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ASDWA and GWPC Submit Joint Comments to EPA on Source Water Protection Measures Reporting

On January 8th, ASDWA and the Ground Water Protection Council (GWPC) submitted joint comments to EPA’s docket on the “Agency Information Collection Activities; Proposals, Submissions, and Approvals: EPA Strategic Plan Information on Source Water Protection.” The request for comments was originally posted in the Federal Register Notice on November 9, 2018. This new information collection request (ICR) proposes to change the reporting frequency for the voluntary source water protection (SWP) measures in EPA’s 2018-2022 Strategic Plan from annual to quarterly reporting, which is consistent with the Agency’s efforts to streamline and increase the reporting frequency on all the Strategic Plan measures in EPA’s Draft FY 2020-2021 National Water Program (NWP) Guidance to monthly and quarterly reporting.

The ASDWA and GWPC comments to EPA on the Strategic Plan source water protection measures were developed jointly with input from the associations’ Source Water Protection Committees. The comments highlight that it is essential for EPA to continue including these measures in the Strategic Plan and NWP Guidance to help ensure the importance of SWP for states and EPA, and to track progress on implementation actions. However, the comments recommend that EPA retain the annual reporting requirement rather than changing to quarterly reporting for the two SWP measures. The comments also include information about:  the burden of increased reporting on SWP outweighing the benefits; the difficulty in demonstrating progress and calculating changes for quarterly reporting due to the more than one year time frame for developing local SWP plans; the inability to accurately estimate the burden for all states because of the broad variability in state tracking and reporting processes; the need for state workplans to be renegotiated; and more.