KAM submits comments on water quality standards

On May 31, 2006 KAM submitted comments on revisions to the Ohio River water quality standards that were proposed by the

Ohio River Valley Water Sanitation Commission (ORSANCO). Key topics addressed in the comments follow:

Kentucky Association of Manufacturers has adopted the following regarding environmental policies: (a) they should consider cost-benefit relationships; (b) they should consider technical and economic feasibility; and (c) they must be based on sound science.

Many of our members operate businesses and manufacturing facilities in communities along the Ohio River. As such, KAM has an interest in ensuring that water quality is safeguarded and protected in the Ohio River, but that communities do not face unnecessary or excessive costs for dealing with wet weather issues associated with stormwater and sanitary wastewater treatment and disposal.

The wet weather standards proposed by ORSANCO, consistent with the Clean Water Act and EPA’s CSO control policy, establish a more realistic goal for the CSO communities. The Commission is to be commended for including specific recognition of the Clean Water Act, and U.S. EPA’s CSO Control Policy. The end result will be more cost-effective spending by municipalities, and lower fees on homeowners and businesses, by affording a more holistic approach to wet weather program spending to ensure that projects that are implemented provide the most improvement and environmental benefit for the monies expended.

The Association does not agree with the proposed revision to the standards to specify that the 1-day, 10-year low flow (1Q10) be used for developing water quality-based effluent limits for protection of acute aquatic life criteria. The use of seven-day, 10-year low flow (7Q10) values to establish low flow has been used historically and is sufficiently protective. An adjustment of the basis for the standards has not been justified as being environmentally necessary or appropriate.