ASDWA Submits Comments on Proposed Consumer Confidence Report Revisions

Last week, ASDWA submitted its comments on EPA’s proposed Consumer Confidence Report (CCR) revisions. Developed with the assistance of ASDWA’s primacy agency CCR Workgroup, some of the highlights from ASDWA’s comments include:

• Biannual delivery will be duplicative and needs clarity;
• EPA’s request for all compliance monitoring data (CMD) erodes state, territorial, and tribal Safe Drinking Water Act (SDWA) primacy authority, and the compilation and submission of data will be burdensome;
• Providing and validating translations will be costly for states, and guidance will be needed;
• The CCR summary is duplicative and adds to CCR length;
• The new definitions need to be reevaluated and corrosion control efforts need a detailed description;
• More information on “misleading statements” is required, and the examples used in the proposal should be reconsidered for the final rule; and
• The timeline of the proposed rule presents serious feasibility concerns and should be adjusted for more time to develop needed guidance and translation services.

Burden is a major theme in ASDWA’s comments, particularly when addressing the translation requirements for which primacy agencies would be responsible in the proposed revisions, and the submission and compilation of CMD, which ASDWA recommends should be delayed to better align with the new Safe Drinking Water Information System (SDWIS) known as Drinking Water State-Federal-Tribal Information Exchange System (DW-SFTIES). ASDWA’s full comments, along with its previous comments on the CCR, can be found here.