ACWA’s Permitting & Compliance Committee focuses on all of the issues associated with National Pollutant Discharge Elimination System (NPDES) including effluent guidelines, permitting, compliance, enforcement, data management, and performance measures.
This committee has several sector based workgroups under it including:
- The Cooling Water Steam Electric Workgroup which serves as a forum for state-to-state and state-EPA discussion of the §316(b) cooling water intake and steam electric effluent limit guidelines.
- The Pretreatment Workgroup which focuses on the pretreatment program and issues associated with pretreatment effluent limitation guideline (ELG) development, implementation, and related policy.
- The Rural Workgroup which works on issues associated with animal agriculture management, pesticide permitting, and logging/forest roads.
- The Stormwater Workgroup’s focus areas includes construction and post construction stormwater programs, industrial stormwater, MS4 program updates, CSO/SSO, green infrastructure, blending, integrated planning, and other issues impacting municipal facilities.
Members of this Committee also represent ACWA and their state on a number of EPA workgroups associated with the State Review Framework, NPDES eReporting Rule Implementation, New Enforcement Framework, and several other initiatives under the Office of Compliance and Enforcement.
Summary of Meetings
2021 National Pretreatment Virtual Event
This year, from May 17-19, 2021, ACWA partnered with the National Association of Clean Water Agencies (NACWA) to bring states the latest developments and analysis of the national, state, and local issues affecting pretreatment programs from the perspective of both utilities and regulators. The 2021 National Pretreatment Virtual Event brought together 480 federal, state, and local permitting and pretreatment program staff to engage on the following hot topics:
- PFAS Developments
- Marijuana Industry and the Potential Impact on Pretreatment
- FOG: Strategies for Investigations and Lessons Learned
- CROMERR Compliance: Bringing Pretreatment into the Digital Age
- Breaking Down Barriers: EPA, States, and POTWs as Co-Regulators.
May 20-21, 2021 States and EPA held a private two day co-regulator meeting that included topics such as local limits development, combined waste streams formula, regulating/permitting CIUs, electronic data reporting, the permit writers clearinghouse, and a special session on audits and inspections during COVID. A copy of the presentations and final agenda can be found here.
2020 National CAFO Roundtable
On October 21, 2020 ACWA participated 2020 Fall Animal Agriculture Discussion Group virtual meeting. As part of the meeting ACWA reported out on the 2020 National CAFO Roundtable and discussed potential projects that states might be interested in working with industry groups. The list included example projects including developing marketing tools that dispel negative connotations of a site visit, identify “results focused” metrics for the CAFO programs, identify CAFO facilities nationwide, work with EPA to resolve access issues, identify common problems that lead to a discharge, what does sound agronomic and conservation practices look like, etc. And other excellent topics. A copy of the presentations and final agenda can be found here.
2020 National Stormwater Roundtable
February 4-6, 2020 ACWA staff facilitated the 2020 National Stormwater Roundtable, held in San Antonio, Texas. In total, 88 individuals participated at this meeting with representatives from 33 states, 7 EPA regions, ACWA staff, and EPA Headquarters. We also had 57 people participate in this meeting remotely. Topics for this meeting included: An Overview of the Texas Program; the San Antonio Stormwater Program; Stormwater Testing and Evaluation for Products and Practices; Training, Outreach, and Tools for the Public and Private Sector; Long Term Stormwater Planning; Construction Permits for Small Sites; Implementation of the Small MS4 Remand Rule; TMDLs and General Permits; Integrating Municipal, Industrial, and Construction Stormwater Programs; Concerns Regarding WOTUS Impacts; Tier 2 Waters Analysis for Construction; Pollutant Specific Challenges associated with Chloride, Human Bacteria, Nutrients, and Trash; Updates to the Industrial Stormwater Program; Stormwater Permits for Solar Farms; Monitoring and/or Modelling Requirements in Stormwater Programs; and Municipal Coalition Building in Massachusetts. A copy of the presentations and final agenda can be found here.
2019 National NPDES Permit Writers Workshop
This quarter ACWA hosted the 2019 National NPDES Permit Writers Workshop in Washington, DC, September 17 – 19, 2019. In total, 125 people participated at this meeting with representatives from 41 states, 7 EPA regions, ACWA staff and EPA Headquarters. We also had 100+ people participate in this meeting remotely. Topics for this meeting included permit writer resources and a clearinghouse, updated federal application forms, integrated planning, fact sheets, CSOs, peak flow management, several 316(b) cooling water intake structure topics, collection systems, performance based limits for nutrients, ammonia criteria, design flow, PFAS/PFOS, Antibacksliding, permit streamlining, NPDES eReporting Rule, permit streamlining, and program performance measures. A copy of the presentations and final agenda can be found here.
2018 National CAFO Roundtable
The week ACWA staff, states, EPA HQ, Regions, and USDA participated in a 2 ½ day meeting to discuss animal agriculture issues. As part of this meeting, participants visited two dairies and the Dixie Drain, which is agriculture return phosphorus removal plant intended to help offset Boise’s POTW permit requirements. Topics discussed at the meeting included an overview of the Idaho programs, the pros and cons of using a two permit system, common ownership challenges, making NMPs simpler and easier to implement, the value of microbial source tracking, recent trends in the animal agriculture world including litigation issues, federal updates from EPA and USDA, program challenges in IA and VA, eReporting Implementation, and electronic tools designed to help the programs be more efficient. This year’s CAFO Roundtable had 68 participants representing 31 states, 6 EPA Regions, EPA HQ, local/regional NRCS, and USDA HQ. Presentations and a copy of the presentations and final agenda can be found here.
2018 National Stormwater Roundtable
This week, 100 representatives from 34 states and interstates, along with representatives from EPA Headquarters and Regions, met in Atlanta, Georgia for a 3 ½ day stormwater meeting to discuss a number of challenging topics including writing permits that meet the small MS4 remand rule, meeting TMDL and other water quality based stormwater requirements in permits, defining Maximum Extent Practicable, developing “clear, specific, & measurable” requirements, using electronic permitting systems, increasing the value of oversight inspections, taking enforcement actions and assessing penalties, targeting sites for inspection, erosion and sediment control measures, the MSGP settlement and implication for states, residual designation authority, long term stormwater planning, unpermitted industries and no exposure certification, transportation and stormwater, illicit discharge detection and elimination, efficient and effective oversight of MS4 programs, post construction trends and findings, different approaches to ensuring BMP verification and effectiveness, tools and technology that can help permittees, and factors to consider when permitting unique facilities. Presentations and a copy of the presentations and final agenda can be found here.
2017 National NPDES Program Managers Meeting
From October 31, 2017 to November 2, 2017 states and EPA participated in the 2017 National NPDES Program Managers Meeting in Silver Spring, Maryland. This meeting was supported by an EPA cooperative agreement and was focused on helping assist states and EPA in further identify challenges & barriers to NPDES program implementation, highlighted opportunities for permitting authority program improvement & enhancement, showcased innovations, assisted with analysis of training, guidance, tools, and other support material needs, offered insights into improving administrative efficiencies, clarified roles and responsibilities, promoted program streamlining, provided suggestions for building stronger linkages to WQS & TMDLs, recommended modernizing some permit terms and data management, identified program areas where targeted technical assistance might be most beneficial, and laid a foundation for further discussion in solving some of the most intractable NPDES program issues. A copy of the final agenda can be found here. A copy of the presentations and final agenda can be found here.