G. Tracy Mehan III, AWWA's Executive Director of Government Affairs, sent me AWWA's comments on the Perchlorate Rule.
Here is the relevant EPA publication, Health Risk Reduction and Cost Analysis of the Proposed Perchlorate National Primary Drinking Water Regulation:
Download EPA-HQ-OW-2018-0780-0124
The following PDF is Tracy's letter followed by 30+ pages of the AWWA comment:
Download AWWA_Comments_Perchlorate_NPDWR_26Aug2019
Below is Tracy's letter:
August 26, 2019
Mr. David Ross
Assistant Administrator, Office of Water Environmental Protection Agency
1200 Pennsylvania Ave. NW Washington, DC 20460RE: National Primary Drinking Water Regulations: Perchlorate; Docket ID No. EPA–HQ– OW–2018–0780
The American Water Works Association (“AWWA”) appreciates the opportunity to comment on the request for comments regarding EPA’s proposed National Primary Drinking Water Regulation for perchlorate published in the Federal Register on June 26, 2019.
AWWA is an international, nonprofit, scientific and educational society dedicated to providing solutions to ensure the effective management of water. Founded in 1881, AWWA is the largest organization of water supply professionals in the world. Our membership includes more than 4,000 utilities that supply roughly 80 percent of the nation's drinking water and treat almost half of the nation’s wastewater. Our 50,000-plus total members represent the full spectrum of the water community: public water and wastewater systems, environmental advocates, scientists, academicians, and others who hold a genuine interest in water, our most important resource. AWWA unites the diverse water community to advance public health, safety, the economy, and the environment.
Following extensive review of this issue for many years, EPA has rightly suggested that perchlorate does not exist in public water systems with a frequency and at levels of public health concern and that the regulation of perchlorate does not present a meaningful opportunity for health risk reduction.1 EPA also rightly concluded that the benefits of any of its proposed perchlorate regulations would not justify the costs of such regulatory action.2 If EPA proceeds, it will set a troubling precedent and undermine the scientific credibility of the Agency’s regulatory process under the Safe Drinking Water Act. As such, EPA should withdraw the positive regulatory determination for perchlorate.
AWWA firmly supports the efforts of the Agency to follow through on the recommendations of the Science Advisory Board and peer review panel identifying weaknesses regarding the innovative modeling efforts applied during this evaluation. AWWA appreciates the opportunity to share our concerns, which are aimed at ensuring that sound science guides EPA’s regulatory actions. Our full comments are below. If you have any questions, please feel free to contact Kevin Morley or me in our Washington Office at 202-628-8303.
Best regards,
/s/ G. Tracy Mehan III
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