3 2
As the dust settles from the mid-term elections, questions abound over
the potential fallout for the U.S. Environmental Protection Agency
(EPA) and its regulatory programs now that Republicans have control
of Congress. But while some high profile rules such as the proposed
Waters of the U.S. Rule will come under fire, much of EPA’s agenda will
be unaffected. And for clean water utilities, even if there were no new
rules released from EPA in the next two years, there is already plenty to
manage. Affordability challenges will continue to mount and the role
of the
Integrated Planning Framework
in helping to prioritize mandated
investment will likely play an increasingly important role.
November Meeting Features Utility Perspectives
In an effort to maintain a productive dialogue on affordability issues,
NACWA hosted a meeting on November 4 with representatives from
several public water and wastewater utilities, as well as staff from the
Association of MetropolitanWater Agencies (AMWA), the American
Water Works Association (AWWA), the Water Environment Federation
(WEF) and the National League of Cities (NLC), to discuss the issue of
affordability and the financial capacity of clean water utilities to meet
their CleanWater Act mandates. Dave Rager, NACWA Board Member
and Executive Director of the Northern Kentucky Sanitation District
No. 1 in Ft. Wright, Ky., provided an overview of the work on affordabil-
ity his utility is doing as it strives to meet its requirements under a fed-
eral consent decree. Rager and his team have been employing many of
the new approaches to assessing the affordability of clean water spend-
ing that NACWA, WEF, AWWA and others have studied over the past
several years. These approaches are intended to provide a more refined
picture than median household income. Discussions during the meet-
ing focused on what level of burden associated with clean water spend-
ing is considered ‘affordable’; ways to offset impacts on low income
populations, including potential federal subsidy programs; opportuni-
ties for Congress to provide a more rational approach to address finan-
cial capability challenges; and, other areas where the water sector could
work together to advance this issue.
Financial Capability Framework Anticipated
Discussions at the meeting also reflected on the role of EPA’s forthcom-
ing
Financial Capability Framework
, expected to be released later this
year – and the recent report by the Environmental Financial Advisory
Board, which recommends a number of significant changes to EPA’s
current approach to evaluating financial capability. NACWA is prepar-
ing a brief summary of the discussion and will make that available to
its membership soon. NACWA and the other water sector groups plan
to discuss next steps with the goal of having some concrete direction
and message by Water Week 2015 in April.
Federal Dollars to Help Utilities Move Forward
On the integrated planning front, five communities benefitted from
NACWA’s efforts to promote and support EPA’s
Integrated Planning
Framework
, with the Agency announcing in October that two NACWA
members, the City of Springfield, Mo. and the Onondaga County
Department of Water Environment Protection, N.Y., along with the
Cities of Burlington, Vt., Durham, N.H. and Santa Maria, Calif. were
selected as recipients of a total of $335,000 of technical assistance to
help develop integrated plans. The announcement came after nearly
two years of NACWA advocacy urging Congress and EPAmake fund-
ing available to support development of these plans. Currently, the
House of Representatives has proposed an additional $2 million in
FY15 for another round of awards and the Association is working to
Affordability, Integrated Planning Continue
to Play Central Role in Clean Water Policy Discussions
A
fter several years of delays, the U.S. Environmental
Protection Agency’s (EPA) proposed a Dental Amalgam
Separator Rule on October 22 that, if finalized, would es-
tablish pretreatment standards for the over 100,000 dental
offices that place or remove amalgam fillings. Clean water agencies
(also known as publicly owned treatment works or POTWs) with
pretreatment programs would be required to ensure the compliance
of the dental offices in their service areas, potentially creating a sub-
stantial burden on these utilities.
Under the rule, dental offices that place or remove amalgamwould be
required to install separators certified to achieve a 99% reduction of to-
tal mercury according to the 2008 ISO 11143 standard. Dental offices
would also be required to comply with two best management practices
(BMPs): preventing scrap amalgam from being flushed down the drain,
and cleaning chair-side traps at least weekly with approved cleaners.
A one-time baseline report and initial compliance report must be pre-
pared by the dental offices, as well as annual certification statements.
Dental offices that already have separators installed could continue
using these separators until ten years after the effective date of the final
rule.
Proposed Dental Amalgam
Separator Rule Would
Substantially Affect POTWs
Photo Credit: DeltaDental.com
