The Association of Metropolitan Water Agencies (AMWA) supports the U.S. Environmental Protection Agency (EPA)’s continuing emphasis on establishing environmental priorities based on sound science. Environmental policies and priorities should not be driven by individual issues or contaminants as they receive media or political attention. Scarce public resources must be targeted toward the most pressing environmental and human health-related problems. The EPA’s continued commitment to a science-based approach to policy making is critical to achieving this goal.
AMWA specifically urges the EPA to: (1) target resources at reducing the highest demonstrated risks to human health, (2) develop solutions to environmental problems using an integrated approach that examines all sources of a contaminant and considers effects on all stakeholders, including drinking water systems, (3) emphasize pollution prevention as a program priority, (4) work to improve public understanding of environmental and health risks and the costs for their correction, (5) develop improved analytical methods, (6) improve scientific understanding of environmental health impacts including the health protection of children and other potentially sensitive populations, (7) continue to provide for stakeholder involvement in the development of solutions to environmental problems, (8) consider sustainability of our environment and resources, and (9) utilize a holistic approach to its integrated planning policies by considering drinking water infrastructure investments alongside those of wastewater and stormwater infrastructure.
Rationale:
- Only by ranking environmental problems scientifically by risk, and considering the costs of correction, is it possible to ensure that resources are appropriately allocated to the greatest public health benefit.
- Reacting to perceived public health threats without regard to proper risk assessment could lead to a fragmented regulatory approach and the expenditure of federal, state and local resources in areas of negligible return - resources that could be devoted to the greatest public health benefit.
- EPA’s continued emphasis on a more holistic approach to regulation is appropriate. The agency should always consider the interaction of various existing laws, such as the Safe Drinking Water Act (SDWA), the Clean Water Act (CWA), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), and others, when seeking to reduce contaminant risks and assessing potential regulatory costs.
- Excluding drinking water from integrated planning discussions could lead to unintended outcomes that disproportionately direct capital investments toward wastewater and stormwater infrastructure –thus leaving communities with fewer resources to address equally important drinking water infrastructure needs.