has been done on developing new rate structures and practices; however, their implementations have been slow.
nity to legal action and/or fines should they fail to meet any environmental permit.
How can you advocate for appropriate water, sewer, and stormwater rates?
Anti Backsliding – Section 402(o) of the Clean Water Act prohibits backsliding. This means that established discharge limitations for wastewater cannot be reduced once established. This limits any flexibility for the permit regarding the length of time for meeting the permit requirements.
This is a challenging question to answer. EPA has developed a framework for Integrated Permitting. Integrated Permitting is a process where a community’s environmental permits are prioritized and brought together under one permit presumably structured to be affordable.
Challenges to developing a successful Integrated Permitting: Permitting Silos – While under the purview of EPA, permits are still issued from subsets of EPA silos. Many communities have a drinking water permit, a wastewater permit, a stormwater permit (MS4), sanitary sewer overflow permit, and a combined sewer overflow permit. Each of these permits is issued by individual divisions of the EPA. There are no provisions within the Clean Water Act mandating collaboration occur amongst the divisions. Consent Decrees – Communities which have consent decrees for issues such as Combined Sewer Overflows (CSO) would then be developing a plan which would also be bound under the consent decree. This would subject the commu-
The Clean Water Act has allowed us to make incredible progress as it relates to water and the environment. During the seventies and eighties, federal funding was abundant for the upgrades to our infrastructure and improving water quality. These burdens now lie primarily on the shoulders of the taxpayers and ratepayers. Clean water has always been viewed as a right, and is becoming increasingly a question of affordability. After 35 years since the Clean Water Act was enacted, we should be revisiting the Act to ensure that water remains clean, available, and affordable for generations to come. Please be involved and advocate. Get engaged with APWA Advocacy at http://www3.apwa. net/be_involved/APWA-Advocates. Eric Labelle can be reached at (207) 985-4811 or elabelle@ kennebunkmaine.us.
March 5- 7, 2018 | Denver, CO SWANApalooza.org
February 2018 issue of the APWA Reporter, the official magazine of the American Public Works Association