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NACWA Provides Comments to EPA on Proposed ICR on Water Quality Improvements Survey

December 1, 2021

NACWA submitted comments on November 29 to EPA on a recent proposed Information Collection Request (ICR) on Estimating Benefits of Surface Water Quality Improvements, published in the Federal Register in September.

EPA's Office of Research and Development, the Office of Water, and the National Center for Environmental Economics are collaborating on an integrated assessment model of water quality and economic analysis that could "eventually be capable of estimating benefits for a wide range of surface water changes" and are seeking to collect data through a public outreach process of 6,000 participants via online or mail-to survey to help inform this effort.

EPA’s rationale for this ICR is that there is a lack of data, coupled with the Agency having less time and fewer resources to commit to completing regulatory economic impact analysis, and therefore the empirical data received from this survey can be used to fill certain data gaps and better inform the assumptions EPA policy analysts have been "forced to make."

While NACWA strongly supports efforts to improve water quality and our members engage in this work each and every day, the Association has serious concerns with this proposed survey approach.

NACWA’s comments noted that surveying the public as a means to close research information gaps and address untested assumptions is a worthy goal, and that the Association supports additional research by the research community to understand the value that people place on surface water quality and address research gaps.

However, the comments go on to state that extrapolating public perception via a narrowly constructed survey on willingness to pay for improved water quality as a means to adjust current regulatory policies and priorities that may impact specific watersheds or individual communities in different ways is not—in NACWA’s view—an effective or appropriate way to achieve that goal.

Asking the public to respond to a general hypothetical (i.e., asking if they would be willing to pay “more” for “better” water quality anywhere) is very different than presenting individuals with a specific relatable scenario (i.e., asking about a body of water they are familiar with and whether they are willing to pay a certain amount of money to achieve a certain water quality outcome for that individual water body or watershed).

NACWA has other concerns with the proposed survey and asked EPA to not move forward with the survey in its current form. These concerns are explained in more detail in the comment letter and include proposed survey delivery, controlling for participant bias, confusing language, and misleading graphics and survey questions generally.

If members have questions on the comments submitted or the ICR more broadly, please contact Emily Remmel, NACWA’s Director of Regulatory Affairs.

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