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Clean Water Current - October 31


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October 31, 2014

Pretreatment Professionals to Discuss EPA’s Proposed Dental Amalgam Rule

EPA’s proposed Dental Amalgam Separator rule pdf button, published last week after years of delay, would require the over 100,000 dental offices that place or remove amalgam to install dental amalgam separators.  Utilities with pretreatment programs will be required to provide oversight of these dental offices, which must also submit annual certifications and follow best management practices.  EPA estimates that the proposal will result in a reduction of 860 lbs. of mercury being discharged into waters of the U.S. each year, at an annual cost of $44-49 million.  NACWA’s Advocacy Alert 14-21 provides details about the proposed rule and its impacts on utilities.  Public comments on the proposed rule are due by December 22; however, NACWA and the American Dental Association (ADA) plan to jointly request an extension of the comment deadline. 

NACWA’s Pretreatment & Pollution Prevention Committee will hold a conference call next Thursday, November 6, from 2:00 – 3:00 pm Eastern, to discuss the proposal and strategies for the Association’s comment effort.  The Association will likely focus on EPA’s cost and mercury removal estimates, since the estimated costs may be too low and the removal estimates too high.  All NACWA members are welcome to join the call – please call 1-877-394-0659, enter the Conference ID (2349353972), and log in on your computers at to join.

NACWA Convenes Discussion on Implementation of EPA's Ammonia Criteria

NACWA, together with the Water Environment Federation (WEF), the Water Environment Research Foundation (WERF), and the Association of Clean Water Administrators (ACWA), convened a day and a half-long meeting this week in Arlington, Virginia to discuss implementation of EPA's revised ammonia aquatic life criteria.  Representatives from each organization, as well as experts on freshwater mussels, participated in the meeting.  EPA presented an overview of the criteria – which was similar to what the Agency presented to NACWA members after the criteria were released.  The discussion during the meeting, however, focused on the concerns raised by NACWA members and state regulators regarding implementation challenges, including those associated with determining whether freshwater mussels are present or absent in a particular water body. 

The new criteria allow for site-specific recalculation if mussels are determined to be absent from a water body, resulting in much less stringent criteria.  It is anticipated that many dischargers will try to take advantage of this recalculation, where possible.  Much of the first day of the meeting focused on small dischargers, including lagoon systems, that will likely not be able to meet the criteria (and who are not likely to have the capability of conducting the studies necessary for site-specific criteria).  NACWA and the other meeting sponsors utilized the discussion to identify gaps in knowledge and areas where additional research or guidance tools could help ease the burden on states and clean water agencies as they implement the criteria.  A summary of the meeting, as well as all the presentations, are available now available on the NACWA website.

Presentations from the workshop:



NACWA Weighs in on FY16 Budget for Infrastructure

As the Administration develops its budget priorities for FY 16, NACWA is weighing in and urging that funding for water infrastructure remains a top budget priority.  The Association sent a letter to the White House Office of Management & Budget urging the Administration to fund the Clean Water State Revolving Fund Program at FY 15 levels – and to not place any limitations on the tax-exemption status of investments in municipal bonds.  In addition, NACWA joined other water sector associations on a letter urging the EPA to provide funding for the Water Infrastructure Financing Innovations Act Program (WIFIA), while at the same time ensuring that funding remains intact for the CWSRF. 

The Administration’s final FY 16 budget request due to be send to Congress in February.  It is estimated that over $500 billion will be needed over the next twenty years to help communities meet their clean water challenges.  A strong federal commitment to helping communities meet this investment need remains a top priority for NACWA members and a key component of the Association’s advocacy agenda. 

Clean Water Finance Dialogue Summary Complete; Workgroup to Be Formed

NACWA recently distributed its summary pdf button to participants in the first Clean Water Finance Dialogue (held June 24 in New York City).  The Dialogue was the first of its kind and brought together private investment and public clean water agency leaders to discuss the opportunities and barriers to increased private investment in public clean water infrastructure.  The most prominent barriers identified were that private capital is often less competitive than public financing methods, like tax-exempt municipal bonds, although arguments were brought forth asserting that this is beginning to change.  Another barrier identified was the lack of trust between the sectors, an issue that this – and future dialogues – are aimed at addressing and overcoming.

As the summary report concludes, the two sectors can establish a base of trust by beginning with partnerships on smaller, “bolt-on” projects in more discrete areas – especially in the arena of  Utility of the Future-type projects – including biosolids recycling, nutrient recovery, green infrastructure, waster reuse, and energy production.  To help develop this trust – and to ensure both an effective conversation about public-private efforts on clean water projects, and that NACWA’s advocacy efforts in the finance arena are well-informed – the Association plans to create a Clean Water Finance Workgroup to provide leadership and strategic input.  The Association, and this Workgroup, will promote dialogue through a variety of different formats and advance NACWA’s advocacy efforts on finance issues through strategic discussions.  If you are interested in joining the Workgroup, please email This e-mail address is being protected from spambots. You need JavaScript enabled to view it , Government Affairs Assistant, or call her at 202.588.1801.

EPA Highlights Green Infrastructure in Cleveland; Convenes Second Annual Summit

Northeast Ohio Regional Sewer District (NEORSD) partnered with EPA and Cleveland State University to host the second annual Green Infrastructure Summit in Cleveland, Ohio this week.  Thirty-three communities gathered for a two-day event that built on the first Summit pdf button EPA held for its Green Infrastructure (GI) partner communities in Syracuse, NY last year.

NACWA members included representatives from Toledo, Omaha, Akron, Portland, Atlanta, Los Angeles, Milwaukee, Chicago, and Washington DC, who joined regulators and other participants for a tour of GI projects in NEORSD’s service area, and a day and a half of peer-to-peer discussion.  The bulk of the event involved a large facilitated roundtable covering a broad array of topics including using GI to reduce volume into combined sewer systems; effectively manage stormwater in separate systems; provide multiple community benefits; and, build resilient communities.  GI leaders, program managers, and planners exchanged best practices and lessons-learned when using GI as a tool to enhance traditional gray infrastructure within comprehensive wet weather solutions.

EPA also released the Enhancing Sustainable Communities with Green Infrastructure Guidebook pdf button on Monday which aims to assist communities in developing a GI plan that can overcome technical, regulatory, financial, and institutional obstacles that could limit widespread implementation.

Public Agencies Invited to Join Reuse Workgroup, Conference Call Next Week

NACWA continues to track reuse as part of the Water Resources Utility of the Future pdf button effort, and has developed a Water Reuse Workgroup to help determine the scope of – and strategically guide – the Association’s advocacy around water reuse and recycling issues.  This working group is setting NACWA’s reuse agenda and positioning collaboration with other organizations.  NACWA will be holding a call of the Workgroup on Thursday, November 6 at 2:00pm Eastern.  Any Public Agency members interested in joining the Workgroup or participating in the call should contact Brenna Mannion at  This e-mail address is being protected from spambots. You need JavaScript enabled to view it .

NACWA Blog of the Week –
What a Difference a “Green” Year Makes

NACWA’s Director, Regulatory Affairs & Outreach, Brenna Mannion attended the Green Infrastructure Summit in Cleveland this week (see related story).  What she learned is that there have been quite a few changes in how communities are dealing with stormwater in the period of one year, illustrating how a sustainable combination of green and gray infrastructure ultimately builds sustainable and resilient communities.  What were these community improvements and what other programs can we see in the future?  Read on to find out, or subscribe to The Water Voice and never miss a post!

Not to be Missed. . .
Webcast to Focus on Utility Concerns about Ebola Virus

A November 4, 2:00-3:00 pm EST, Water Environment Federation (WEF)/Water Environment Research Foundation (WERF) webcast – co-sponsored by NACWA, Association of Clean Water Administrators (ACWA), the American Public Health Association (APHA), and WateReuse – will address concerns that the Ebola virus poses on wastewater worker safety.  The webcast will include a general overview of what is known about the survival of the Ebola virus in wastewater and what is needed in terms of additional research, sanitation and personal protective practices for wastewater personnel.  Other WEF resources on operator safety, and the U.S. Centers for Disease Control and Prevention (CDC) Interim Guidance for Workers Handling Untreated Sewage from Ebola Cases in the United States (if released prior to this webcast), will also be featured.  Registration is required for the free webcast.



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