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Posted 04/19/06

WQA opposes EPA’s new affordability assessment proposal

"It would render the original maximum contaminant levels (MCL) useless."

Lower-income areas, and those served by small water systems, could receive drinking water with chemicals at triple the current maximum contaminant levels (MCL), if a US Environmental Protection Agency proposal goes forward.

The Water Quality Association (WQA) strongly opposes the suggested revisions, stating it would create a dual standard and render the original maximum contaminant levels (MCL) useless. The association further blasts the proposal for what it calls “discriminatory health protection.”

WQA submitted comments to the Agency on April 19, and encourages WQA members to submit comments on how the proposed changes may affect their companies and water treatment services.

The EPA requests comment on proposed major revisions to their national affordability methodology for small drinking water systems, and whether an affordable variance technology protects public health. The proposal and request for comment was published in the March 2, 2006, Federal Register. Comments are due May 1, 2006.

Lowering the affordability threshold
Under the Safe Water Drinking Act (SDWA) as amended in 1996, states may grant variances to small drinking water systems for drinking water standards that the EPA determines are unaffordable. A small system variance enables a system to use treatment technology that achieves maximum removal of a contaminant that is both affordable and protective of public health, but does not remove the contaminant to the degree specified by the drinking water regulation.

Currently, the EPA determines affordability by comparing the current cost of water, plus the estimated cost of additional treatment for compliance with a new standard, to an affordability threshold of about $1,000 per household per year (calculated by taking 2.5 percent of the median household income among small systems).

Since the small system variance provisions were enacted in 1996, the EPA has found all new drinking water regulations to be affordable, and therefore, states have not had the right to grant variances. However, some stakeholders have argued that the current criteria are too stringent, and they fail to recognize situations in which small systems may deem a regulation unaffordable.

The proposal would lower the median household income (MHI) threshold — the maximum cost that is affordable to customers served by small systems — from 2.5 percent (approximately $1,000) to one of three alternatives for which EPA seeks comment:

  • 0.75 percent MHI (approximately $310-$330)
  • 0.50 percent MHI (approximately $200-$220)
  • 0.25 percent MHI (approximately $100 to $110)

Proposed variances would allow three times the MCL
The SDWA limits variance technologies to those that are determined to be protective of public health, however, the rule doesn’t specify how to make the determination. In the new proposal, the EPA requests comment on whether it should find variance technology sufficiently protective of public health “if the concentration of the target contaminant after treatment by the variance technology is no more than three times the MCL. The EPA would view this three times level as a general guideline which might be modified for a specific contaminant if unusual factors associated with the contaminant or the EPA’s risk assessment suggested that an alternate level, whether higher or lower, was appropriate.”

WQA says the revisions would “irreparably undercut the integrity of the MCLs”
The EPA cannot allow three times the maximum contaminant level a

   

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