AMWA submitted comments to EPA on April 4 to provide recommendations for how the agency should conduct its regulatory review of drinking water regulations in response to President Obama’s Executive Order (EO) 13563, Improving Regulation and Regulatory Review. The comment letter is available on AMWA’s Regulatory Committee page under “Comments Recently Submitted.”
AMWA’s letter makes several recommendations to EPA for reviewing parts of the Ground Water Rule and LCR as well as a rule under the Clean Air Act addressing Reciprocating Internal Combustion Engines. The letter also urges the agency to maintain the current Water Transfers Rule.
The document also suggests that the agency:
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consider its Retrospective Review process in a broad, multidisciplinary way, to consider guidance and enforcement policy and also to consider the agency’s bigger environmental goals beyond the demarcation of program offices;
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work across federal agencies to consider whether any of the regulations (or lack of regulations) of other industries jeopardizes the ability of drinking water utilities to provide safe drinking water to customers in a reliable manner;
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develop a guideline or metric for what constitutes the requirement for a revised regulation under the SDWA to “maintain, or provide for greater, protection of the health of persons” (also known as the anti-backsliding provision); and
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perform a cost retrospective of EPA drinking water rules to compare estimated costs with actual rule implementation costs.