Reporting Requirements under EPA's Safer Detergent Stewardship Initiative (SDSI) Program; Agency Information Collection Request (ICR) Activities

EXECUTIVE COMMITTEE PRESIDENT Christopher M. Westhoff Assistant City Attorney Public Works General Counsel City of Los Angeles Los Angeles, CA VICE PRESIDENT Marian Orfeo Director of Planning & Coordination Massachusetts Water Resources Authority Boston, MA TREASURER Kevin L. Shafer Executive Director Milwaukee Metropolitan Sewerage District Milwaukee, WI SECRETARY Jeff Theerman Executive Director Metropolitan St. Louis Sewer District Saint Louis, MO PAST PRESIDENT Dick Champion, Jr. Director Independence Water Pollution Control Department Independence, MO EXECUTIVE DIRECTOR Ken Kirk December 13 , 2007 Attn: Docket ID EPA - HQ - OPPT - 2007 - 0274 Office of Pollution Prevention and Toxics Document Control Office (7407T) Environmental Protection Agency 1200 Pennsylvania Ave., NW Washington, DC 20460 - 0001 Submitted via electronic mail : oppt.n cic@epa.gov Dear Sir or Madam : T he se comments are submitted on behalf of the National Association of Clean Water Agencies (NACWA) in support of the Information Collection Request (ICR) for the Safer Detergent Stewardship Initiative that the Environmental Protection Agency (EPA) has forwarded to the Office of Management and Budget. NACWA represents the interests of nearly 300 publicly owned wastewater treatment works (POTWs) nationwide. NACWA’s members serve the majority of the sewered population in the United Sates, and collectively treat and reclaim more than 18 billion gallons of wastewater each day. As stewards of the water environment, NACWA’s members support efforts to reduce pollution at its source, preventing the discharge of pollutants into th e wastewater system. Sustainable environmental protection cannot be achieved solely through end - of - pipe wastewater treatment . T he increasing number of chemicals used in commercial and consumer products and the technical challenges associated with removin g these chemicals from wastewater make source control the best option . Programs like t he Safer Detergent Stewardship Initiat ive that seek to decreas e the amount of potentially harmful chemicals from entering the sewer system and encourag e businesses and o ther entities to transition to alternative ingredients and products are critical to addressing the environmental impacts from the diverse range of substances in commercial and consumer products . NACWA therefore supports the ICR submitted by EPA for the Sa fer Detergent Stewardship Initiative. If you have any questions, please contact me at 202/296 - 9836 or cfinley@nacwa.org . Sincerely, Cynthia A. Finley Director , Regulatory Affairs