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 somebod y 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 any one in particularl y wat er 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 y our regulatory agency without putting yo urself immediatel y 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 maj or university might be held to. And quite frankl y, we have to assess whether to even appl y for those grants because of the amount of time it takes to do that reporting, accounting and programmatic license. Steve Meyer , Cit y of Springfield. Blending, whe n sy stem can’t quite handle diluted wastewater and y ou by

pass, if y ou by

pass it, the biological part of it. But if we can take our full y - 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 Ihear 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. Hy drate treatment. If we can, again, through chemical processes, meet our limits with a chemical h ydrate treatment, then we would like to see that taken into c onsideration 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 effectivel y. Consent decrees have been project

- based and, generall y s peaking, ove r long period of time. I think a better approach to eliminating SSOs is to be more progress

- based, agrade 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. Man y 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 alway s 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 somebod y 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 closel y with our MS4 program (40 CFR 122.34), and part of that is the TMDL s that we are required to follow. And one of the things that really is of concern to us is that when thos e 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 largel y i gnored 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

- size

fits

- all’’ approach. Vern Morgan. On Brownfields Program, the one thing I would ask that may be y ou could think about changing is when we're provided funding, it's separated out from petroleum and other contamination. It gets pretty unwield y, 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 generall y paid in man y of the areas we work in, and cleanup is one of them. I f 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 reall y 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.