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NEIWPCC Responds to Potential Changes to EPA Quality Policy & Procedure

Posted on Tuesday, December 1st, 2020 | Posted in News

NEIWPCC, on behalf of the six New England member states, recently submitted comments on an unpublicized update that, if adopted, would result in largely unknown effects to NEIWPCC and state Quality Management Programs.

NEIWPCC has requested clarification and additional information on parts of the update and the added time to provide “substantive, meaningful feedback.” Without adequate time to provide feedback on and review requested clarifications on changes in the updated policy and procedure, the full effect to NEIWPCC and state quality management programs remains elusive.

Quality management is an integral process for environmental data collection projects completed by NEIWPCC or by those working on our behalf. Major changes to EPA’s governing policies may be difficult to implement for our states, especially during a time when states are facing budgetary and staffing-related uncertainties related to the COVID-19 pandemic.

An Atypical Process

Distribution, communication, and timelines did not follow the typical EPA channels and process for this update. A public docket was not issued, with state comments coordinated through Environmental Council on States and the process for interstates specific to each region.

NEIWPCC received the draft update from our QA colleagues at the EPA Region 1 Lab in Chelmsford, MA, but had no indication of a timeline on which comments were due. Despite a lack of a clear timeline, NEIWPCC worked expeditiously with the six New England member states to develop a response within a greatly shortened timeline.

To date, NEIWPCC has not received word from the EPA on extending the deadline for further comment or responses to NEIWPCC’s request for more information.

NEIWPCC, Member State Input Matters

As a participant in the EPA Quality Management Program since 2001, beginning with the EPA Region 1 approval of NEIWPCC’s first Quality Management Plan, we remain committed to the collection of sound, defensible environmental data to support decision making.

Nowhere is this more evident than through the success and efficiency of our Quality Assurance Project Plan (QAPP) program. To date, more than 440 QAPPs have been reviewed and approved. We take data integrity seriously.

Regular Communication Channels and Timelines Avoided

The significance of sound, defensible data to water quality is great. As such, changes to EPA Quality Policy and Procedures necessitated for NEIWPCC, on behalf of its New England member states, to request additional time for a thorough and substantive review of the documents and for the EPA to provide further information and clarification on a number of issues including:

  • Clarification on the definition of ‘Environmental Information’ and how that differs from the previous use of “Environmental Data.”
  • Clarification on how the scope of the policy and procedure have changed in the update including a whether the scope has expanded to programs that have not traditionally been included, such as inspection, rule-making, and compliance programs.
  • Identification of the expected timeline for implementation and additional guidance on when “adjustments to NEIWPCC’s and the states’ quality management systems will need to be completed to comply with the updated policy.”
  • Additional funding available to support the adoption and implementation of the updated policy and procedure.

For more information regarding NEIWPCC’s Quality Management program or these comments, contact Peter Zaykoski, NEIWPCC.

Two water quality professionals getting reading to conduct a quality assessment at a Dutchtown Road stream crossing in Sugerties, NY.

Ben Ganon (Ulster County Department of the Environment) and Tim Koch (Ashokan Watershed Stream Management Program) participating in a NEIWPCC QA Field Assessment in August, 2020. NEIWPCC Environmental Analyst Megan Lung (not pictured) oversaw the assessment. Lung is responsible for the Hudson River Estuary Program’s stream restoration and conservation efforts.

Additional Information

Quality Management