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December 10, 2010
NACWA Participates in EPA Meeting on Stormwater Rule, Submits Comments on Potential Chesapeake Bay ProvisionsIn a busy week of stormwater advocacy, NACWA participated Dec. 9 with a number of other municipal and state organizations in a federalism consultation held by the U.S. Environmental Protection Agency (EPA) to discuss the new stormwater rule currently under development, and on Dec. 7 submitted written comments During the meeting, NACWA asked the Agency about their November 12 memo regarding numeric limits in stormwater permits – and how the memo was related to the rulemaking effort. EPA staff responded by saying that the stormwater rule under development is not expected to include requirements for numeric end-of-pipe limits, or numeric pollutant concentration limits, but instead may contain numeric performance standards for new development or redevelopment standards to achieve on-site retention of stormwater. Additionally, with regard to the potential for retrofits, EPA indicated that it was aware of the significant cost of retrofits to municipalities and that any retrofit requirement would likely include the ability to implement retrofits over an extended period of time to take into account cost considerations. NACWA will be following up with some additional written comments, providing further considerations for the stormwater rule as a result of the federalism consultation.
NACWA Submits Stormwater Comments on Chesapeake Bay The Association supported EPA’s consideration of environmental justice (EJ) issues as part of the stormwater rulemaking effort, but noted that many of the low-income communities identified as a focus of EJ efforts are also the ones least able to absorb the significant rate increases that will likely come with the new stormwater regulations. NACWA will continue to be an active advocate on behalf of its members during the rulemaking process and will report on any developments.
NACWA Participates in CSO Summit, Highlights Importance of Money Matters CampaignNACWA participated Dec. 6 in a summit of combined sewer overflow (CSO) communities held in Cincinnati, Ohio to discuss current challenges facing CSO cities, as well as potential solutions to these challenges. Participants at the meeting discussed many of the difficulties their communities are grappling with to address CSOs, with affordability concerns playing a central role for almost every municipality. There was also a significant discussion of the need for greater flexibility in meeting clean water mandates, as well as a consensus that local elected officials need to become more engaged in raising affordability concerns at the national level. Participants acknowledged the important leadership role that NACWA has taken on CSO and affordability issues. NACWA was able to add value to the discussion by highlighting the important efforts of the Association’s Money Matters campaign, noting that many of the potential solutions under discussion are part of the Money Matters effort. In particular, NACWA encouraged those in attendance at the meeting to attend the Association’s Money Matters Summit & Fly-In, on March 1-2 in Washington, DC. This event will provide an important opportunity to clearly convey the clean water community’s top priorities to Capitol Hill and EPA, and will feature information exchanges on the very real affordability concerns NACWA Member Agencies are experiencing as well as face-to-face discussions with top national policymakers. More information on the Money Matters Summit will be available soon. NACWA will continue efforts to spread the message of the Money Matters campaign to help communities meet wet weather mandates through smarter investments and better use of local resources.
Heeding NACWA Recommendation, EPA Seeks Extension to Incineration Rule DeadlineSince last summer, EPA has maintained an aggressive pace in developing its proposed new source performance standards and emission guidelines for sewage sludge incinerators (SSIs), published in the Federal Register on October 14. NACWA filed comments
NACWA Discusses Climate Change Strategy with EPANACWA participated in a conference call this week with EPA and other water sector associations to discuss the Agency’s upcoming climate change strategy for the Office of Water (OW). OW originally published its National Water Program Strategy: Response to Climate Change in September 2008. This document described actions that OW could initiate within two years. OW is now considering a longer-term strategy focusing on actions for the next three to five years, and is seeking stakeholder input. One major topic of discussion was the potential role of adaptive watershed management in helping utilities to adapt to climate change and how to change regulatory structures to better allow this type of watershed approach. EPA also asked questions about improving energy efficiency for drinking water and clean water facilities, stating that considering increased greenhouse gas emissions for improved nutrient removal from wastewater was not valid because of the gains in energy efficiency that could be made at treatment plants. NACWA pointed out the financial considerations involved with both nutrient controls and energy efficiency measures, and noted that some utilities have found that the costs to implement energy efficiency and renewable energy options does not have a sufficient rate of return to justify the investment. EPA plans to release its draft strategy in June 2011 – and a final strategy in October 2011. NACWA, through its Climate Change Committee, will review the draft when it is released and submit comments.
Leadership Center Adds Leading Organizational Change Simulation to CurriculumThe Water & Wastewater Leadership Center, a joint venture of NACWA, the Association of Metropolitan Water Agencies (AMWA), the American Water Works Association (AWWA), and the Water Environment Federation (WEF), will include – for the first time – a computer simulation program called Leading Organizational Change. This enhancement to the curriculum will offer students the opportunity work as a team to save a hypothetical company using limited time and resources to identify the issues, create a change plan, and implement this plan in the face of company-wide resistance. The program is a rigorous exercise for executives to get real-time practice planning and implementing change that introduces and promotes the effective use of change theory, tools and techniques. Leading Organizational Change has been utilized with great success in other executive education programs. The joint venture views Leading Organizational Change, as an excellent opportunity for Leadership Center students to gain an understanding of the factors that trip up promising organizational transformations and the strategies that can make them more successful. The simulation affords participants a better grasp of the complex interpersonal and strategic issues involved to become a more effective change agent in their utility. With utility executives facing both an uncertain economy – and increased environmental challenges – this enhancement to the Leadership Center’s curriculum could not have come at a better time. Application Deadline for 2011 Water & Wastewater Leadership Center Extended to December 31
Jeff Eger Named Executive Director of WEFThe Water Environment Federation has named NACWA Member Agency representative Jeff Eger, Executive Director of Sanitary District No. 1 (SD1) in Wright, Kentucky as its new Executive Director. Jeff will assume the leadership of WEF on January 24, 2011. Under his leadership, SD1 has been recognized as a national leader in the implementation of green infrastructure as a wet weather control strategy, and in the use of innovative, cost effective watershed-based planning to manage wastewater and stormwater infrastructure. Serving on multiple NACWA committees, Jeff has been a driving force in SD1’s involvement with NACWA. Most recently, Jeff’s active involvement on NACWA’s Money Matters Task Force – and his engagement in proposed affordability legislation, green infrastructure, and drinking water/clean water nexus issues – has been invaluable to Association’s advocacy agenda. Jeff succeeds William (Bill) Bertera, who has served as WEF’s Executive Director since 2001. Bill’s legacy at WEF includes increased membership and financial stability, as well as growing WEFTEC to the largest annual water quality conference and exhibition in the world. NACWA looks forward to working with Jeff in his new leadership capacity as WEF Executive Director.
NACWA Index Responses Due by Next Friday, December 17The Association is now conducting its 2010 NACWA Index survey. All Member Agencies should have received a customized survey form in the mail last week. NACWA has published the Index annually since 1992 to track increases in the average annual single-family residential sewer bill, as compared to the rate of inflation. The annual NACWA Index, which will be distributed to the membership next spring, will examine national and regional trends in annual sewer bills since the mid-1980s. The survey is one of the Association’s most-used resources – made possible by the responses provided by NACWA’s members. It is critical that we get information from as many NACWA Member Agencies as possible, so please make every effort to complete the brief questionnaire. Surveys can also be completed online at www.cleanwatercentral.org, or simply contact Thea Graybill at This e-mail address is being protected from spambots. You need JavaScript enabled to view it to get your agency’s customized survey form via e-mail. We are asking that members complete their surveys by next Friday, December 17. Thank you, in advance, for your participation.
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to the Agency regarding potential Chesapeake Bay-specific provisions of the stormwater rule. As part of the invitation-only federalism consultation, EPA discussed many of the options currently under consideration for the new stormwater rule including, an expansion of the areas subject to federal municipal separate storm sewer system (MS4) permits; the inclusion of performance standards for new development or redevelopment for onsite retention of stormwater using green infrastructure or low impact development techniques; and, the possibility of retrofit requirements for areas of existing impervious surface.