Dear EPA: We need to strengthen water protections, not erase them.
Yesterday, EPA’s Office of Water held a listening session on what Scott Pruitt and Donald Trump call, “the regulatory burden.” We call it public protections for our air, water, and health. I had the opportunity to testify. My comments are below. If you want to weigh in, you can take action here, and be sure to personalize the message you send.
My name is Andrew Grinberg, with Clean Water Action. I appreciate the opportunity to comment, and thank the office of Water for all your hard work protecting our vital water resources.
Clean Water Action strongly objects to the premise behind Executive Order 13777 and this whole process. Regulations, including environmental and health protections, are NOT holding back our country. On the contrary, regulations that protect our water and health are some of the most powerful driving forces for our economy and our communities.
We need more protections for water, not less. Whether it is water for drinking, fishing, swimming, boating, irrigation, food production, brewing or other industries, clean water is the essential input. It is the foundation of healthy communities.
The benefits of environmental and health regulations have repeatedly been shown to far outweigh the costs and we hope this process takes an honest look at the many benefits of regulation.
For any regulation under review, EPA must quantify all the benefits, not just the costs. That includes costs in water treatment, costs to downstream communities, health related costs including medical bills and lost productivity as a result of missed work days from pollution related illness and death.
A 2013 OMB study found that benefits of regulations far outweighed costs across numerous agencies. At EPA, though, the benefits were most striking. Over the preceding decade, the benefits of EPA regulations were as high as $600 billion and only cost the economy as much as $45 billion.
The excellent return on investment is even more stark when looking at the costs and benefits of sourcewater protection. According to EPA’s own website, every $1 spent protecting a drinking water source, results in a savings of $27 on water treatment. Preventing pollution is always more cost effective than cleaning it up or dealing with its negative impacts.
With such clear benefits at relatively low costs, rather than looking for regulations to cut, EPA should be working to develop new protections that bring with them even greater benefits. We need more protections for the environment, not less.
EPA’s own policy dictates that it must prioritize drinking water protection. Since 1980, it has been EPA’s policy as part of its human health criteria, not to pass on the burden of water pollution to drinking water users and the providers who are responsible for treatment. The Agency must continue to implement this by protecting regulations that positively impact drinking water quality both at the tap and at the source.
Clean Water Action strongly objects to rolling back any protections for drinking water, our nation’s waterways or public health. A number of regulations have already been named by this Administration, and others have been identified by polluting interests for potential roll back in other stakeholder meetings.
While we object to any regulatory roll back that would have negative impacts on water quality or supply we are especially concerned and opposed to rolling back the following protections that are immediately at risk:
- Clean Water Rule, which protects the drinking water sources for 1 in 3 Americans.
- Steam Electric ELGs, which keeps toxic chemicals from powerplants out of our waterways
- Unconventional Oil and Gas ELGs, which prohibits the wastewater from hydraulic fracturing and other unconventional oil and gas production out of sewage treatment plants that are unable to handle that waste stream.
Thank you for the opportunity to comment.