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California passed the Sustainable Groundwater Management Act (SGMA) almost a decade ago as a step to bring the states’ depleted groundwater aquifers to sustainability. With increased droughts, the implementation of SGMA and protection of vulnerable communities dependent on small water systems and domestic wells is urgent. Over the last 2 years, Clean Water Action has reviewed and analyzed over 95 groundwater sustainability plans, in every groundwater basin covered by SGMA, closely evaluating the steps local agencies are taking to protect vulnerable communities.

Every year in Massachusetts more than 40% of the waste in landfills, incinerators, or as litter (more than 2 million tons) is composed of materials that were banned from disposal long ago by Massachusetts Department of Environmental Protection regulations. This report covers the scope of the problem and provides recommendations to eliminate this substantial portion of the waste stream.

May 4, 2020

Dr. Thomas Armitage, Designated Federal Officer (DFO)

EPA Science Advisory Board (1400R)

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue NW, Washington, DC 20460

via email: armitage.thomas@epa.gov

Dear Dr. Armitage,

We provide these comments for consideration by the EPA Science Advisory Board (SAB) in their review of EPA’s National Primary Drinking Water Regulations: Proposed Lead and Copper Rule Revisions. We urge the SAB to consider aspects of the Proposed Revisions where EPA’s proposal missed the mark in terms of achieving significant public health risk reduction