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Massachusetts Coalition for Water Resources Stewardship

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Massachusetts Coalition for Water Resources Stewardship Presentation to New Hampshire Water Pollution Control Association by Robert L. Moylan Jr. P.E. – PowerPoint PPT presentation

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Title: Massachusetts Coalition for Water Resources Stewardship


1
Massachusetts Coalition for Water Resources
Stewardship
  • Presentation to New Hampshire Water Pollution
    Control Association
  • by Robert L. Moylan Jr. P.E.
  • Commissioner of Public Works and Parks
  • Worcester MA
  • 6/13/2013

2
Overview
  • What is the Massachusetts Coalition for Water
    Resources Stewardship (MCWRS)?
  • What is its purpose?
  • Why was it formed?
  • What has it done?
  • What has been its impact?

3
Who is the Massachusetts Coalition for Water
Resources Stewardship?
  • It is a group of cities and towns and sewer
    authorities across Massachusetts who banded
    together in June 2007 and who share a common
    concern with how EPA writes and enforces NPDES
    permits
  • Recently established as a 501(c)(4) non-profit
    and elected Board of Directors

4
What is its purpose?
  • To speak for the regulated community with one
    voice
  • To object to unreasonable and costly unfunded
    mandates
  • To seek real environmental improvements by making
    cost/benefit a fundamental consideration of any
    permit requirement
  • To engage the rate paying public about the costs
    and other impacts of NPDES permits (CSOs, POTWs,
    Stormwater)
  • To restore the partnership that once existed
    between federal/state regulators and the
    regulated community

5
Why was it formed?
  • FRUSTRATION!!!
  • We have all been there. Dealing with EPA is a
    difficult and frustrating experience because they
    come from a different planet
  • They dont have to face ratepayers thus cost is
    not a consideration
  • Their permits often lack valid science
  • They have compartmentalized permitting so that
    the big picture is often lost
  • They fail to consider sustainability when
    establishing permit requirements
  • They do not communicate well

6
What has MCWRS done?
  • In November 2007, issued a White Paper with 10
    recommendations for change
  • In April 2008, met in Washington DC with the full
    Massachusetts federal delegation and Region 1 EPA
    to discuss the recommendations of the White
    Paper
  • Met monthly from May-December 2008 with DEP and
    EPA to explore White Paper recommendations.
    Results of these meetings were compiled in a
    report to the Mass. Congressional delegation.
  • Received NACWAs Special Recognition Award in
    2009
  • We have since held 4 Symposiums to discuss NPDES
    permits in general, develop strategies for
    reform, and offer reasonable alternatives to
    EPAs heavy handed approach

7
White Paper recommendations
  • Base permits on peer reviewed science and
    holistic watershed planning
  • Costs and cost/benefit must be considered
  • Focus on biggest problems first
  • Develop longer permit terms
  • Open dialogue with regulators and stakeholders
  • Coordinate permits by watershed
  • Numerical limits must be based on valid science
    and pragmatic watershed needs
  • Commonwealth to assume primacy

8
Outcome of EPA/DEP/Coalition Meetings
  • Agreements
  • Better communication needed
  • Watershed based planning and permitting needs to
    be re-considered and must involve all
    stakeholders
  • Innovative permitting, especially pollutant
    trading should be considered
  • Compliance costs are a significant factor
  • Good science should form the basis for regulatory
    decision making
  • DEP and EPA should explore authorization of NPDES
    permitting program in Massachusetts

9
Outcome of EPA/DEP/Coalition Meetings (cont.)
  • No Agreement/Continue Debate
  • Cost and affordability EPA maintains the CWA
    does not give them discretion to consider costs
    and that they address the issue through
    compliance schedules and Use Attainability
    Analysis.
  • Coalition wants longer permit terms as 5-year
    term is unreasonable given costs and project
    funding EPA says CWA dictates term
  • EPA maintains that it uses the best available
    science Coalition claims that EPA often ignores
    better science if it refutes their own studies
  • Coalition believes permits should consider
    sustainability in terms of energy use and overall
    environmental impact EPA says CWA does not allow
    for such consideration

10
Outcome of EPA/DEP/Coalition Meetings (cont.)
  • Recommendations
  • Congress, EPA, DEP, and Coalition all have role
    to play
  • Amend the CWA
  • Promote and incentivize pollutant trading
  • Reconsider watershed planning and permitting
  • Explore full realm of UAA
  • Reassess 2 HMI test for affordability
  • Fund river studies
  • Review and amend TMDLs
  • Revise water quality standards to consider urban
    areas

11
The CWA in 1972
  • Created at a time when federal funding was the
    norm and no consideration that this funding
    stream would disappear
  • Hugely successful at addressing gross
    contamination of waters
  • Built sewage treatment plants where there were
    none
  • Modernized existing sewage treatment plants
  • Brought everyone together shared costs, shared
    goals, noticeable benefits

12
The CWA Now
  • State and federal government no longer have a
    financial interest in financing CWA requirements
    costs do not concern them they have taken a walk
  • Science supporting CWA requirements is often
    lacking it is the publics money, shouldnt we
    have the best science?
  • Appeal of EPAs mandates is costly and severely
    biased in favor of EPA process is rigged
  • Costs are borne entirely by local by ratepayers
  • The game has changed-the target is now fine
    tuning waterways that have been vastly restored.
    The goals, expectations and strategies for
    success are more nebulous.how clean is clean?
  • The current process is totally adversarial its
    a loser!

13
Examples of the Regulatory Excess
  • UBWPAD (POTW)
  • 180M upgrade to meet 0.75P and other
    improvements in 2001 permit
  • EPAs latest permit (2008) requires
  • 200M to meet 0.1P and 5 N which will increase
    debt service another 10M/yr and OM by 5M/yr
  • Cost to average customer in Worcester will
    increase by about 2.25/CCF
  • Based on same science as their 2001 permit

14
Regulatory Excess UBWPAD (cont.)
  • Our model of river shows
  • New limits will have little effect on river
    beyond that of current upgrade
  • New limits will increase the carbon footprint
  • 20 increase in electrical power (600 homes)
  • 21 million ft³ of natural gas (500 homes)
  • 1.8 million gals. of ferric chloride
  • 8.2 million gals. of sodium hydroxide
  • 150,000 gals. of methanol
  • 50 more sludge ash

15
Regulatory Excess (cont.)
  • Worcester Stormwater NPDES permit
  • Phase 1 community..1st in EPA Region 1
  • Cost to comply with current draft permit as
    estimated by CDM is 1.2 BILLION!
  • The goals of our permit will be required by all
    other communities
  • Maximum Extent Practicable (MEP) is no longer the
    standard.meeting numeric limits is expected
  • Stormwater effluent to TMDL impaired waters
    cannot cause or contribute to an exceedence
  • TMDL of dubious quality drive permit requirements

16
Whats next?
  • EPA has estimated that over the next 20 years it
    will cost 1 trillion dollars to meet the
    requirements of the CWA..this cost will be borne
    completely by local ratepayers
  • Nitrogen and Phosphorous will continue to be the
    pollutants of concern. Dischargers will be
    required to implement LOT processes to meet new
    standards because dischargers are the easy
    targets
  • Individual stormwater permits for private
    properties with gt2 acres impervious area (i.e.,
    Bellingham, Milford, Franklin MA)

17
Whats next (cont.)
  • Stormwater Permits with have numerical limits
    MEP will be superseded
  • Eliminate CSOs and SSOs
  • More guidance, regulations, and exceedance of
    statutory authority with increasing intrusion
    into local control
  • Stricter NPDES limits and more control is equal
    to higher rates
  • Can you say Live Free or Die

18
What are we up against?
  • Environmental extremists (both inside and outside
    of EPA) manipulate CWA to drive their agenda.
    Money is no object and saving the environment has
    no limit.
  • Environmental advocates are well organized, well
    funded, entrenched within the agencies, and are
    masters at manipulating public thinking through
    emotional and oversimplified views.
  • The most powerful environmental groups use the
    media and the courts to convey their message and
    intimidate the agencies.

19
What can you do???
  • Work together and speak with one voice and a
    consistent message.
  • Get involved in reviewing/commenting on other
    permits not just your own.
  • Educate and inform the public on the status of
    your dealings with EPA. Explain the costs and
    benefits of the permit.
  • Learn from the environmental groups approach
    this is not a technical fight it is a political
    fight.
  • Contact your congressman
  • JOIN A COALITION!

20
What is My Message?
  • You as City and Town Officials are
  • Stewards of your communitys natural resources
  • Pragmatists and practitioners of common sense
  • Managers of complex infrastructure systems
  • Responsible for the prudent expenditure of the
    your towns money
  • Know the challenges and priorities of your
    community better than anyone else

21
Message (cont.)
  • EPA is not all knowing.nor do they walk with the
    angels as some might have you believe
  • They have a job to do and are narrowly focused on
    that job but they are not concerned with you or
    your problemsthey are looking out for
    themselves!
  • They are driven by environmental purists
  • The CWA was not intended to bankrupt cities/towns

22
Message (cont.)
  • You have an obligation to call attention to the
    issues
  • You must advocate that permits
  • Be based on good science
  • Consider cost/benefit
  • Consider communitys affordability
  • Be sustainable Meet the Triple Bottom Line
  • Stormwater Permits should be based on MEP

23
Message (cont)
  • Recognize that stormwater issues are largely
    linked to population density.it is a problem
    that has developed over 220 years during which
    time the country has grown to over 300 million
    peopleit wont be solved in one 5 year permit
    term
  • Perfection will take time to achieve.in the
    meantime accept continuous improvement

24
Message
  • The enemy of the good is the perfect
  • -Voltaire
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