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Know the Facts About HB2506.pdf

The West Virginia Manufacturers Association and its members have an interest in promoting fair standards and good science in regulating the discharge of wastewater.  Both are under attack by the opponents of HB 2506, a bill that would regulate mixing zones for NPDES (wastewater permit). Let’s look at the facts.

All of us -  citizens as well as manufacturers – contribute to pollution.  Water quality standards are the safe levels of pollutants that are allowed in our streams.  EPA determines those safe levels after making conservative assumptions about the effect of each chemical.  For drinking water protection, they generally assume that someone will drink the water (about a half gallon per day) for 70 years. The standards are set so that such exposures are not harmful over long exposure periods. 

The US EPA has determined that the proper way to set wastewater permit limits for most drinking water criteria is to assume an average flow in the river, rather than assume the river is in a state of drought for 70 years. The average that EPA recommends is harmonic mean flow, a long-term average for those chemicals where standards were set using long term exposures.  That is what good science tells us we should do – match the safe levels with the correct flow.

And that is what HB 2506 does.  It would implement the US EPA guidance for setting permit limits for drinking water, in a way that is recommended by the Obama EPA.  It’s hard to get a better recommendation than that.

It is also instructive what HB 2506 will not do.  It changes nothing with regard to protection of fish, or the people who swim, raft and fish in our state streams.  It does not change the rule that the safe levels for protection of drinking water must be met not just at the intake, but a full half mile upstream. 

Are there ways we as a state could improve water quality?  Of course, and the greatest problem we could address is human and animal waste. There is a list of streams called the 303(d) list, which identifies the streams that are impaired, that are not achieving the state’s standards.  Thousands of miles of streams are polluted by sewage.  I’m proud to observe that the list does not contain, as far as we can see, any streams that are impaired because of the current discharges from WVMA members.  I’m also proud of the fact that, despite a hundred years of industrial development along the Kanawha River, the year-long sampling that was done at the request of West Virginia American Water showed no impairment from our industry. Where there were problems, it tended to be sewage.

The West Virginia Manufacturers Association urges collaboration between the WVMA, the Rivers Coalition and others on the real issue that could interfere with our citizens and the state’s tourist industry – raw sewage in our streams and rivers.  That is what makes fish less safe to eat, or could discourage rafting or swimming in our streams. We hope they’ll agree to work with us on a way to move the state forward, relying on science rather than rhetoric.

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