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NACWA to Participate in EPA Workshops on Integrated Planning; Members Urged to Add their VoiceNACWA, along with other national stakeholder groups including the Natural Resources Defense Council (NRDC), the National League of Cities (NLC), the U.S. Conference of Mayors, and the Association of Clean Water Administrators (ACWA), has been invited by EPA to identify two representatives to participate in each of the upcoming workshops hosted by the Agency in Regions 2, 4, 5, 7, and 10 to discuss its integrated planning initiative, now under development. EPA will announce the meetings formally in the Federal Register next week, but has provided the location, date, and time for each meeting:• Atlanta, Georgia - January 31, 2012, at EPA Region 4 Office • New York City, New York - February 6, 2012, at EPA Region 2 Office • Seattle, Washington - February 13, 2012, at EPA Region 10 Office • Kansas City, Kansas - February 15, 2012, at EPA Region 7 Office • Chicago, Illinois - February 17, 2012, at EPA Region 5 Office All workshops will run from 10:00 am to 3:00 pm. EPA first outlined the elements of its draft integrated planning framework in a PowerPoint  presentation during NACWA’s December 13 stakeholder dialogue in Washington, D.C. (see Advocacy Alert 11-26 for more details on the dialogue). The workshops are intended to provide another look at these elements and allow for in-depth discussions with stakeholders around the country. NACWA has learned that while the workshops will be open to the public, the sessions will be structured in order to keep the dialogue focused among the small group of invited participants. While NACWA has been invited to name two representatives to participate in the facilitated discussions at each of the five workshops, all members are encouraged to register for, and participate in, the workshops. Participants who are not at the table for the facilitated discussion will be able to listen and weigh in at designated points during the meeting. Additional details on registration and the structure of these meetings are expected to be provided in an upcoming Federal Register notice.NACWA is working with its Money Matters Task Force to identify the Association representatives for each workshop. In addition, NACWA staff plans to attend all of the workshops. More details on the integrated planning effort and NACWA’s involvement are available in Advocacy Alert 11-26. NACWA Meets with EPA Deputy Administrator, Urges Agency to Reconsider Incineration RuleNACWA representatives, including member agency the Washington Suburban Sanitary Commission, met Dec. 20 with EPA Deputy Administrator Bob Perciasepe to urge the Agency to reconsider its rule imposing stringent new air emission standards on sewage sludge incinerators (SSI). Arguing that the Agency developed the rule based on a flawed interpretation of the Clean Air Act (CAA), NACWA outlined its arguments as to why reconsideration is warranted. The Deputy Administrator was joined by other key EPA staff including Gina McCarthy, Assistant Administrator for the Office of Air & Radiation, as well as representatives from the Office of Water, Office of Solid Waste & Emergency Recovery, and Office of General Counsel. The rule, Standards of Performance for New Stationary Sources and Emission Guidelines for Existing Sources: Sewage Sludge Incineration Units, was finalized in March. NACWA petitioned EPA for reconsideration of the rule in May and filed a petition for judicial review in June. EPA has not formally responded to the Association’s petition for reconsideration.Bringing the issue to the Deputy Administrator level was critical so that the Clean Water Act and Clean Air Act issues raised by the rulemaking could be considered by Perciasepe who can assert authority over all EPA offices and programs. As a follow- up to the meeting, NACWA sent a Dec. 22 letter to Mr. Perciasepe thanking him for his time and consideration of our petition. NACWA expects to hear back from Perciasepe this month, in advance of the February deadline for acting on NACWA’s motion to reconsider, and will update members as developments occur.NACWA to Comment on Revised Recreational Water Quality CriteriaEPA’s long-awaited revisions to its 1986 criteria for recreational waters were released in draft form on December 21, 2011. In large part, the draft revisions make few changes to the 1986 criteria. The criteria values themselves are identical, but there are a few notable differences that may have implications for clean water agencies. The biggest change is the availability of a new, rapid test method – quantitative polymerase chain reaction (qPCR) – which provides results in a matter of hours, rather than days. The new qPCR method for detecting and quantifying enterococci, however, is intended only for beach monitoring and states wishing to use the qPCR method for such beach monitoring are directed to develop site-specific alternative criteria based on the test method. The actual criteria recommendations are based on the existing culture-based test methods. Accordingly, as drafted, all Clean Water Act permit requirements and compliance determinations would be based on these culture methods, not the new qPCR method. Ensuring that the qPCR test method was not used for Clean Water Act permitting or compliance purposes was a priority issue for NACWA. The Agency has also signaled its intention to begin work on implementation guidance for the criteria that should help clarify key qPCR test method issues. NACWA is hopeful that some of this implementation guidance will be available as soon as the criteria are finalized, which must happen by October.The revised criteria also introduce a new term, the statistical threshold value (STV), which would replace the old single sample maximum (SSM). Rather than provide a range of STVs for beaches with different use intensities, as with the current criteria, EPA sets a single STV for all beaches at the 75th percentile. As such, during an assessment period, which EPA is setting at 90 days, up to 25 percent of bacteria samples could exceed the STV and the water would still be meeting criteria. NACWA has been closely following EPA’s efforts to conduct the additional studies necessary for this update to the criteria. EPA’s research agenda and the timing for developing the revised criteria were set based on the terms of a Consent Decree and Settlement Agreement stemming from litigation, in which NACWA intervened, over EPA’s failure to update the criteria. EPA will be accepting comments and additional information on the criteria recommendations document until February 21, 2012, and NACWA will be working to develop comments. Please send any input you may have to Chris Hornback at This e-mail address is being protected from spambots. You need JavaScript enabled to view it . All Members Urged to Complete and Return NACWA Index Survey by January 20NACWA has extended the deadline for its 2011 NACWA Index survey to Friday, January 20. All member agencies should have received a customized survey form via e-mail in late November. 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 in the spring, examines national and regional trends in annual sewer bills. It is critical that as many NACWA member agencies as possible respond, so please complete the brief questionnaire. Surveys can be completed online at www.cleanwatercentral.org, or 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. Please complete the survey by the extended deadline of January 20.2011 Peak Performance Award Application Now Available!NACWA encourages members to submit their applications for the Association’s 2011 Peak Performance Awards. As announced in this week’s Member Update 12-01, the Peak Performance Awards program acknowledges member agency facilities for excellence in wastewater treatment as measured by compliance with their National Pollutant Discharge Elimination System (NPDES) permit requirements. This program has honored thousands of NACWA member agency facilities since its inception in 1987, and the Association anticipates that this year will enjoy another record number of honorees. The deadline for submissions is April 6, 2012. More information on the Peak Performance Award program, including the award categories, criteria, and how to apply, can be found at www.nacwa.org/peakperformance.Register for NACWA’s Winter Conference NowJoin NACWA February 12 – 15, 2012 at the Omni Los Angeles Hotel at California Plaza for its winter conference, Watershed Moment in the Making...Conquering the Challenges of the New Regulatory Frontier. This year’s conference program will focus on the increasing regulatory requirements clean water utilities are facing and the emerging suite of innovative solutions and strategies being employed to address, and even get out ahead of, these regulatory pressures. Sign Up for the City of LA’s Unique Green Technology Tour Registration for NACWA’s Conference and an updated agenda |