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NACWA is pleased to announce the availability of its Nutrient Summit Outcomes and Issue Paper , which details the discussions at NACWA’s Nutrient Summit last fall.  NACWA drafted the Issue Paper to use in initiating dialogues with key stakeholders on how current approaches to developing and implementing numeric nutrient criteria are hampering efforts to address this priority water quality challenge.  The concepts from the Summit and Issue Paper have already led to important discussions with state regulators and the U.S. Environmental Protection Agency (EPA).  This Advocacy Alert provides additional background on the Issue Paper’s development and outlines NACWA’s next steps.

NACWA Nutrient Summit Discussions, Issue Paper Well-Timed to Influence National Dialogue

The Nutrient Summit, and now the release of the Issue Paper, have been very timely and have already begun to influence the national debate on this issue.  While EPA has played an increasingly important role on nutrient issues in the Chesapeake Bay and Florida, EPA continues to assert that states should take the lead on nutrient-related challenges, working cooperatively with stakeholders – an approach that NACWA’s Issue Paper identifies as a key element for success.  In remarks during Congressional testimony earlier this month, EPA Administrator Jackson indicated that “the case of Florida is unique” and that “addressing nitrogen and phosphorus pollution – which is a major problem - is best addressed by the States.”  Jackson also noted that EPA will soon release a “framework memo” memorializing this preferred approach.  Given the important role that states will continue to play on this issue, NACWA has already initiated discussions with the Association of State and Interstate Water Pollution Control Administrators (ASIWPCA) based on the tenets outlined in the Issue Paper.

The ongoing national debate over the most appropriate, scientifically-based approach for developing numeric water quality criteria for nutrients served as the impetus for last year’s Nutrient Summit.  More than 50 public agency and wastewater community stakeholders participated in the day-and-a-half facilitated discussion to outline what the clean water community believes are the essential elements of a rational approach to developing and implementing water quality criteria for nutrients.  After presentations from EPA, state regulators, and the environmental NGO community, Summit participants provided their perspectives on criteria development and what the clean water community needs to better ensure the investments they make are the right ones.  One of the top issues discussed during the Summit was the need to ensure that criteria are sufficiently linked to actual water quality impacts and that any controls imposed upon wastewater treatment plants be technically achievable and result in measurable water quality benefit.  The importance of being able to demonstrate wise investment for ratepayers was identified as a critical issue for clean water agency leaders.

The Issue Paper contains a set of guiding principles outlining what NACWA believes are the essential elements of any program to address nutrients.  In addition, the Issue Paper makes a series of recommendations on innovative ways to address the nutrient challenge and to improve and better use existing Clean Water Act tools in the nutrient context.  The Issue Paper’s findings and recommendations are not, in every case, representative of a unanimous consensus of the clean water community, but they do identify areas where there are potential opportunities for improvement and areas where utilities need more certainty than the current approach provides.

NACWA Next Steps

Building on its preliminary discussions with ASIWPCA, NACWA plans to use the Issue Paper to further this dialogue with state regulators and explore ways the clean water community can better engage with them in a collaborative fashion.  The paper will also help to continue ongoing discussions with EPA on the need for new approaches.  NACWA will next brief ASIWPCA’s Nutrient Committee on the Issue Paper in mid-April and will be having additional discussions with stakeholders during NACWA’s upcoming National Environmental Policy Forum in May in Washington, D.C.