Auto Recyclers Seek EPA Retraction of Stormwater Permit Guidance Memorandum

Action contradicts Obama administration executive order seeking more affordable, less intrusive means to achieve the same ends.

2011-05-19

MANASSAS, VA, May 19, 2011 (Press-News.org) Today, the Automotive Recyclers Association (ARA) urged the Environmental Protection Agency (EPA) to retract its November, 2010 Guidance Memorandum that encourages state permitting authorities to measure industrial stormwater discharges through numeric effluent limits rather than use the traditional and effective best management practices (BMP) approach. "This Memorandum goes well beyond simply updating a policy as EPA suggests," says ARA's CEO Michael E. Wilson. "Rather, it appears to represent a major shift in how best to measure stormwater discharges - a change that ARA believes to be wholly unnecessary and done in an inappropriate manner," Wilson adds.

ARA made this request in response to EPA's invitation to concerned stakeholders to comment on its Memorandum - an invitation tendered only after EPA received numerous objections from stakeholders that they had not been made aware of the change nor given any opportunity to comment before the Memorandum was finalized. In its communication to EPA, ARA voiced serious concerns about the procedural process surrounding the Guidance Memorandum as well as the potential negative impacts of the EPA's stormwater measurement recommendations on both the environment and the professional automotive recycling industry.

ARA believes that rulings of past court cases and the provisions of both the Small Business Regulatory Enforcement Fairness Act of 1996 and recent Presidential Executive Orders require that EPA follow the formal notice and comment rulemaking process for a change of this significance.

Even more importantly however, ARA asserted that if the appropriate rulemaking procedures had been followed initially then EPA would have heard real world examples of how the longstanding process of measuring stormwater discharges through best management practices and benchmarks is significantly more effective than the proposed system of numeric effluent limits. Further, as part of this process, EPA would have realized that the automotive recycling industry and others with stormwater discharges are committed to protecting our nation's waterways - but that in order to do so, they need a full panoply of tools available to manage levels of defined pollutants.

Since 1943, the Automotive Recyclers Association ("ARA") represents an industry dedicated to the efficient removal and reuse of "green" automotive parts, and the proper recycling of inoperable motor vehicles. ARA represents the interests of over 4,500 auto recycling facilities in the United States and fourteen other countries around the world. With programs such as the Certified Automotive Recycler Program (CAR) and other partnerships, ARA members continue to provide consumers with quality, low-cost alternatives for vehicle replacement parts, while preserving our environment for a "greener" tomorrow.

To learn more about the Association, visit ARA's Home Page at www.a-r-a.org or call (571) 208-0428.

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Auto Recyclers Seek EPA Retraction of Stormwater Permit Guidance Memorandum

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