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."