ASDWA Submits Comments on National Compliance Initiative to EPA

Last week, ASDWA submitted comments on EPA’s recommendations for its National Compliance Initiatives (NCIs) for 2020-2023. As previously reported, ASDWA has been working with EPA’s Office of Enforcement and Compliance Assistance (OECA) throughout the process of developing the NCIs. This set of comments responds to the NCI to increase compliance with drinking water standards.

EPA feels that current approaches and tools have not always been effective in achieving compliance and they want to work with states to improve compliance and provide better public health protection.  This initiative would also support the goal in EPA’s Strategic Plan to reduce the number of community water systems out of compliance with health-based violations by 25% by 2022. ASDWA’s comments encourage EPA to ensure the NCI:

• does not trigger additional reporting requirements from state programs
• includes an action plan for identified problem areas and clear expectations for state actions for any tools that are developed as a part of this effort
• is deployed with states that volunteer to partner with OECA on these efforts

ASDWA’s comments also encourage OECA to:

• Work together with the Office of Water and the strategic breakthrough measure;
• Share and learn from states’ existing tools;
• Recognize states resource needs in this conversation;
• Focus on targeting the largest populations;
• Acknowledge data discrepancies; and
• Explore approaches to returning community water systems to compliance and preventing non-compliance.

ASDWA staff will continue to coordinate with EPA throughout the NCI process, including conversations between states and EPA at the upcoming ASDWA Member Meeting in Alexandria, VA.