the legal
and technical basis for the SSI rule
and asks the court to overturn it.
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NACWA continued its active engage-
ment in regulatory developments
related to EPA’s new emission limits
for SSIs – including the Non-Hazard-
ous Secondary Materials (NHSM)
rule and the Commercial and Indus-
trial Solid Waste Incinerator (CISWI)
rule. The NHSM rule defines sewage
sludge destined for incineration
as a solid waste (NACWA’s legal
challenge of this rule is temporarily
being held in abeyance while EPA
works to revise the rule). NACWA,
together with other impacted stake-
holders, has worked to ensure that
uncontained gases, such as biogas
generated during anaerobic diges-
tion, are not subjected to the more
onerous requirements associated
with burning wastes as a result of
either the CISWI or NHSM rules.
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NACWA put forward a brief in
litigation over EPA’s final Green-
house Gas Tailoring Rule, sup-
porting the Agency’s decision to
exempt sources of biogenic carbon
dioxide, like POTWs, from the rule
pending further study. The Associa-
tion’s brief highlighted the unique
nature of biogenic emissions from
the wastewater treatment pro-
cess, and explained how unneces-
sary greenhouse gas regulation of
POTWs could inhibit the develop-
ment of new resource recovery and
energy production projects.
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NACWA provided testimony, via a
statement for the record, in conjunc-
tion with a Senate Energy & Natural
Resources Committee hearing on
Senator Jeff Bingaman’s proposed
legislation to establish a National
Clean Energy Standard (CES). The
Association’s statement highlighted
the enormous energy potential
in wastewater and encouraged
Congress to include both biogas
and biomass-based energy produc-
tion in any final legislative package.