CRWUA 2006 Resolutions and Supporting Position Statements

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1. The Environmental Protection Agency (EPAZ included in its Safe Drinking Water Act (SDWAZ regulations a "review" of the content of state capacity development strategies that CRWUA believes is not found in the statute. The CRWUA believes that states should have total flexibility over the content of state capacity development programs for existing systems. 2. The CRWUA believes that the EPA should give States the sole authority to design and implement capacity development strategies to ensure that drinking water systems have the financial, technical and managerial resources they need to comply with applicable laws. Groundwater Disinfection Rule: The SDWA requires the EPA to develop a rule that requires disinfection "as necessary" for groundwater systems. States which have primacy under SDWA shall be responsible for determining the circumstances under which disinfection is "necessary." Consumer Confidence Reports: EPA 'has, inappropriately attempted to limit state flexibility in the production and dissemination• -;of consumer confidence reports. Also EPA has gone beyond statutory mandates in requiring (i) additional source water information, (ii) additional explanatory information, and (iii) requiring states to warehouse the reports. This may result in unnecessarily complex and burdensome report obligations. CRWUA believes that EPA should err on the side of flexibility in implementing consumer confidence report requirements. Position Statement - -- Safe Drinking Water Act - -- (Resolution No. 2006 -8) Protection of safe drinking water supplies is of paramount importance to the welfare of this nation. When Congress enacted the Safe Drinking Water Act in 1974, it directed the Environmental Protection Agency (EPA) to set national drinking water quality standards. In its 1986 amendments, Congress further directed the EPA to set maximum contaminant level goals. The Colorado River Water Users Association recognizes that a careful balancing of appropriate scientifically based data and analysis to safeguard human health and safety with the limited financial capabilities of both urban and rural communities across the West is necessary in order to achieve the Act's important objectives. It is vitally important that the EPA be part of the solution and not part of the problem in all matters regarding the public drinking water supplies across this Nation. Resolution No. 2006 -9 - -- RURAL COMMUNITY WATER AND SEWER SYSTEMS Drinking water and sewer systems developed under USDA programs shall be protected. Encroachment by other water and sewer systems into USDA grant or loan drinking water and sewer systems shall not impair the ability of the system to deliver water, provide service or pay financial obligations. Position Statement - -- Rural Community Water and Sewer Systems - -- (Resolution No. 2006 -9) USDA drinking water and sewer programs provide drinking water and sewer services to many rural residents. The programs provide the ability to develop systems and to expand existing facilities. In the last 30 years, USDA programs have helped fund approximately 17,000 water and sewer projects serving more than 12,500 rural communities. The programs have the lowest default (less than 0.1 %) and delinquency (less than 2 %) rates of any government loan assistance program. Repayment is structured according to the ability of the system (through rate payments by system beneficiaries) to charge for services. Current federal law protects USDA drinking water and sewer programs from encroachment by other systems. This protection insures that systems will continue to have the ratepayer base necessary to make the payments. If federal law protection of these systems is altered, impaired or repealed, the systems will not be able to repay loans. 13