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Brent Fewell [brent.fewell@earthandwatergroup.com] 8/28/2017 1:33:19 PM Forsgren, Lee [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=a055d7329d5b470fbaa9920celb68a7d-Forsgren, D]; Byron R. Brown Esq. (Byron_Brown@EPW.senate.gov) [Byron_Brown@EPW.senate.gov] Michael Deane (michael@nawc.com) [michael@nawc.com]; Penman, Crystal [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=93662678a6fd4d4695c3df22cd95935a-Penman, Crystal] Meeting Request EPA 1987 OW Memo re Privatization and CWA.pdf
Lee/Byron,
Would you two be willing to meet with me and Michael Deane of NAWC to discuss an important policy issue involving wastewater infrastructure, i.e., specifically the need to authorize private ownership of POTWs under the CWA. This has been a perennial issue that many have tried to ignore (or workaround), but it reared its ugly head recently when American Water acquired the Scranton wastewater system. http://www.philly.com/philly/business/energy/PUCapproves--195M-takeover-of--Scranton--sewer--system.html Attached is a 1987 office of water memo that describes the issue. Essentially, the CWA uses the term "publicly owned wastewater systems." As you can appreciate, this puts private owners of domestic wastewater treatment plants in a very difficult situation. And the regulators aren't always clear or consistent on how they handle. From a public policy standpoint, it makes no sense that on a Wednesday a system can be a POTW and then Thursday, just because the assets are transferred to a private entity, it ceases to be a POTW for regulatory purposes. In any event, knowing the history and politics of this issue it will also likely require the help of OGC and the Administrator's office, but wanted to see if we could schedule a meeting and you two can decide who would be appropriate.
The best dates for Michael and me are Sep. 14 (any time between 10 a.m. - 4 p.m.) and any time on Sep. 15. Look forward to hearing from you.
Brent
Brent Fewell, Esq. | Earth II W a te r G rou p
1455 Pennsylvania Ave., NW, Suite 400, Washington, DC 20004
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