Proposed BMPs - Comments due April 15, 2011

[PWNA HQ 14]

To date, we haven’t received any suggestions for changes on the proposed BMPs. If you have posted your proposed changes or suggestions on a bulletin board thread, please email, mail, or fax those comments to PWNA Headquarters at:

info@pwna.org

1410 Energy Park Drive

Suite 6

Saint Paul, MN 55108

Fax: 651-699-6709

The deadline for any proposed changes or suggestions is April 15, 2011.

[tonyshelton 112]

There are only 4 more days before the deadline to get in suggestions regarding the PWNA's proposed BMP's. If you guys don't participate, you get what you deserve and have nobody to blame but yourselves.

I plan to send off my fax to the PWNA prior to the deadline. The purpose of this post was to get some ideas of what we, as an industry want. And participation was virtually non-existent.

I know I write long posts, and I've tried to narrow it down. Here is what I think we need as an industry from the PWNA.

1) Refrain from writing anything that can be construed as "guidelines" for municipalities.

2) Go ahead and "certify" your members if you want. I have "********** Certified" contractors. Just like there are "Maytag" certified repairmen and various other trade named certifications. Our certification means the contractor has been trained in our way of doing business. Just don't refer to BMP's or "CWA" or anything else that sounds official. You don't have enough members to withstand the furor that will happen if you do it.

3) LEARN the CWA and it's limitations if you are going to teach anybody about it. If you still think "nothing down the drain but rain" is what the CWA says, then you have no business teaching anything about it. Things are changing too. The EPA is short on money right now. North Dakota is drafting a law declaring the EPA has no jurisdiction in North Dakota. We must not move too fast on this. We may find that we played our hand too early. Manufacturers have been claiming that their equipment will be required in the next year and have been doing so for the past ten years. We need to take the offensive stance and see what is REALLY coming around the bend.

4) FIGHT for the contractors in LOCAL settings. Use any money you would have used to promote your "BMP's" to fly somebody to each location where a problem is rearing it's ugly head. Do it early, before the city councils have made up their minds.

5) FIGHT for the industry with a printed, youtube, facebook etc campaign that shows us as the SOLUTION instead of the problem. Stop acting like we are environmental criminals that need a leash to work.

Those are my suggestions for the proposed BMP's. Of course this is just my opinion and you are free to tell me to shove it. I just can't support any certification or BMP's that appear official and sit out like an apple on your website for local jurisdictions to pick. There's also no reason to give them ideas for reasons to put more restrictions on us than already exist on a federal level.

WE ARE THE SOLUTION.

That's your answer for this industry. Sing it, Play it, Show it, Whistle it, whatever you have to do, but get the word out. That would be a much better service to the industry than making BMP's that were initially made with fleet washing in mind accepted as the BEST practice in every jurisdiction and every type of cleaning.

These are my suggestions to the PWNA.

Anyone else?