The NRDC has petitioned the EPA to add nitrogen and phosphorous limits to the definition of "secondary treatment.  An analysis of their petition has been completed and a response for the IWPCA has been sent to the EPA.  Below are the three documents.

NRDC Petition  (.pdf, 1.83 MB)
IWPCA Response Letter (.pdf, 75 KB)
Evaluation of NRDC Petition (.pdf, 53 KB)

The Iowa Department of Natural Resources (www.iowadnr.gov) is developing new chloride water quality standards.

IWPCA Position Statement  (.pdf, 70.3 KB)

The IDNR has issued a summary of the current status of legislation of interest to the IDNR.  See the following link for a PDF.

The linked PDF outlines the proposed point system.  Based on the sum of the points for all the unit processes, the treatment plant would be rated Grade I to Grade IV.

EPA is currently drafting rules related to Clean Water Act §106 grant funding for National Pollutant Discharge Elimination System (NPDES) permitting programs. The rules will create an incentive program for states that have "adequate" NPDES fees, with adequate being defined as programs that are 100% supported by fees.  In Iowa, the NPDES permit program is supported 15% by permit fees, with the balance coming from general fund sources.

The Iowa DNR has issued a press release expressing their concern with the proposed rules.  You can view that press release by following this link.

View the "Legislative Update" presentation made at the Region II spring meeting in Mason City on April 13, 2006.  Topics discussed include Water Quality Standards, NPDES Fees, Total Dissolved Solids (TDS) and Chlorides, Bid Thresholds, Eminent Domain, Watershed Funding, and various other legislative and regulatory issues.

Legislative Update PowerPoint (.ppt, 233 KB)
Legislative Update PowerPoint (.pdf, 113 KB)

The Iowa Department of Natural Resources (www.iowadnr.gov) has proposed new water quality standards that "presumes" all streams in Iowa are "fishable/swimmable."  The Environmental Protection Commission approved new those water quality standards on January 17, 2006, despite the concerns raised by a number of groups about the appropriateness of the rules.  IWPCA is concerned that they will result in a severe economic impact to Iowa's wastewater rate payers, while resulting in minimal environmental improvements. 

A coalition of concerned groups has asked the state legislature to impose a delay in the implementation of the new rules, and has proposed legislation that would require a Use Attainability Analysis to confirm the appropriateness of any change in stream classification.  This new legislation would ensure that money is being spent in a cost-effective manner to improve Iowa's water quality.

IWPCA Position Statement  (.pdf, 1.53MB)

IWPCA Board offers additional "talking points" for members to communicate concerns with legislators and others on proposed changes to Iowa's water quality standards.  It is important to stress to legislators the enormous cost these standards changes will impose on cities and utilities, all for things that the IDNR readily admits will have virtually no impact on Iowa's water quality.

Talking Points Update (.pdf, 13 KB)
Background Info for Stakeholders (.pdf, 16 KB)
Sample Letter to Legislators (.pdf, 4 KB) 

This is the first of a series of periodic update memos regarding the proposed revisions to the Iowa Water Quality Standards. These memos will be as brief as possible and will include only the most important information for keeping members informed of the basic issues and calls for action.

IWPCA members are strongly encouraged to keep up-to-date on this very important issue.

September 9, 2005 WQS Update (.pdf, 34 KB)

Adam Schnieders
Iowa Department of Natural Resources
Wallace State Office Building
502 E. 9th St.
Des Moines, Iowa 50319
FAX 515-281-8895
E-mail adam.schnieders@dnr.state.ia.us

   
Water Quality Standards Update - May 27, 2005

   
*Legislative Action Alert from WEF*  (May 16, 2005)

WEF has confirmed that Congressman Bart Stupak (D-MI) intends to introduce an amendment prohibiting EPA from issuing guidance on blending when the FY06 Interior and Environment Appropriations Bill comes to the floor of the House next week.

Your immediate help is needed!

WEF is asking members to write each Member of Congress in your state delegation urging them to oppose Congressman Stupak’s amendment. Letters should be sent via fax as soon as possible. We expect the House will consider this Wednesday, May 18 or Thursday, May 19.

Please find a sample letter attached and an excel spreadsheet containing a list of Members of Congress with their contact information.

If you need more information, please contact Patricia Sinicropi, WEF Legislative Counsel at 703-684-2416.

Congressional Contacts (156 KB)
Sample Letter (30 KB)

IWPCA Letter to Rep. Leach (34 KB)
      Similar letters were sent to Rep. Latham, Rep. Nussle, Rep. Boswell, and Rep. King

WEBMASTER's Note:  IWPCA has been actively encouraging support for a national blending policy (see letter to Rep. Duncan, below).  Member action is needed to ensure that blending remains a viable option for wastewater facilities.

On April 14, 2005, the D.C. Circuit Court of Appeals upheld its December 2004 decision regarding EPA's adoption of its Clean Water Act ("CWA") Part 136 chronic Whole Effluent Toxicity ("WET") test methods (Edison Electric Institute, et al., v. EPA, et al., Case No. 96-1062).

Article by Hall & Associates (20 kb)

See also the IWPCA amicus brief on the WET Case below.

In a letter to U.S. Representative John J. Duncan (Committee on Transportation and Infrastructure), IWPCA President Carla Schumacher expressed the appreciation of the Association to the US  House's Subcommittee on Water Resources and Environment for holding hearings on wastewater blending under the Clean Water Act. 

"We commend you on your effort to review this important issue.  We would welcome your support of a final national U.S. Environmental Protection Agency policy on wastewater blending that both will allow us to continue to provide the maximum wastewater treatment at the local level and increase publicly available information on blending."

Full Letter to Rep. Duncan (247 kb)

In conjunction with the League of Kansas Municipalities and the Western Coalition of Arid States (WESTCAS), IWPCA has filed an amicus (Friend of the Court) brief in a court case regarding the whole effluent toxicity (WET) test methodology.  (Edison Electric Institute, et al. v. U.S. Environmental Protection Agency, et al., US Court of Appeals, D.C. Circuit, No. 96-1062)  The essence of the brief is that EPA and the courts have used improper mathematical calculations in evaluating the validity of the WET procedure.  The agencies are concerned with the degree of variability of the procedure, particularly the chronic sub-lethal method.  This variability could improperly result in erroneous permit violations and trigger expensive follow-up and remediation activities.

Petition for hearing (20 KB)
Motion to file amicus brief (40 KB)
AMICI CURIAE brief (71 KB)
Expert affidavit - E. Robert Baumann (30 KB)
Expert Affidavit - Herbert T. David (25 KB)
Expert affidavit - Robert F. Rockwell (26 KB)
Letter to US EPA from Iowa League of Cities (93 KB)

The Government Affairs committee has been working with John Hall, a Washington D.C. based attorney, to develop an approach to address three specific areas of Iowa water quality standards including: Anti-degradation, General Use Classification, and Protected Flow Provisions. Outlines of these approaches are included here. We welcome member questions and comments until 5 pm, January 6, 2005. Please contact Charlie Stevens by calling (641-828-0587) or e-mailing (cstevens_isu@yahoo.com) with your questions or comments. Following this comment period we will ask John Hall to further develop these issue papers for our distribution and use.

Anti-degradation Provisions  (16KB)
Protected Flow and General Use Provisions (21KB)

IWPCA has received notification that US EPA has approved IDNR's revisions to Iowa's Water Quality Standards (567 IAC Chapter 61) related to Total Dissolved Solids (TDS), although they had some issues on the implementation aspects.  The change allows the use of site-specific standards to ensure that NPDES discharges are not creating toxic conditions.  Copies of US EPA's letter to IDNR and of US EPA's Basis of Approval are available here.

At their special meeting on April 12th, the Environmental Protection Commission (EPC), in a 5-3 vote, adopted the Iowa Department of Natural Resources recommendation for Option B with the additional requirement that DNR develop recommended water quality standards for specific constituents (and Total Dissolved Solids, or TDS) by April 1, 2007.  Additional information is available here.

View IDNR's preliminary data from the field monitoring of CAFO ambient air emissions presented at the August 18, 2003 Environmental Protection Commission meeting.