National Association of Clean Water Agencies (NACWA)

NACWA responds to Associated Press articles on pharmaceuticals in drinking water

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The recent series by the Associated Press on pharmaceuticals found in municipal drinking water demonstrates the need for a national strategy to manage the use and disposal of these compounds, according to the National Association of Clean Water Agencies (NACWA), an organization representing nearly 300 municipal wastewater treatment plants.  NACWA members are public servants who pride themselves in putting concern for the environment and public health first by working 24-hours a day, seven days a week to ensure clean and safe water. 

While the presence of these compounds in our waterways is not new, sophisticated new technologies have been developed that can detect concentrations measured at levels of parts per billion or parts per trillion.  As the AP notes, these concentrations do not pose a threat to human health.  However, it does generate public concern.

NACWA has focused a significant amount of attention and resources on the issue of pharmaceuticals and personal care products (PPCPs) in the environment, particularly through its Emerging Contaminants Workgroup.  The Association released a white paper in 2005 that detailed the scope of the problem and possible solutions.  In addition, NACWA and its water sector partners have several efforts underway to shed light on this issue, including:

·         The establishment of a national strategy to address the complex issue of PPCPs that make their way into the aquatic environment, accounting for the fact that while concentrations detected in public drinking water are miniscule, the public’s concerns must be addressed.

·          A partnership with the Product Stewardship Institute on a national dialogue to develop a comprehensive approach for managing the disposal of unused pharmaceuticals.

·         The development of pharmaceutical take-back programs by member agencies that are intended to keep these compounds out of the environment altogether, resulting in the collection of significant quantities of unused medications. 

·         Support for increased funding for research into the potential aquatic and human health impacts from long-term exposure to trace concentrations of these contaminants.  It should also be noted that millions of dollars are already being spent to look at the impacts from these contaminants.  These funds support projects being conducted by EPA, the Water Environment Research Foundation, and the U.S. Geological Survey.

The Commission has consistently authorized support schemes for biofuels where it could be demonstrated that the aid did not exceed the difference between the cost of producing the biofuel (including a normal profit margin) and the market price of the corresponding fossil fuel. This method is considered to ensure the absence of overcompensation.

However, in the notified measure, the tax reduction coexists with a supply obligation. It could be argued that, if fuel suppliers are obliged to put a certain amount of biodiesel on the market, biodiesel is no longer in direct competition with fossil diesel, and therefore the fossil fuel price is no longer the appropriate benchmark and could lead to overcompensation.

In the specific circumstances of this case, the Commission concluded that the risk of overcompensation could be ruled out because the proposed tax reduction did not cover the full difference between the biodiesel production costs and the market price of ordinary diesel. Moreover, only a part of a given producer's biofuel output would benefit from the tax reduction. The Commission has also taken into account the scheme's limited duration to 2010 and the prospect of a transition to a system of pure supply obligation.

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