(March 21, 2018) - NACWA submitted a letter to Alexandra Dapolito Dunn, Regional Administrator, EPA Region 1, to expand on the issues that were raised during a February 15 meeting with Dunn and several senior EPA staff members.
In the letter, NACWA reiterates its position that public clean water utilities must be considered and treated like an equal partner in the cooperative federalism calculation. The letter also addresses the Compliance Assistance First approach; net environmental benefit as the key metric of success; support for Integrated Planning and community prioritization of Clean Water Investments; and the need for the Region to champion a policy encouraging modification of consent decrees, when the utility/community can demonstrate that the modification will result in an increased net environmental benefit.
NACWA also followed up on three specific issues that have arisen in Region 1, which have potential nationwide ramifications: the Long Island Sound Enhanced Nutrient Reduction Strategy, the small municipal stormwater permits issued by EPA Region 1 to Massachusetts and New Hampshire, and the nexus of drinking water and clean water issues around the use of orthophosphates for corrosion control under the Lead and Copper Rule.
NACWA will be advancing this discussion at the Region 1 Forum to be held on July 23 in conjunction with the Association’s Utility Leadership Conference & 48th Annual Meeting, which will be held in Boston on July 23 - 26.
Members interested in setting up meetings in other EPA Regions should contact Chris Hornback, NACWA’s Deputy Chief Executive Officer.