Administrator Andrew R. wheeler
u.s. Environmental Protection Agency
1200 Ave NW
Washington, DC 20460

September 30, 2019
Administrator wheeler,

Vour letter to California of September 25, 2019 criticizes the state for water and safe drinking water
violations. And you demand that California take immediate action to address its compliance problems.
Your letter is apparently based on the mistaken impression that California has the worst record among
the states for compliance with clean water and safe drinking water requirements. Vour letter states that
Calitornia is "falling to meet its obligations" under delegated federal programs. You express "concern"
about California safe drinking waterviolations that "nail into question the state's ability to protect the
public and administer its SDWA programs in a manner consistent with federal requirements." You cite
"numerous exceedances" under the clean Water Act that "suggests the need tor more formal and in-
depth EPA oversight."

You target California despite the factthat California has one of the best compllance records in the
country. EPA's own data shows that forty-five states have higher rates of violation for one or both of
these programs. 50 that you can base your decisions on the facts, I attach two charts that show how
state compliance rates compare for the same topics on which you criticile California. This is data,
readily available on EPA's website.

This data is compelling evidence that compliance issues are not the real reason for your aggressive
stance toward Calitornia. ityou intend to hold California to account for waterviolatlons, the public
would expect you to send equally tough oversight letters to the forty--five states with clean water and
safe drinking water noncompliance worse than California's.

Sincerely,

 

Eric: two charts of compliance data

Percent of Community Water Systems in Violation of the Safe Drinking
Water Act in FY 2018, by State
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All data from EPA website: Enforcement and Compliance History Online (ECHO), Drinking Water Dashboard,
Performance Dashboard, FY 2018 (the most recent year for which complete data is available).

70

 Percent of Major Water Dischargers in Significant Noncompliance with
the Clean Water Act in FY 20L8, by State
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All data from EPA website: Enforcement and Compliance History Online (ECHO), State Water Dashboard,
Performance Dashboard, FY 2018 (the most recent year for which complete data is available). Note: data for
Delaware is not shown for FY2018.

70