October 31, 2022

20.500.12592/4gbxzp

October 31, 2022

6 Dec 2022

We urge the Agency to ensure that the costs and burdens on local governments are justified and that any new regulatory requirements placed on local governments will achieve the identified public benefits and protect public safety within the low-risk water sector, which has a demonstrated record of safety. [...] The water sector is not representative of the chemical process safety risks that the proposed RMP rule aims to address and therefore we urge EPA to reevaluate the need for this rulemaking. [...] We would like to emphasize that drinking water and wastewater systems do not represent the same risk profile as many of the other entities regulated by the RMP program and that the sector has demonstrated a strong record of safety throughout the life of the program. [...] EPA recognized this point in the final 2017 Amendments Rule, stating that the water sector “is among the least accident-prone sectors covered under the risk management program.” As EPA moves forward with this proposed rulemaking, we offer the following overarching and specific considerations and recommendations and urge the Agency to address our concerns. [...] The proposed rule is complex and lengthy, and many of the provisions and definitions are overly broad and vague, which is likely to cause uncertainty at the local level.
Pages
6
Published in
United States of America