MEMORANDUM
Subject:
Changes
to
the
Federal
Register
Notice:
A
Small
Drinking
Water
Systems
Variances
­
Revision
of
Existing
National­
Level
Affordability
Methodology
and
Methodology
to
Identify
Variance
Technology
that
is
Protective
of
Public
Health
@

as
a
Result
of
Informal
OMB
Review
From:
Dan
Olson
TAB
Thru:
Eric
Burneson
Chief,
TAB
To:
Record
The
Agency
provided
the
draft
Federal
Register
notice,
A
Small
Drinking
Water
Systems
Variances
­
Revision
of
Existing
National­
Level
Affordability
Methodology
and
Methodology
to
Identify
Variance
Technology
that
is
Protective
of
Public
Health"
to
the
Office
of
Management
and
Budget
(
OMB)
for
informal
review
on
November
18,
2005.
EPA
and
OMB
worked
to
clarify
the
language
and
address
issues
identified
in
the
review
until
January
27,
2006.
The
OMB
did
not
recommend
changes
to
the
options
during
the
review,
but
did
recommend
the
following
changes
to
the
draft
Federal
Register
notice:
 
Provide
a
response
to
the
concerns
raised
by
the
administrators
of
State
drinking
water
programs
regarding
the
implementation
of
the
revisions
described
in
the
notice,
 
Clarify
and
enhance
the
discussion
of
protective
of
public
health
(
while
not
changing
the
proposed
guidance
level
of
3x
the
MCL),
and
 
Insert
a
discussion
illustrating
the
differences
in
household
costs
of
water
at
the
10th
and
50th
percentile.
