The Environmental Protection Agency’s (EPA) Office of Water is initiating efforts to obtain comments concerning how it should integrate sustainability (i.e., the consideration of environmental, social, and economic factors) into its water regulations, particularly the recommendations of the 2011 National Academies of Science (NAS) report. For example, EPA plans to devote half of its January 18th regularly scheduled coffee with invited industry stakeholders to this topic. EPA is explicitly seeking:
- Views on major science, policy, technology challenges and opportunities to advance sustainability in the U.S. – both generally and in your sector.
- Views on advancing sustainability in the national water program administered by EPA, and your views on the agency’s overall role/priorities in addressing these challenges and opportunities.
- Thoughts on specific EPA roles regarding the science, implementation, tracking and reporting of sustainability.
- Explanations or examples of why sustainability is important, and whether we should embrace the NAS recommendation that EPA make sustainability a fundamental underpinning of our every day operations.
- Opinions concerning what EPA’s vision for sustainability should be (includes principles, objectives, goals and metrics that underlie all agency policies and programs).
- Examples of what strategies other organizations have used to operationalize sustainability that could help with EPA’s own culture change.
The NAS report, on its face, proposes some far reaching changes to EPA’s regulatory decision-making. Any company that is affected by EPA’s water regulatory programs is likely to be impacted. Companies (and their trade associations), therefore, may want to provide their perspectives on incorporating sustainability into EPA’s existing water programs (particularly on whether EPA’s role should continue to be focused on assisting in the development of voluntary metrics and other actions to encourage the private sector to adopt internal sustainability programs or whether EPA has the legal authority and/or should issue legally binding requirements). While as yet, no comment mechanism has been established by EPA concerning the NAS report recommendation, typically at this early pre-proposed rule phase, EPA accepts comments.
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