RE: Adequate time for review - thoughts needed

[Anne Pamperl <anne.pamperl@hhss.state.ne.us>]

More time would be greatly appreciated. I had a very frustrating experience when preparing comments on the NODA for the radionuclide drinking water rule. We sent letters to water operators of all community water systems letting them know about the existence of these proposed revisions to the proposed rule. A few of the communities wanted to comment and asked for help from our State Drinking Water Program because they didn't think they could educate themselves on the proposed rule's background and then understand the proposed rule in the allotted time. By the time I finished preparing our comment letter and had it reviewed and approved by management, we were almost at the end of the comment period. We faxed copies of the letter to the interested communities and anwered any questions they had on the letter. These communities had to rush just to get a letter in and didn't really have time to stop and understand the proposed rule.

As things stand now, a 60-day comment period is too short for complex technical issues, such as proposed drinking water rules. If we have a longer comment period, we have time at the State level to review the proposed rule and all supporting documents. Then we can prepare a letter or fact sheet and send that to the water operators and/or local governments that are most likely to be impacted by the proposed. We would have time to do a press release, too, and whatever other ideas come up for education of the general public (I haven't had time to completely think this through).

Ideally it would be nice if we knew more about what is going to be in proposed rules in advance. That would give us more time to identify affected communities and inform them of the highlights of the proposed rule and how it potentially affects them. Then after the proposed rule is published, we can fill in additional details.

A better mechanism is needed for getting the word out on proposed rules. Publication in the Federal Register isn't enough. EPA needs to work with States to identify the areas most likely to be impacted and then generate press releases that are tailored for the areas.  For example, on the radionuclide NODA, EPA could have learned from the State that communities in 3 river valleys were more likely to be impacted than other areas of Nebraska. EPA could have issued a press release that briefly summarized the new rule, its probable effect, the cost/benefit to affected communities, and the areas most likely to be affected.  The local news media is going to pick up a story when it knows its coverage area is potentially affected.  Also, the general public is more likely to pay attention to an announcement if the public knows that it's potentially affected.