United States
         Environmental Protection
Office of Water
February 1994
                                              Printed with Soy/Canola Ink on paper that
                                              contains at least 50% recycled fiber






                   U.S. Environmental Protection Agency.  Office of Water.  February 1994.
                            DRINKING WATER PROTECTION

                               A GENERAL OVERVIEW OF

The Safe Drinking Water Act (SDWA) has
become a  symbol  of the  debate  over
unfunded federal mandates.  Two  issues
seem to fuel the controversy:

•      Costs to small systems are increas-
mg.  While 89% of US households pay an
average of $1-2 per  month for SDWA
compliance, costs for households served by
some small systems can be more than ten-
fold higher.

•      Nation-wide   standards   address
contaminants not found in certain localities.
leading to costs  that are  said  to  be
disproportionate to benefits,  and a  poor
regulatory "buy."


No single change can solve all the problems.
The Administration's approach is a balanced
package to:

-*      Address  problems  facing  small
systems, including monitoring and treatment

-ป      Revise the mandate to regulate  25
additional contaminants every 3 years and
focus only on those contaminants that pose
real health risks;

-ป      Enact a State revolving fund (SRF) to
loan water systems the funds for capital
-*    Increase   State   drinking   water
program resources and work with States to
cut  monitoring   costs   using   existing

-ป    Emphasize  pollution prevention by
protecting sources of drinking water.


Congress passed the Safe Drinking Water
Act  (SDWA)  in  1974  following public
concern over findings of harmful chemicals
in drinking water  supplies.  The  SDWA
established   the   basic  Federal-State
partnership  for drinking water used today.
EPA sets standards to protect drinking water
and provides grants, guidance and technical
assistance  to  States and  public  water
systems.  States ensure compliance by the
200,000 public water systems serving 241
million Americans.

EPA's authority to set standards under the
1974 Act was discretionary.  Twelve years
later,  when EPA  had regulated only one
additional   contaminant   beyond  the  22
originally covered by the Public Health
Service,  Congress  decided  that  a more
directive  approach  was  warranted  and
enacted the  1986 SDWA amendments.

The 1986 SDWA Amendments required reg-
ulations for 83 specific contaminants and 25
additional contaminants every 3 years. The
regulations, called National Primary Drin-
king Water Regulations (NPDWRs), include
Maximum Contaminant Level Goals based

purely on health concerns,  and enforceable
Maximum Contaminant Levels (or treatment
techniques)   that   reflect   feasibility  of


Focusing on Real Health Risks

Expenditures must be targeted to the highest
priority   health  risks.      For   current
regulations, about 75% of costs are for
(1) filtering  and disinfecting to  protect
against bacteria and  viruses;  and  (2)
reducing lead in drinking water.
       Targeting investment to Health
          x-  -   ' Benefits
" - tJMปซt ^ 'Coppซ* Rwfe? WS pwtwct sn
„ 600.ODO  cases gf illnass annually.
Other   regulations   address   significant,
nationwide  drinking  water risks  such as
petroleum compounds leaked from storage
tanks,  and widely used pesticides.  Many
risks  remain, however.   In the  1990's,
SDWA costs will go up as EPA regulates
harmful disinfection byproducts and widely-
occurring   natural   contaminants  (e.g.,
arsenic),  and tightens  protection against
waterborne   microbes   such   as
Ciyptosporidium,  the parasite that made
400,000 residents of Milwaukee  sick in
April of 1993. It is critical to revise the "25
every  3  years"  mandate so that  future
expenditures can be used to combat only the
highest priority drinking water risks.

EPA proposes to consider health  risks ur>
front before initiating a regulation.  Sound
scientific information should be assembled
first, then EPA should regulate only those
contaminants that occur in drinking water at
levels posing real health risks.

The Critical Role of States

Nearly all States have "^primacy" to oversee
the day-to-day operations of the SDWA. In
recent   years,  SDWA  regulations  have
allowed greater State discretion and decision
making in program implementation  (e.g.,
monitoring waivers) which allows for better
targeting of program resources toward prior-
ity health  risks.  However, State programs
often lack the funding necessary for meeting
basic primacy requirements, and few States
are able to take full advantage of existing
flexibilities. EPA estimates that States face
a resource shortfall  of $162 million.

States need additional resources, particularly
if the  SDWA is reformed to  provide  a
greater  State  role  in implementing new
flexibilities  and other  approaches  (e.g.,
pollution prevention).

Helping Small Systems

Nearly all Americans (89%) are supplied by
systems that serve more than 3,300 people.
Yet most  water systems are small: 87% of
the systems serve fewer than 3,300 persons.

Small systems include much more than cities
and towns.   Trailer  parks,  homeowner
associations,  factories, churches and hos-
pitals that have their own water systems are
also regulated.  Some small systems find  it
too costly to filter surface waters or test for
chemical compounds that may threaten water
supplies. Many lack the technical, financial,
and managerial capability to consistently
comply with regulations.  New approaches
are needed for small systems.   For small
systems facing disproportionate costs,  the
Administration recommends a streamlined

variance to spur development of innovative,
low-cost technologies for small systems.

Reducing Monitoring Burdens

Everyone  deserves to know  whether the
water  coming out of their  faucet is  safe.
However, water testing can be expensive,
especially for chemical contaminants.

SDWA  regulations  have  a  risk-based
monitoring approach.  Most of the cost is
for tests to guard against bacteria, parasites
and viruses,  tests that no one disputes are
essential.     For  chemical  contaminants,
periodic testing is required to  ensure water
is safe —  with State-issued  waivers where
monitoring   is   clearly   not   needed.
Monitoring   frequency   drops   if  no
contamination is found.

EPA has put a new emphasis on using flexi-
bilities in SDWA regulations  to  focus on
cost-effective monitoring through:

       "use"   waivers  to   eliminate
       monitoring where  a chemical has
       never been used, and "susceptibility"
       waivers  where a  community  has
       protected wells or watersheds;

       mixing samples together ("composit-
       ing") to lower laboratory costs, and
       use   of   previously   collected
       ("grandfathered") data.

EPA has  issued  guidance and is funding
workshops to  help   States  make use  of
waivers.  States with approved monitoring
waiver programs can cut  monitoring costs
for some regulations by 50% or more. For
an  investment of $500,000, Wisconsin is
cutting monitoring costs for water systems
by $15 million.  With monitoring waivers,
Massachusetts estimates that approximately
$12.5  million  could  be  saved  by  water
systems over  a two year period.
Pollution Prevention

Preventing contaminants from reaching and
fouling our water supplies in the first place
will bring sensible, cost-effective protection
of our drinking water.  This will help focus
monitoring on problem areas,  reduce the
future need for treatment, and complement
similar tools under the Clean Water Act.

The Funding Challenge

No matter how  hard we work to focus
SDWA on real  public  health  risks  and
address the disproportionate costs to small
systems, new funding is needed.  States
require additional resources to take  full
advantage  of existing flexibilities  and to
cany  out new  responsibilities.   Many
systems need financial assistance to build
filtration  plants,  replace  lead  pipes  and
comply with other protective standards.


The Administration's integrated proposals
address the funding challenge, small system
concerns,  risk-based priority setting,  and
pollution  prevention.   Cost-effective  sol-
utions are possible without lessening public
health protection.     The  first  step  is
regulating only contaminants that pose real
health  risks,  then   setting   affordable
standards.  Small systems should be allowed
to use innovative technologies  to  reduce
compliance" costs  and ensure safe drinking
water.  Targeted monitoring and  flexible
compliance timeframes will save  money.
Investments in pollution  prevention  will
provide long-term risk reduction at lower
costs.  The proposed Drinking Water State
Revolving  Fund  addresses  the  need  for
investment in drinking water infrastructure
and will help  water systems defray the costs
of compliance.  For more  detail,  see the
accompanying list of the  Administration's
ten SDWA proposals.






                   U.S. Environmental Protection Agency.   Office of Water.  February 1994.

In September, 1993, the Administration submitted to Congress a package often recommendations
for Safe Drinking Water Act (SDWA) reauthorization. These recommendations are a package
which, taken together, address the fundamental issues surrounding implementation of the
SDWA. The recommendations are summarized below.

       1 Establish A Drinking Water State Revolving Fund Many communities and water
       suppliers lack the financial capability to meet the rising costs of SDWA compliance.  A
       State revolving fund would provide low or zero interest loans to help water systems comply
       with the provisions of the SDWA and protect the safety of drinking water.

       2 Maintain State Primacy Through An Optional SDWA User Fee  The Federal/State
       partnership for drinking water is in jeopardy due to inadequate funding and rising program
       responsibilities.  The SDWA should require States  to develop plans for implementing a
       well-run primacy program.  States  that identify funding problems in their plan should have
       the option of establishing a dedicated State "drinking  water protection fund" into which
       SDWA fees would be deposited. If the optional fund is established by the  State, the fees
       would be used, in conjunction with other resources, to cover the cost of State services and
       functions related to SDWA implementation. If a State loses authority for implementing the
       SDWA program, the fees would be paid to the Federal government to cover the cost of
       EPA's administration of the program in that State.

       3 Implement Programs To Protect Sources Of Drinking Water No level of monitoring
       and treatment can protect against man-made contaminants as reliably as preventing
       contamination in the first place.  Requiring States,  in cooperation with public water
       suppliers and local government entities, to develop and implement a source water protection
       program for both ground water and surface water will help prevent pollution, thereby
       reducing the long-term costs associated with monitoring and treatment.

       4 Provide Flexibility For States With Enhanced Source Water Protection Programs
       States with primary enforcement authority for the Public Water Supply Supervision
       Program should be allowed, with approval from EPA, to develop alternative monitoring and
       treatment approaches for public water supply systems with "enhanced" local (or area-wide)
       source water protection programs.  To support  the  development of these prevention-based
       programs, such activities should be eligible for funding under the Drinking Water State
       Revolving Fund  (see recommendation #1).

5 Ensure Viability Of Small Systems Eighty-seven percent of community water systems
are small systems (serving less than 3300 persons). Many of these systems lack the
financial, managerial, and technical capacity to meet the requirements of the SDWA.  To
address these problems, States should adopt programs to improve system capabilities and
prevent the formation of new  non-viable systems. Through sharing of administrative
functions and other restructuring options, many small systems may find they are better able
to afford the costs of providing water and complying  with the regulations.   An estimated
one half of the 50,000 small community water systems would benefit from restructuring.

6 Establish "Best Available  Technology" (BAT) Alternative For Small Systems Due to
economies of scale, treatment technologies that are affordable for large systems often are
not affordable for small systems. Small system "BAT" provides a streamlined process for
States to grant 5-year treatment variances to groups of eligible systems that install
affordable technology and take other practical steps to protect public health.

7 Train And Certify Systems Operators   Forty-five States currently have operator
certification programs.  However, most States exempt small systems to some extent. States
should be required to implement a complete program for  operator certification and training
as a condition of primacy.  EPA would define minimum program criteria and address the
role of certified  operators as appropriate within individual drinking water regulations.

8 Improve The Process For Selecting Contaminants For Regulation  EPA is currently
required by the SDWA to establish standards for an additional 25 contaminants every 3
years regardless  of health risk.  This process should be replaced with a new process
whereby EPA, in consultation with States and the Science Advisory Board, would identify
priority contaminants and determine an appropriate regulatory response based on health risk
and occurrence.  EPA would  categorize contaminants into 2 tracks. Track 1 would warrant
immediate regulation based on analysis of risk and occurrence data. Track 2 contaminants
would receive further study before decisions are made regarding  the need for regulatory

9  Increase Flexibility For Setting Compliance Timeframes  Under current law, drinking
water  standards  become effective 18 months after EPA promulgation. In many
circumstances, this timeframe is not realistic for systems  that need to install treatment,
particularly when major construction is necessary. EPA  should have explicit authority to
specify, within regulations, reasonably expeditious compliance timeframes of up to 60

10 Streamline And Strengthen Enforcement Provisions  The SDWA lacks enforcement
authorities found in other environmental statutes. Enforcement authorities within the
SDWA should be combined and revised to (1) provide uniform administrative, civil
judicial, and criminal enforcement authorities which  are more consistent with other statutes
administered by EPA, and  (2) increase deterrence and improve compliance with the lav/.





                     U.S. Environmental Protection Agency.  Office of Water.  Feburary 1994.
                                    DRINKING WATER ISSUE
A  rigid statutory requirement to regulate 25
contaminants every 3 years discourages cost-
effective regulation by diverting  attention and
resources from priority public health risks, and
hampering science-based decisionmaking.

              The 1986 Safe Drinking Water
              Act  (SDWA)   Amendments
              require  EPA to issue  national
              primary  drinking   water
              regulations (NPDWRs) for 83
specified contaminants  and for 25 more  every
three years.    EPA has now  regulated 84
contaminants  and will  regulate about 110 by
1996. This mandate has served to strengthen the
Nation's  drinking  water safeguards —  for
example, the  control of lead and the protection
against  microbial waterborne disease.  These
highly beneficial regulations address important
public health risks and account for three-fourths
of the cost of today's regulations.

However, the rigid "25 every  3  year" statutory
scheme  prevents  EPA  from  aiming future
regulations at only the highest priority drinking
water risks and therefore may produce relatively
small benefits hi a tune of constrained resources.

          'There  should be  no  mandatory
         m "quota" of contaminants to regulate.
EPA should have the flexibility and the time to
select contaminants based on sound  scientific
data on occurrence and health effects.  EPA
should regulate ONLY those contaminants that
pose real risks to health.

In consultation with the  States,  the scientific
community and the public,  EPA periodically
should identify a limited number of contaminants
to be placed on a study track accompanied by a
published research plan.  Following completion
of the necessary health and occurrence studies,
EPA  would  decide  whether a  regulation  is
needed based  on health risk.

           By regulating only contaminants that
           pose the greatest public health risks
        Jp (rather  than  a large number  of
           contaminants that may pose small
           risks) States and water systems will
be making the best possible use of limited
resources.    Targeting priorities will  foster
compliance and lead to full  realization of the
Act's public health benefits.

Reforms to the regulatory process will benefit all
water systems and State programs.  However,
for small systems facing disproportionate costs,
streamlined variances should be available for
systems that install special "small system best
available technology." This approach will spur
development  of  innovative,  lower-cost  small
system  technologies  while  improving the
drinking water safety for small systems.

The  Administration supports  several  other
measures   that  would   improve  the  cost-
effectiveness  of the  drinking water program,
including more flexible compliance timeframes
and pollution  prevention.  (For more detail, see
the Administration's ten SDWA proposals.) The
Administration also supports more effective use
of  risk-based  monitoring   regimes   under
authorities already hi SDWA regulations.

U.S. Environmental Protection Agency.  Office of Water. February 1994.
                      STATE CAPACITY

Insufficient resources prevent many State primacy
agencies from fully carrying-out ever increasing
State drinking water  program responsibilities.
These States are at risk of losing their authority to
run the Safe Drinking Water Act (SDWA) program.
Any loss of State primacy would severely weaken
the Nation's drinking water safeguards.


State drinking water programs perform a broad
range of activities  which include:
             I  adopting  drinking  water  regu-
            lations at least as  stringent as EPA's
           (national   primary   drinking   water
            regulations (NPDWRs);
            • maintaining an inventory of public
            water systems (PWSs);
 • reviewing requests for public water supply
   system expansion;
 • assuring that the design and construction of new
   or modified water systems  will be capable of
   compliance with the SDWA;
 • providing technical assistance to PWSs;
 • certifying and training PWS operators;
 • tracking PWS compliance with NPDWRs;
 • conducting or overseeing sanitary surveys;
 • making filtration determinations;
 • issuing waivers, variances and exemptions;
 • certifying and supervising laboratories;
 • ensuring water  supplies are monitored;
 • making inspections;
 •  carrying-out enforcement responsibilities; and
 •  reporting data to EPA.

 Combined Federal and  State funding for State
 drinking water programs grew from $96.5 million
 in  1988 to $142 million in 1993,  a 47 percent
 increase.  This increase has not kept up with State
 needs.  EPA estimates that State funding needs
                              totalled $304 million in 1993, creating a shortfall
                              of $162  million.   This  shortfall  limits  States'
                              ability to issue monitoring waivers that provide
                              cost  savings for systems  and hampers  States'
                              ability  to fulfill  their primacy  responsibilities,
                              particularly adopting and enforcing regulations in
                              a timely manner.  Such delays may result in a loss
                              of State primacy and postpone health benefits for
                              millions of people.


                              The  solution?  Increase the amount of resources
                              for State  drinking  water  programs.   In States
                              having trouble fulfilling their responsibilities due
                              to insufficient resources, Congress should establish
                              a SDWA drinking water "backstop" user fee and
                              provide  States with  an   option to  establish  a
                              dedicated "drinking water fund" to receive SDWA
                              fees. These fees would be used by the State solely
                              to fulfill its  SDWA responsibilities.

                              Already, 33 States dedicate user fees to  their
                              drinking water programs.   The most common fees
                              are water usage and connection fees received from
                              water systems.  Some of these  States increased
                              their revenue  by $33 million for  their drinking
                              water programs in FY 1992 and FY 1993. How-
                              ever, more is needed.  The SDWA-authorized fee
                              would  not  interfere  with successful  State fee
                              systems, but would stimulate action in other States.
                              If a State fails to fulfill its primacy responsibilities
                              due to insufficient resources and fails to establish
                              a "drinking water fund,"  EPA  would have the
                              authority to withdraw primacy.  In States where
                              EPA is  the  primacy authority,  the  Federal
                              government would establish a fund to  receive the
                              user fees to cover the cost of implementing the
                              SDWA hi that State.

                      U.S. Environmental Protection Agency. Office of Water. February 1994.
                                      DRINKING WATER ISSUE

                                   SMALL SYSTEM COMPLIANCE

 Systems that serve fewer than 3,300 persons supply
 water  to  approximately   11  percent  of  the
 population,  but  comprise 87 percent of  the
 community -water systems.   Many small systems
 lack the  financial,  technical and managerial
 capability to consistently  comply with  the Safe
 Drinking Water Act (SDWA).


           [Current drinking water regulations are
           affordable for  most Americans —  the
 average cost is a  little more than $1 per month.
 However, the cost can  be much higher for 11
 percent of Americans who drink water supplied by
 one of the 50,000 small systems.  For systems
 serving 25-100  persons,   the average annual
 incremental household costs for SDWA compliance
 are $145 as compared to $12 for  systems serving
 between 100,000  and 500,000 persons.  In part
 because of high  household costs, many small
 systems  do  not  fully comply with  SDWA
 requirements.  In  1992, 77 percent of "significant
 non-compliers" were systems which served fewer
 than 500 persons.

 In addition to potentially  high household costs,
 many small systems suffer  from:

        • limited customer/rate base;
        • limited technical/management
        • inadequate or aging  infrastructure;
        • inability to access capital.

 Small community systems  have  many  different
 forms of ownership — 15% of the small systems
 are owned by  homeowner  associations;  15%  by
private investors;  25% by mobile  home parks;
 40% by  local governmental   entities;  and the
 remaining  5% by other forms.  This  diversity
makes it difficult for regulatory agencies to address
the unique problems of small systems. We need a
new approach to ensure that small systems deliver
safe drinking water economically, while main-
taining  strong  national  drinking  water  safety


           Several  of  the   Administration's
           proposals would relieve the financial,
           technical and managerial problems
           facing small systems.   The drinking
water State revolving fund (SRF) would assist in
financing capital projects or source water protec-
tion programs.   This proposal, along with  the
proposal to  allow  special  5-year variances  to
systems that install best available technology  for
small systems (small system BAT), should assist
many systems to achieve compliance with the Act.
In addition, increased State resources should help
States provide additional  technical assistance  to
smalll systems, including monitoring waivers  for
systems with little vulnerability to contamination.

Some small systems may no  longer be able to "go
it alone."  To address the underlying institutional
weaknesses of many small  systems, the SDWA
should require States to adopt programs that assure
the viability of new and existing drinking water
systems.  Among the many options available to
small   systems   are   informal   cooperative
agreements,  sharing  of administrative staff  and
managerial and operator services, contracting for
operation   and   maintenance,    management
consolidation  and  ownership  transfer.    These
solutions,  as  well as physical consolidation, are
called "restructuring."  States  should work with
individual systems to use one or more restructuring
options, as appropriate.   By  doing so,  small
systems  may find that they are better able to meet
compliance costs  and other costs of supplying
water.  An estimated one-half of the 50,000 small
community water systems would  improve their
viability and benefit from restructuring.

                      U.S. Environmental Protection Agency.  Office of Water. February 1994.
                                      DRINKING WATER ISSUE
                                   SOURCE  WATER PROTECTION

The Safe Drinking Water Act (SDWA) focuses on
expensive monitoring and treatment to assure safe
public water supplies without an equal focus on
protecting ground water and surface water supply
sources BEFORE they become contaminated.


            Monitoring and treatment can never
            protect drinking water  supplies as
            reliably as preventing  contamination
            in the first place. The environmental
            paradigm  of pollution  prevention,
along  with  monitoring  and  treatment  where
necessary, provides a stronger, more cost-effective
basis for safeguarding public water supplies.

Benefits  of source  water  protection  programs
include reduced treatment needed to comply with
the  regulations,  more   focused  and  targeted
monitoring  of vulnerable water supplies, avoided
costs for finding alternative sources of water, such
as drilling new wells, and citizen involvement in
protecting water supplies.   In addition,  source
water  protection  programs, in  tandem with
monitoring  or treatment, provide a safety net for
drinking water supplies.

           JOnce  contaminants reach the source
            of   drinking   water  supplies,
particularly   ground  water, clean-up  or  well
replacement costs can be high. Estimated costs for
the remediation of 50 of the Superfund sites which
affect ground water  sources of drinking water
totaled over $370 million, with the vast majority of
sites costing over $1  million  each and many
exceeding $10 million.  Water well closures and
replacement costs  range from $58,000 (for wells
serving fewer than  100 people) to hundreds of
thousands of dollars per well.

           As  part  of its pollution prevention
	| initiatives,   the   Administration
recommends the development and implementation
of source water protection programs.  Already 31
States   have  approved  Wellhead  Protection
Programs under the SDWA.  This concept should
be  broadened  to  include  surface  waters  and
strengthened  to  assure  implementation.   At  a
minimum, all States should be required to establish
a  baseline  protection  program —  with local
participation  and  implementation — to  protect
community  water  supplies.    These  baseline
programs would include a delineation of drinking
water protection areas, inventories  of significant
sources  of  contamination,   vulnerability
assessments,   contingency  plans   and  local
involvement. The next step would be an optional
enhanced  source water protection program.  An
enhanced  program,  also  developed with local
participation, would contain stronger, enforceable
prevention measures.  Where enhanced  programs
are in place, "States would be allowed to establish
tailored monitoring  and treatment exemptions.
Such flexibility would benefit both large and small
water systems.

SDWA-authorized   source   water   protection
programs would complement the watershed initia-
tive under consideration in the  Clean Water Act
reauthorization process.  To stimulate source water
protection  programs,  implementation  activities
should be eligible for drinking water SRF funding,
including monitoring to assess vulnerability.





                    U.S. Environmental Protection Agency. Office of Water. February 1994.
 "Chemicals such as the 'pineapple pesticide' were never used in
most of the United States, yet EPA needlessly  requires every
system in every State to monitor for such chemicals."
 • The so-called  "pineapple pesticide" is dibromochloropropane
 (DBCP), a pesticide that, in fact, has been detected in ground
 water and surface water supplies across the country.

             DBCP wasi detected in 16 out of 25 states for which
       data were analyze.*  At least ten of these States found
       levels exceeding the drinking  water standard.  EPA is
       currently reviewing data from other States.

 • DBCP was used on more than 40 crops including citrus, cotton,
 grapes, soybeans, peanuts, almonds, strawberries, and commercial
 vegetables prior  to  1979.   Its  use was restricted by EPA to
 pineapples in 1979,  then banned completely in 1987.

 • The pesticide, considered a probable human carcinogen, is
 highly persistent and mobile in the environment -- that is why it is
 still showing up in water supplies.

 • Monitoring waivers — an option under current regulations ~ can
 reduce monitoring costs in places where a chemical is unlikely to
pose a contamination problem.  To use this option, a State must
 gain EPA approval of a program for evaluating the vulnerability
of water  supplies.    Through  waivers and other  flexibilities
Wisconsin is  reducing  monitoring  costs by $15 million.  Other
States are expected to reduce monitoring costs for some regulations
by up to half or more.
             * States with detections: Alabama, California, Colorado, Massachusetts, North Carolina, Pennsylvania,
             Delaware, North Dakota, New Mexico, New York, New Jersey, Ohio, Georgia, Tennessee, Texas,
             and the Virgin Islands (counted as a State).

                    U.S. Environmental Protection Agency. Office of Water. February 1994.

              "The current Safe Drinking Water Act requires such stringent
             standards that regulating a single contaminant could cost billions
             of dollars to  avoid just a single case of illness."
             ป No  SDWA regulations  have  the  impact  alleged  by this
             statement.  The total annual  cost of all 84 standards now on the
             books is expected to reach $1.4 billion nationally by  1995. The
             fact is that approximately 80 percent of households pay $3.00 to
             $13.00 per year for compliance with all SDWA regulations.*

             • Studies that calculate the theoretical "cost per case avoided" are
             often based on limited occurrence data and assume expenditures
             that are not actually incurred  by systems. There are many options
             for compliance, including restructuring, use of alternative water
             supplies, or the protection of source waters.   Federal and State
             infrastructure assistance programs help to defray costs incurred by

             • Measures of "illnesses or deaths avoided" for the regulation of
             a contaminant often under-estimate the true value of drinking water

                           Most treatment processes, once in operation, will
                    protect  against several potential threats — not just a single
                    contaminant and its associated health impacts.

                           Calculations of "illnesses or deaths avoided" usually
                    ignore  the  extra margins of safety the public desires.
                    Safety — not just  illnesses  and deaths avoided — is a
                    valuable benefit of drinking water regulations.  In fact, a
                    1993 study by the American Water Works Association-
                    Research Foundation found that 74 percent of-water system
                    customers were witting to pay additional costs in order to
                    raise drinking water quality above federal standards.

* 75% of the national SDWA investment is for the combined costs of filtration and the control of lead.
Filtration is expected to prevent 83,000 cases of illness, and the EPA lead rule is expected to protect
an estimated 600,000 children from unsafe blood lead levels.



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Change in Average Household Costs
        For Drinking Water
System Baseline Incremental Total Projected Percent
Size Costs1 Costs Costs Increase
(population served)
25-100 $264
101-500 314
501-1K 198
1K-3.3K 256
3.3K-10K 282
10K-25K 201
25K-50K 192
50K-75K 186
75K-100K 157
100K-500K 176
500K-1000K 169
> 1 0OOK 1 42
Average2 $1 90
^•FoT systems serving


less than 10,000,
Survey of Community Water Systems


costs were derived from


the 1986
and updated according to the CPI;
for systems serving over 10,000, costs were derived from the
Water Industry Data Base
2Weighted according
to population served
                                 Source: EPA's Report
                                 to Congress, Sept 1993


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