Region 7 Public Listening Session Comments, Recommendations

Springfield, Missouri, March 15, 2011

Larry Martin, Stormwater and the MS4 permitting process (40 CFR 122.34). I would like to 

see EPA working more closely with DNR; that the counties and municipalities be considered 

more a partner in that process than somebody who is treated more as an adversary from an 

enforcement standpoint. But treating them as a partner rather than trying to have them enforce 

regulations that start with federal origin, and then through the state, and just giving those to 

municipalities and counties to enforce on their behalf, more consideration needs to be given to 

that process and those like it.

Allow regional organizations, water districts and municipalities that supply water to have more 

input into regulations, local input from the communities themselves that bought into the idea, not 

as an opposition, but agreed to it. The same kind of thing could be applied to drinking water. 

When something like that comes along, let us address it or have input locally, because we're 

talking hundreds and hundreds of thousands of dollars for the difference in monitoring each one 

of these additional things on a region-wide basis.

And, the TAP program, the Technical Assistance Program, that was in place, which was a 

valuable tool for water, sewer districts, municipalities, counties anyone in particularly water and 

wastewater, also air quality and landfills dealing with technical issues. It was a great way to get 

involved, to get technical assistance and expertise from your regulatory agency without putting 

yourself immediately in an adversarial or enforcement role against you. You could openly take 

problems and concerns and discuss them. Then it was discontinued. 

Joe Pitts. 319 grant funding. I have a three-person group, three full-time people, and we're held 

to the same accounting standards that a major university might be held to. And quite frankly, we 

have to assess whether to even apply for those grants because of the amount of time it takes to do 

that reporting, accounting and programmatic license.

Steve Meyer, City of Springfield. Blending, when system can’t quite handle diluted wastewater 

and you bypass, if you bypass it, the biological part of it. But if we can take our fully-treated 

wastewater and blend it with partially-treated wastewater and still meet limits, we're thinking 

that that ought to have some consideration. I think the analogy I hear all the time is: "What we 

do inside our fence, as long as we protect our property, that's our business. But once it hits that 

pipe, it's your business." And that's when we think that the blending, if we can meet our limits, 

should be considered as -- only in periods of extreme wet weather.

Hydrate treatment. If we can, again, through chemical processes, meet our limits with a 

chemical hydrate treatment, then we would like to see that taken into consideration as acceptable 

treatment because it does meet the limits. 

The push we're making to eliminate SSOs is great. But we want to do it so it is economical and 

done effectively. Consent decrees have been project-based and, generally speaking, over long 

period of time. I think a better approach to eliminating SSOs is to be more progress-based, a 
grade card. Did you eliminate I&I, so much out of these pipes, and you continue to show 

progress? Do it in a phased approach, a multi-facet plan so that we can do the work, see what 

worked, see what didn't work, and obviously do more of what worked and less of what didn't 

work. Many decades with our aging infrastructure, some of our pipes are a hundred years old. 

So it's going to take decades to fix it. 

Stacy Doing. EPA will always have an enforcement arm. We need that. However, I'd like to 

see that changed to one of education and helping not only to states and the communities, but also 

industry. Industry intends to do the right thing, but we need help just like the communities need 

help. And we need, rather than having somebody come in from an enforcement agency to do an 

inspection, to say, "You're doing these five things wrong, and here's a fine," we need to start 

changing the way that we look at environmental protection in this country. 

Timothy Davis. We work very closely with our MS4 program (40 CFR 122.34), and part of that 

is the TMDLs that we are required to follow. And one of the things that really is of concern to us 

is that when those TMDLs were being written, EPA didn't really solicit input from the local 

entities, local governments that were in charge of implementing them. We had reams and reams 

of data that was largely ignored because the EPA didn't take that cooperative approach in asking 

us what was going on with the water quality. So consequently, we get that kind of ``one-sizefits-all’’ approach. 

Vern Morgan. On Brownfields Program, the one thing I would ask that maybe you could think 

about changing is when we're provided funding, it's separated out from petroleum and other 

contamination. It gets pretty unwieldy, because usually we’re dealing with both, and what could 

happen is all of a sudden we use up all of our petroleum money, and we've got tons of regular 

contaminant money and we can't use it because it's not the right kind of money. It would just 

make sense if you could figure out how, just make it an assessment program or a cleanup 

program for whatever contamination happens to be, rather than trying to split it out. And one 

more regulation, it's an overall federal regulation, the Davis-Bacon Act. It's just really hard for 

us to work with in this part of the country. The wages that are paid are way above what are 

generally paid in many of the areas we work in, and cleanup is one of them. If you can make it 

prevailing for the actual area that you're working in, it would help. 

Randy Lyman, City of Springfield. The Leaking Underground Storage Tank program, and the 

UST program under that storage tank program, that's just really been a success. Now we can use 

the same man-hours, FTEs, to work on our Fats, Oils and Grease program, our Pretreatment 

Program, and other things, and we're not running out there all over the place chasing gasoline 

vapors. I wanted to give a plus side of what regulations can do.