Additionally, it is important to note that EPA’s cost analysis is calculated across 35 years, even though the bulk of the costs will be required in the first 10 to 13 years after the rule is finalized, resulting in a likely inaccurate assessment of the impact the proposed rule will have on ratepayer affordability. [...] Unfortunately, the historic capital stimulus provided by Congress in the IIJA falls far short of the cost this proposed LCRI will impose on public water systems and affordability will continue to represent a major barrier to reaching the public health goals of the proposed rule. [...] Recommendation: We urge EPA to take a holistic and integrated approach to drinking water regulations and consider the cumulative impacts that the rules and regulations will have on local governments in terms of cost and compliance and implementation timelines. [...] The Agency should take such factors as the preponderance of LSLs in a community, local market conditions, issues around gaining authority to access private property, liability concerns and the use of water rate revenue to remove LSLs into consideration when working with local communities on the implementation of the proposed LCRI. [...] The Safe Drinking Water Act defines public water systems and delineates between portions of the distribution system that are under the control of the PWS and portions that are connected to the distribution system, but are not under the control of the PWS.
Authors
- Pages
- 8
- Published in
- United States of America
