Anonymous public comment

The Discharge Monitoring Report Quality Assurance (DMR-QA) program plays an important role in ensuring analytical accuracy and regulatory consistency. However, in its current form, it places a disproportionate burden on small publicly owned treatment works (POTWs), particularly those with limited staffing and constrained budgets. This comment outlines concerns regarding financial impact, increased workload, lack of direct benefit, and participation frequency, and offers recommendations for improvement. Key Concerns 1. Financial Impact Small POTW laboratories operate under fixed annual budgets that often do not account for DMR-QA participation. This results in: Unplanned costs for proficiency testing materials Reallocation of limited funds from essential operations For smaller systems, even modest additional expenses can strain already tight budgets without providing clear operational value. 2. Lack of Direct Benefit While DMR-QA supports regulatory oversight, it offers little direct benefit to participating facilities or staff: No additional compensation or recognition for laboratory personnel No reduction in regulatory burden or reporting requirements No tangible incentive tied to successful participation As a result, the program is often viewed as an added obligation rather than a beneficial tool. 3. Increased Workload Laboratory staff already conduct routine compliance sampling, maintain detailed daily logs, and follow established QA/QC protocols. DMR-QA introduces additional testing and administrative work that often duplicates these existing efforts. For small facilities with limited personnel, this added workload creates operational strain without additional staffing support. 4. Annual Participation Requirement Requiring annual participation does not account for facility size, staffing limitations, or demonstrated compliance history. Facilities with consistent records of accurate reporting may not need such frequent external verification. Recommendations To improve the program’s effectiveness and fairness: Adopt a Tiered, Risk-Based Approach: Adjust requirements based on facility size, compliance history, and laboratory certification. Reduce Participation Frequency: Allow qualifying facilities to participate once per permit cycle (e.g., every 3–5 years). Provide Financial Support: Make DMR-QA costs eligible for state or federal assistance programs. Introduce Incentives: Offer recognition, reduced reporting requirements, or regulatory flexibility for successful participation. Conclusion While the DMR-QA program serves an important purpose, its current structure imposes recurring financial and operational burdens on small POTWs without corresponding benefits. A more flexible, risk-based approach would better support both regulatory objectives and the practical realities faced by smaller facilities. Thank you for the opportunity to provide this comment.