AWWA JAW63359

This article discusses small-system variances (SSVs) that were created with the 1996 Safe Drinking Water Act Amendments in response to requests by financially strapped small towns for relief from the mounting costs of complying with an aggressive 1986 rulemaking schedule directing the U.S. Environmental Protection Agency (USEPA) to regulate no fewer than 25 contaminants every three years. Unlike relatively short-lived exemptions, which require eventual compliance with a maximum contaminant level (MCL), SSVs allow utilities to avoid meeting an MCL for the lifespan of the variance technology, subject to state review every five years. Under national affordability criteria established in 1998, USEPA has always identified affordable compliance technologies for the three categories and so has never identified any SSV technologies (SSVTs). The proposed revisions to the affordability criteria, however, are intended to result in the identification and use of SSVTs, starting with the recently finalized Stage 2 Disinfectants/Disinfection Byproducts Rule (D/DBPR).