I am offering this testimony on behalf of NAWC's membership over 300 companies in 43 states that provides safe, reliable drinking water to over 23 million Americans every day. With its emphasis on public participation and right to know, and the requirements for sound science and cost-benefit analysis in the regulatory process, the 1996 Act represents a new paradigm for environmental legislation of which this Committee and Congress can be justly proud. Although our statement expresses some concerns over current and future issues regarding the Act and the drinking water industry, NAWC believes that overall EPA has made a good faith effort to comply with the letter and spirit of the Act. Areas of concern that we wish to address today include the proposed radon rule, the proposed arsenic rule, MTBE contamination of drinking water sources, inequitable implementation of the DW-SRF by some states, the threat to national drinking water standards posed by tort litigation, and drinking water infrastructure needs. NAWC's California chapter, the California Water Association, has prepared a statement that documents in detail the deficiencies of EPA's cost estimates, and we would like to submit CWA's statement for the record of this hearing.
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Furthermore, we believe that the prospect of water systems implementing local MMM programs in the absence of state programs is unrealistic. It is highly doubtful that the nation's public water systems, especially small systems, will have sufficient resources to achieve the goals of multimedia mitigation by themselves without state assistance. Tracking new home construction and remedial venting of existing homes is far removed from the chartered objectives of community water systems, not to mention the added burdens that would be placed on water ratepayers. In summary, NAWC believes that nationwide implementation of effective state MMM programs is essential for the Radon Rule to achieve its intended goals. Otherwise systems will be faced with the very unattractive alternatives of implementing local MMM programs or meeting a very costly MCL which cannot be justified by cost-benefit analysis.