THE POWER OF A SINGLE VOICE—THE SUCCESS OF THE BAY AREA AIR TOXICS GROUP

The number of air quality regulations and requirements facing Publicly Owned Treatment Works (POTWs) is continually escalating, making it important to track regulatory developments and maintain relationships with local regulators. This effort results in implementable regulations and proactive awareness of new regulatory requirements that could impact operations and the plants' abilities to remain in compliance with laws and regulations. The Bay Area Air Toxics, or BAAT Group is a coalition of POTWs in the San Francisco Bay Area that works cooperatively to address regulatory issues related to air quality. This group has been extremely successful in its efforts to lobby local regulatory agencies from a POTW perspective, keep member agencies up to date on regulations that affect them, and function overall as a compliance tool for POTWs.This paper will give a step-by-step guide to working cooperatively with neighboring POTWs and creating a collaborative organization to address air quality issues. It will describe the formation of the BAAT Group and trace the fourteen-year evolution to its current status and structure, including highlights of regulatory successes and the driving factors that made those efforts successful. It will outline the benefits of POTW participation in such a group, as well as noting some lessons learned from the BAAT Group's experience.The BAAT Group was formed in 1988 in response to a California law requiring each facility to submit an inventory of toxic air emissions. At that time, forty-four Bay Area POTWs came together to create and compile emissions estimation protocols, toxic emissions inventories, and risk assessment approaches, and to ensure that a consistent deliverable would be submitted to the Bay Area Air Quality Management District (BAAQMD) and the California Air Resources Board.Since 1988, the scope of the BAAT Group has expanded to address all relevant air quality regulations. Quarterly meetings and newsletters keep members up to date on regulatory issues the Group is tracking. As issues come up, the Group creates special programs to meet members' needs. Examples of these programs include developing a guidance document on implementing Risk Management Plans, negotiating favorable conditions for internal combustion engine regulations, creating a template for Title V permit applications, and developing the Bay Area Sewage Toxics Emissions (BASTE) Model, a nationally recognized model for estimating treatment plant air emissions.Members meet regularly with the staff of the local air district and the California Air Resources Board, and combine efforts where possible with professional groups dealing with common issues, including the Southern California Alliance of POTWs, the California Association of Sanitation Agencies, the American Metropolitan Sewerage Association, Tri-TAC, and others.This collaboration allows POTWs to speak through one voice on important regulatory issues, giving increased power and greater consistency in the messages delivered to regulators. The cooperative efforts of the BAAT Group greatly reduce cost and effort expended by individual agencies, give a voice to small facilities, allow compliance specialists to share ideas and experiences, and provide POTWs with on-call consulting on air quality issues. This model for collaboration can be duplicated in other areas for similar success in the air quality regulatory arena.