Board of Directors

PRESIDENT

Mayor Robert L. Bowser

East Orange, New Jersey

2 st VICE PRESIDENT

Mayor Hilliard L. Hampton, Jr.

Inkster, Michigan

3 ND VICE PRESIDENT

Mayor Ron Davis

Prichard, Alabama

TREASURER

Mayor Jamie Mayo

Monroe, Louisiana

ASSI STANT TREASURER

Mayor James L. Walls, Jr.

District Heights, Maryland

SECRETARY

Mayor Johnny L. DuPree, Ph.D

Hattiesburg, Mississippi

ASSISTANT SECRETARY

Mayor Mary Ajoku

Cruger, Mississippi

SERGEANT

- AT

- ARMS

Mayor John White

Ames, Texas

BLACK WOMEN MAYO RS CAUCUS

Mayor Velma H. Jenkins, Ph.D

Shuqualak, Mississippi

CHAPLAIN

Mayor James K.S. Knox

Northwest, North Carolina

PARLIAMENTARIAN

Mayor Otis T. Wallace

Florida City, Florida

Mayor Dave Bing

Detroit, Michigan

Mayor Antonio Blue

Dobbins Heights, Nor th Carolina

Mayor Michael Blunt

Chesilhurst, New Jersey

Mayor Irene H. Brodie, Ph.D

. Robbins, Illinois

Mayor Edward Brown

St. Joseph, Louisiana

Mayor Willie Burns

Washington, Georgia

Mayor Michael B. Coleman

Columbus, Ohio

Mayor Andre’ DeBerry

Holly Springs, Mississippi

Mayor Evelyn Winn

- Dixon

Riverdale, Georgia

Mayor Kevin Johnson

Sacramento, California

Mayor Dwight Jones

Richmond, Virginia

Mayor John Marks

Tallahassee, Florida

Mayor Michael Nutter

Philadelphia, Pennsylvania

Mayor Andre Pierre

North Miami, Florida

Mayor Kasim Reed

Atlanta, Georgia

Mayor Gary Richardson

Midfield, Alabama

Mayor Raymond Steele

Eutaw, Alabama

Mayor A.C. Wharton

Memphis, Tennessee

Mayor Frank A. Wilson

Bolton, North Carolina

Mayor Terry Wright

Brunson, South Carolina

Presidents Emeriti

Mayor Henry Espy

Clarksdale, Mississippi

Mayor Harvey Johnson, Jr.

Jackson, Mississippi

Heather M. Hudson

Greenville, Mississippi Executive Director

Vanessa R. Williams Pa st Presidents

Marion Barry

Unita Blackwell

Dr. Gordon D. Bush

Rev. Emanuel Cleaver, II

A.J. Cooper, Founder

Roosevelt Dorn

Johnny Ford, Founder

Richard G. Hatcher 

# July 20, 2011

U.S. Environmental Protection Agency

Water Docket

1200 Pennsylvania Ave., NW

Washington, DC 20460

ATTN: Docket ID No. EPA

- HQ

- OW

- 2008

- 0667

Dear Administrator Jackson:

On behalf of the National Conf erence of Black Mayors (NCBM) and the 40 million Americans NCBM’s members

represent we are writing to express our views on an imminent rulemaking by the U.S. Environmental Protection

Agency (EPA) regarding cooling water intake structures at existing elect ric generation and manufacturing facilities.

As you consider this rulemaking, we strongly encourage you to allow cooling water technology choices to be based

on site

- specific characteristics and cost

- benefit analyses, as is the agency’s current practice.

The current application by EPA of section 316(b) of the Clean Water Act

— applying best

- technology available on a

site

- by

- site basis

— remains the most scientifically valid and cost

- effective method of regulating water intake

structures. In 2009, the U.S. Supr eme Court affirmed that the law allows consideration of costs and benefits,

common in environmental regulation.

There has been expressed reservations that EPA may be considering a one

- size

- fits

- all technology approach that

would essentially mandate coolin g tower retrofits at existing facilities instead of basing technology decisions on site

specific characteristics and cost

- benefit considerations. We understand such an approach could be extremely

expensive and may not be feasible in all cases. Furthermore, such a national mandate would result in a variety of

adverse environmental and energy impacts, including, but not limited to, increased air emissions, particularly

greenhouse gas and particulate emissions; increased water use; and decreased electric capac ity in several regions

.

We believe this rulemaking should recognize and implement a proven, flexible approach as reflected in current law.

Allowing such flexibility within the states will help create new jobs, restore economic growth and lower the burd en of

government and taxes on our citi zens. These are actions that constituents across our nation clearly have set forth

as public policy priorities.

We thank you for your consideration of our views and stand ready to work with you and the agency to assu re the

best possible rulemaking on this issue.

With kindest regards,

Mayor Robert L. Bowser Vanessa Williams

President, NCB M Executive Director, NCBM

Headquarters • The 191 Building

191 Peachtree Street NE, Suite 84 9

Atlanta, Georgia 30303

404.765.6444 • Fax 404.765.6430 Past Presidents

Dr. Robert B. Ingram

Jesse M. Norwood

James Perkins, Jr.

John H. Smith

James L. Usry

Wellington E. Webb

George L. Grace