A Clear Commitment to America’s Waters
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ACWA and the Water Environment Federation (WEF)
will host a web seminar on Tuesday, December 16, from
1:00 to 2:00 pm EST to discuss important changes
to the Clean Water State Revolving Fund (CWSRF).
for the
Revisions to Clean Water State Revolving Fund
Program and EPA Guidance to States
web seminar is complimentary.
The CWSRF received a significant make-over this year by Congress
in the reauthorization package for the Water Resources Reform&
Development Act (WRRDA). Over the course of the winter and spring
NACWA actively urged Congress and the Administration to demon-
strate their commitment to the CWSRF as a core investment tool for
municipal wastewater agencies. Key provisions in the WRRDA bill
reflected this work by extending the CWSRF loan repayment period
to 30 years; enabling economically distressed communities to receive
more affordable financing; and incentivizing investments for projects
related to energy efficiency, water efficiency, reuse, and sustainable
infrastructure practices. The U.S. Environmental Protection Agency
(EPA) issued
to states in September on implementation of
the new statutory revisions, many of which went into effect on October
1. Municipal borrowers across the country will be impacted by these
changes and there is much to learn and understand.
The December 16 web seminar will include participation by Andrew
Sawyers, Director of the Office of Wastewater and former CWSRF
Administrator for the State of Maryland. He will discuss EPA’s recent
to the states – and how states are likely to implement these
changes. Sawyers will also discuss how these changes may impact
clean water utilities. Plan today to attend this important offering.
Web Seminar to Examine CWSRF Changes
Dental Amalgam
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ensure the Senate accepts the House recommendation in final negotia-
tions over EPA’s FY15 budget.
Though integrated planning has, thus far, been primarily used as a tool
for communities negotiating consent decrees, ample opportunity ex-
ists for integrated plans to be used in coordination with CleanWater
Act permits. In fact, EPA’s technical assistance is focused on just this
issue. In New Jersey, where 21 communities will soon receive combined
sewer overflow (CSO) permits for the first time, integrated planning is
being used on the ground floor of that state’s efforts to require devel-
opment of long-term control plans (LTCP). In an effort to ensure its
members and other utilities in New Jersey fully understand integrated
planning and its opportunities, the Association partnered with the
Association of Environmental Authorities of New Jersey (AEANJ) to co-
host an
Integrated Planning Workshop
on October 23 in Newark for public
agencies across the Garden State. Over 35 attendees benefitted from
expert insight and frank discussion with the state regulators, as well as
EPA Region 2, and EPA Office of Water and Office of Enforcement &
Compliance Assurance staff.
The discussion around the
Integrated Planning Framework
has begun to
change the way EPA, both policy and enforcement staff, view their inter-
actions with the municipal clean water community. It is reshaping the
command and control approaches of the past into more collaborative
discussions, with the clean water utility firmly in the driver’s seat on in-
vestment priorities and schedule. NACWA and its members will contin-
ue to nurture this evolving relationship and utilize integrated planning
to recast the way CleanWater Act goals are met.
Affordability, Integrated Planning
Rule Creates New Classification for Dental Offices
The proposed rule would revise the General Pretreatment Regulations
to create a new classification of categorical industrial user (CIU), the
“Dental Industrial User” (DIU). The oversight required by clean water
agencies of DIUs would be less onerous than required for CIUs classified
as Significant Industrial Users (SIUs). For example, clean water agencies
must conduct annual inspections and sampling of SIUs, as well issue a
permit or other control mechanisms, which would not be requirements
for DIUs. If a DIU does not maintain compliance, however, it must be
treated as an SIU by the utility or other control authority (which is the
state or EPA region for dentists discharging to POTWs without pre-
treatment programs). Significant noncompliance would be triggered if
a DIU was 45 days late with its annual report, requiring the clean water
agency to initiate enforcement action, and the DIU would become an
SIU if compliance was not achieved within 90 days.
Costs Dramatically Underestimated, Potential Benefit Small
EPA estimates that the annual cost of the rule would be $44 to $49 mil-
lion, to achieve a reduction of only 860 lbs. of mercury discharged by
clean water agencies into waters of the U.S. NACWA believes that EPA’s
cost estimate for the rule is too low, since the cost for public utilities and
other control authorities is dramatically underestimated. NACWA also
believes that the amount of mercury actually removed due to the rule
would be even lower, since EPA underestimates the current mercury re-
moval efficiency of POTWs and neglects to consider the falling numbers
of amalgam fillings that are placed and removed due to improved oral
health and the use of resin fillings.
NACWA has communicated with EPA on multiple occasions about
the issues associated with a dental amalgam separator rule, and the
Association is planning to provide extensive comments on the proposed
rule. NACWA’s Pretreatment & Pollution Prevention Committee met
on November 6 to discuss the rule, and committee members continue
to overwhelmingly believe that the rule is not necessary and will create a
significant burden to clean water agency pretreatment programs.
NACWA will be conducting a national survey of POTWs to obtain up-
to-date information on mercury removal efficiencies and other infor-
mation that will help to assess the impact of the rule. Comments on
the proposed rule are currently due December 22, but NACWA and the
American Dental Association (ADA) have submitted a joint request for a
60-day extension of the comment period.
