White Paper Recommends Changes To Wet Weather Policy, Practice

The National Association of Clean Water Agencies (NACWA) announced on Nov. 2 the release of its Financial Capability and Affordability in Wet Weather Negotiations White Paper, which provides a review of existing EPA guidance on affordability-related issues and recommends modifications to existing policy and practice on wet weather compliance and its financial impacts.

Through case studies, the white paper also provides information for, and guidance on, affordability negotiations and details viable approaches for reducing the financial impacts of wet weather projects on low-income households.

NACWA's Executive Director, Ken Kirk, stated that "When short implementation schedules are coupled with a zero overflow philosophy, many public utilities find it all the more essential to make affordability and financial capability arguments. This white paper reviews a broad sampling of clean water agency wet weather negotiations and highlights various techniques for making successful affordability arguments."

The white paper can be accessed at http://www.nacwa.org/getfile.cfm?fn=2005-10NACWAWhitePprFinCapAff.pdf.

On Oct. 27, NACWA, announced that, after high-level and extensive negotiations with the Natural Resources Defense Council (NRDC), a mutually agreeable draft final guidance addressing the complex and controversial issue of wet weather flow diversions was delivered this morning to EPA. NACWA and NRDC are urging the agency to finalize the joint Guidance on Peak Wet Weather Flow Diversions as written. Simply stated, the NACWA/NRDC agreement provides EPA with a sound path forward on an issue that had become highly politicized and appeared to have reached an unfortunate impasse, NACWA officials said.

NACWA believes that the joint guidance:

1. Provides much-needed national consistency on wet weather flow diversions.

2. Offers significant additional environmental and water quality benefits.

3. Ensures necessary public involvement with, and municipal flexibility in making, peak wet weather flow management decisions.

As Kirk stated, "this joint NACWA/NRDC guidance demonstrates that sound policy can result when organizations stay focused on the critical mission of improving water quality and protecting the public health. I sincerely hope that EPA finalizes this consensus Guidance document as developed."

As the guidance suggests, many municipalities currently have situations in which high peak influent flows during significant wet weather events exceed the treatment capacity of existing secondary treatment units. In these situations, wet weather flows are sometimes diverted around secondary treatment units and then either recombined with flows from the secondary treatment units or discharged directly into waterways from the treatment plant. The NACWA/NRDC Guidance only applies to those diversions as they are recombined, and as they occur in separate sanitary sewer systems. Peak wet weather diversions in combined sewer systems are already regulated in a similar way pursuant to the 1994 Combined Sewer Overflow Policy.

The guidance would benefit the nation's water quality by minimizing POTW reliance on peak wet weather flow diversions as a long-term wet weather management approach to the maximum extent feasible, taking into account the economic and real-world factors detailed in the guidance, NACWA officials said. The guidance asserts that the need to use peak wet weather flow diversions can be eliminated from many systems in a variety of ways, such as by enhancing storage and treatment capacity and reducing sources of peak wet weather flow volume. The method to achieve this objective is through aggressive efforts by sewage treatment plants in consultation with permitting authorities which can dramatically reduce the volume and duration of peak wet weather flows and can improve the treatment and quality of peak wet weather flow discharges.

NACWA believes that the guidance's enhanced public notice provisions will improve the understanding and knowledge of peak wet weather flow diversion practices at public utilities. NACWA and NRDC will work with EPA to finalize the guidance which will provide municipalities with a consistent, sound policy to manage peak wet weather flow diversions.

This article originally appeared in the 11/01/2005 issue of Environmental Protection.

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