Advocacy submits comments on EPA’s proposed rule “Revisions to the Unregulated Contaminant Monitoring Rule for Public Water Systems”
On March 11, 2021 the Environmental Protection Agency (EPA) published a proposed rule titled “Revisions to the Unregulated Contaminant Monitoring Rule for Public Water Systems.” This letter constitutes the Office of Advocacy’s (Advocacy) public comments on the proposed rule, which may also be referred to as “UCMR 5” in this letter.
As written, EPA’s proposed rule creates a confusing regulatory framework for small PWS which may be left wondering whether they are obligated to collect and analyze samples without funding from EPA. Advocacy encourages EPA to revise the proposed rule to expressly conform to existing statutory requirements as well as to streamline the necessary sample collection and analysis by eliminating duplicative sampling and analysis requirements already required by EPA and states under other regulations.
 86 F.R. 13846 (March 11, 2021).