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A Call to Action for All NPDES Permittees March 21, 1998 Dear Superintendent: I am writing this letter to request your support for a potential challenge of the Connecticut State Discharge @ Regulations. The Connecticut Water Pollution Abatement Association (CWPAA) has established an NPDES subcommittee. This subcommittee has determined that the regulations are truly the concern of both municipal and industrial facilities. With a combined organization, much more can be accomplished to establish a rational implementation procedure for water quality based effluent limitations. Some of the measures to be challenged or negotiated with DEP officials include:
Connecticut was one of the first states nationwide to implement whole effluent toxicity tests and followed on, in 1992 with the adoption of stringent water quality criteria. Since that time, the state has been slow to allow or encourage permittees to pursue modifications to instream criteria or propose testing which would argue against the independent applicability of water quality based toxics limits. For purposes of showing strength, we propose to have an organizational meeting for Connecticut NPDES permittees. The goal of this meeting is to establish an agenda for potential challenge of the discharge regulations in the State of Connecticut. The CWPAA has previously engaged Attorney John Hall of Washington, D.C. One item of discussion is further employment of Mr. Hall to achieve our ends or a pursuit of more technical means of regulation modification. We set a meeting for 9:30 a.m. to 11:30 a.m. on April 15, 1998 in Cheney Hall, Manchester, Connecticut. There will be an afternoon session to discuss permit issues in detail. We have invited municipal officials from your town to attend as well. We urge you to encourage them to attend to develop a better understanding of these important issues. Please respond by April 11, 1998 to Bob Dusza (860-647-3219) if you can attend and an agenda and directions will be e-mailed or faxed to your attention immediately. We sincerely look forward to seeing you there for this first organizational meeting. Sincerely, Bob Dusza |
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