AWWA JAW62669

This article discusses a U.S. Environmental Protection Agency (USEPA) proposal to revise how it determines whether small water systems can afford to comply with new drinking water regulations, thus making it easier for States to grant small system variances (SSVs). The USEPA considered three key factors in developing the revised approach that include: variability in household costs of water treatment; variability in small system ability to pay; and, the need for improved implementation at the federal level of SSV provisions in the Safe Drinking Water Act (SDWA). Under a new incremental approach, the USEPA would consider the affordability of each new rule, on its own, against a much lower household income threshold for each size category. Under this incremental approach, cumulative household water bills would not be considered, in effect removing the 2.5% median household income (MHI) ceiling on total household cost. The USEPA is also considering whether it should evaluate affordability strictly on a national level using the incremental methodology or use a two-step process that additionally assesses county-level affordability when a national-level evaluation shows a regulation to be affordable. To get around the potential problem of not being able to identify SSV technologies that cost less than the affordability threshold amount, the USEPA proposes to consider technologies affordable "if they are cheaper than the least expensive compliance technology and still protective of public health."