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Let us help you and your group to understand the upcoming changes in Missouri water quality standards; changes that will impact almost everyone in the state within the next few months.
Don\'t worry, this isn\'t a sales presentation (we don\'t enjoy that kind of thing any more than you do). But we are local water and wastewater experts who can share our insider perspective and offer insights on this important issue. We appreciate the opportunity to interact with community leaders throughout the state. In fact, most of the 30-minute program is written out in text form below so you can see what you\'ll be learning in advance.
For more information about the Alliance difference, check out our June 18, 2005 Columbia Daily Tribune Saturday Business feature at http://archive.columbiatribune.com/2005/jun/20050618busi002.asp.
To inquire about available program dates, contact Veronica Salmons at email@example.com or call 573.874.8080 x242.
Read on for a program preview:
At Alliance, we\'re responsible for the operations and maintenance of water and wastewater systems throughout Missouri and in Iowa. You can imagine how important it is that we keep on top of industry regulations. We belong to every important water industry organization and pay special attention to legislation that can affect our clients. Most of the time this kind of news is only interesting if you work in a treatment plant all dayâ€”but this is a big one.
Big changes are coming for Missouri water quality standards. I\'ll tell you what I knowâ€”what\'s happening, why these changes, exactly who will be effected and what we think will happen next.
So what\'s going on here? In short, the Environmental Protection Agency is requiring the state of Missouri to make changes to our water quality standards. This last December (Dec. 27, 2004), EPA signed a settlement agreement with an environmental group called the Missouri Coalition for the Environment. Terms of the agreement state that EPA must compel our state to make changes in its water quality standards, which in turn effects effluent regulations. Effluent is treated water that leaves a wastewater plant and enters a waterway.
Right now, Missouri Department of Natural Resources has proposed its own changes to those rules in order to keep the EPA from enforcing its own federal version of the State regulations. These new rules are then scheduled to be finalized this December. If you back that up and allow time for paperwork and red tape, we are talking a matter of weeks or months. The comment period we are in now is critical because interested parties can make comments on DNR\'s proposal and have a real impact on what the final rules will look like. (What is happening immediately at the time of presentation).
Why New Rules?
I\'ll give you some background: back in 1994 and 1996, the State submitted water quality standards to EPA. Now skip forward to September 2000â€”EPA sends a letter back to the State about those standards. The letter states official notice of disapproval on some parts of the water quality standard, and requested that the EPA administrator for the region check in to the situation and make a recommendation.
Skip forward again, to 2003â€”The Missouri Coalition for the Environment sued the EPA. The Coalition is an environmental group based out of St. Louis. Their position is that EPA neglected its duties by not following up on the Missouri standards. The EPA\'s settlement with this group mandates this follow-up.
DNR Proposed Standards
Since the ruling in December, the state has developed and proposed amendments to the water quality standards and effluent regulations, and has published each of them, according to Missouri state law in a â€œRIR,â€ or Regulatory Impact Report. These reports are reviewed and debated by stakeholders such as ourselves at Alliance, the organizations you see here (Respondents to DNR Proposed Regulations RIR).
The Issues: Official Classifications and Designations
The major issue boils down to official water classification and water usage definitions. There are countless numbers of lakes, streams and waterways in Missouri. Each one can qualify for a unique classification and a designated usage. These two components then determine how the water is managed and regulated by the state. (review classifications and uses)
The Issues: Federal Clean Water Act Section 101(a)(2)
The goal of the federal Clean Water Act is commonly referred to as the â€œfishable/swimmableâ€ goal. This means that out of that list of 12 water use classifications, â€œwhole body contact recreation,â€ or â€œWBCR,â€ is the goal. (WBCR definition). This sounds fine, but how does the State know which waters should meet this goal? The answer is; they really don\'t.
The Issues: So Much Water, So Little Time (and Money!)
Only a very small percentage of Missouri waters have been studied scientifically and an even smaller number are classified as WBCR. But in order to comply with EPA standards, all waters have to be classified by the deadline and the State simply does not have the resources to do this. Instead, the State has decided that all 3,774 waterways will automatically be upgraded to WBCR status without study. (Table 2 wqs RIR)
The Issues: Just How Big Is This?
To give you another idea of how big this is, here are the actual lists from Missouri DNRâ€”lakes and streams (tables G and H) that will now carry this sweeping designation. All of these waters will immediately be subject to strict WBCR regulations, which means that every single home, farm, business, industrial park, subdivision and wastewater system that ultimately discharges to these waters will also be affected. In fact, the State estimates the economic impact will be greater than $300 million dollars and many experts believe the actual cost will be as high as $1 billion.
Effects and Impacts: Why More Regulations?
A lot of factors determine the quality of a body of water. Natural process such as mineral erosion from rocks and soil and animal waste all make a difference. On the human side, we have boating emissions and sometimes dump beer or trash (or contribute our own natural waste) into the water. Ironically, wastewater effluent is usually cleaner than the water it enters, but it\'s the only substance that can really be pinpointed and regulated.
Effects and Impacts: Who will be effected?
Missouri put together a list of those they know will be effected (appendix G, list of 911 facilities). Some are traditional municipalities, and some are owned by private citizens or small business owners. Districts and small businesses that use lagoons to treat their wastewater will be the biggest group affected because lagoons will probably need to upgrade in order to meet the new water quality standards. Upgrades could range from adding extra treatment steps or to building a whole new facility. Either way, these changes are likely to be financed by the citizens.
Effects and Impacts: When will this happen?
Permits to operate a wastewater treatment facility are renewed every five years, and all new permits will be issued with WBCR restrictions. Permit holders will then have three years to fully comply with regulations. The only way out of the expense of changing to meet these requirements is to conduct a Use Attainability Analysis, or UAA.
Effects and Impacts: Options
This is the analysis that the State would have had to provide for each waterway in the first place in order to not enact the blanket WBCR rules, but instead the burden is on the user. The UAA should be completed prior to when the new rules take effect, which means right now.
And performing a UAA is very likely to confirm that the water should in fact be designated WBCR. Good news for swimmers, but now the entity must go back to the drawing board and design a new system and submit it to DNR for approval. Most new systems will be designed with modern UV light or membrane technology that is proven to work without some of the adverse effects of traditional chlorine treatment, but these technologies are significantly more expensive.
Final Notes: Long and short term effects
We all want our lakes and streams to be as clear as practical. Whatever technology is used, the new regulations could prove to be a positive for the State and all of us as citizens in the long run. But for the short term there will be chaos. The Regulatory Impact Report for Water Quality Standards published by Missouri DNR even states: (wqs RIR, p.8) This is going to cost a lot of money and it\'s going to happen fast, and your local district/city will be directly impacted.
Final Notes: Resources
There are other regulation issues that will fall under the new standards that we didn\'t have time to talk about today; disinfection, ammonia levels and metals to name a few. If your head is reeling, I do a have a few suggestions for what you might do next: you can become informed, you can talk to DNR, and you can talk to your state representative. There\'s a lot of information out there for you. Here\'s a sheet to help you get started if you would like to learn more or make a contact. (Handouts with resource notes)