AMSA favors an integrated and holistic SSO rule

May 7, 2002
The Association of Metropolitan Sewerage Agencies said more progress would be made in Sanitary Sewer Overflow control with a single federal rule for all requirements and standards.

May 7, 2002 -- The Association of Metropolitan Sewerage Agencies (AMSA) says the lack of substantial progress in Sanitary Sewer Overflow (SSO) control can be attributed solely to the absence of a single federal rule that spells out all requirements and standards.

AMSA continues to express concern that key parts of the draft regulation are flawed, however, the group also says it has a genuine interest in seeing EPA develop a workable rule with consistent, national standards for controlling overflows.

Last week in a letter to EPA Administrator Christine Todd Whitman, AMSA lent the Agency its support for its February 25, 2002 Water Quality Trading Policy Statement as well as for the sanitary sewer overflow (SSO) proposed rule plan that EPA Assistant
Administrator for Water, Tracy Mehan announced November 7, 2001.

Mehan's plan calls for proposing the same regulatory text from the January 2001 draft, but with a revised preamble inviting comment on alternative options. AMSA's support of the rulemaking process depends upon EPA's following the plan announced by the assistant administrator.

AMSA's letters to EPA explain that it believes the quality and amount of SSO reporting and notification would not significantly improve. The group says if EPA pursues a two-phased approach to promulgate the SSO unintended consequences would undermine national improvements in SSO control and would be fatal to the rulemaking process.

AMSA said the proposed rule would impose new permit requirements for the estimated 5,000 satellite communities that are currently unregulated. Proceeding with a rule that only addresses reporting, notification, and record keeping apart from the satellite collection system provisions, it said, would leave a significant portion of the collection system not owned by a permitted publicly owned treatment works (POTW) unregulated by the new provisions.

"AMSA will not support a proposal that simply publishes the withdrawn January 2001 rule package. We have consistently advised the Agency that its current draft rule provisions are flawed, primarily because of the inclusion of a zero overflow standard for SSOs, and that a new, more realistic standard based on the implementation of the widely-accepted Capacity Management Operation and Maintenance (CMOM) plans should be considered," said the April 30, 2002 letter.

Wet weather events, such as massive rainstorms, lead to overflows of sewer systems that were not built to handle the capacity generated by these storms, causing overflows into the nation's waterways.

EPA estimates it would cost municipalities $45 billion to overhaul only combined sewer overflows, with an additional price tag of $32 billion for sanitary sewer overflows, as municipalities continue their hard work to control overflows.

"Cash-strapped cities and towns simply cannot foot this bill, especially when you take into account aging infrastructure needs, " said Adam Krantz, director of communications and public affairs for AMSA. "Between $460 billion to $1 trillion in further infrastructure investment will be required over the next 20 years, according to the Water Infrastructure Network, EPA and others as well as growing water security costs," said Krantz.

Additionally, AMSA announced its support of EPA's draft Water Quality Trading Policy Statement. The organization also is encouraging EPA to clarify the relationship between trading and total maximum daily loads (TMDLs), saying that it is "...important to add that trading should not be used as a replacement for a fair and equitable allocation of pollutant reduction responsibilities among watershed sources."

Ken Kirk, AMSA executive director said, following the organization's review and discussion of the February 25, 2002 draft policy, and feedback from AMSA members and Office of Water staff, "...we believe the draft policy represents a positive step towards encouraging greater use of voluntary, market-based approaches to achieve water quality objectives. AMSA believes that water quality trading offers a potential option for achieving cost-effective water quality gains."

A TMDL or Total Maximum Daily Load is a calculation of the maximum amount of a pollutant that a water body can receive and still meet water quality standards, and an allocation of that amount to the pollutant's sources. The Clean Water Act, section 303, established the water quality standards and TMDL programs.

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