18990_Authority_Feb_2026

60 The Authority │ February P a g e | 2 P.O. Box 115, Harrisburg, PA 17108 | www.paawwa.org | (717) 774-8870 | info@paawwa.org The following are general comments by the WUC for your consideration: Water and wastewater system laboratories operate as essential public service entities—not as profit-generating businesses. Our operations are supported primarily through ratepayer funds, both of which are under significant fiscal pressure. The proposed fee increases represent a disproportionate burden on local governments and could jeopardize the financial viability of small and mid-sized water and wastewater system laboratories across the Commonwealth. Chapter 252 accreditation is a regulatory requirement, not an elective service. Therefore, these fee increases cannot be absorbed through internal efficiencies or offset by new revenue streams. Instead, they will directly divert funds from other public health and environmental protection activities. The likely outcomes are concerning: • Smaller water and wastewater system laboratories may be forced to reduce analytical capabilities or surrender accreditation, leading to decreased local testing capacity. • Water and wastewater systems would become more dependent on private laboratories, often resulting in higher per-sample costs, longer turnaround times, and logistical challenges for sample handling and reporting. • Residents and ratepayers will bear the fiscal impact through increased utility rates or reduced service levels. Water and wastewater system laboratories play a vital role in the Commonwealth’s public health infrastructure. They ensure local control over data quality, rapid response to water quality concerns, and cost-effective regulatory compliance. Increasing accreditation fees without consideration for these realities’ risks undermining that local capacity. In addition, the WUC offers the following specific comments: 1. With less laboratories than previously and virtual inspections now occurring, why are fees projected to increase so much? The WUC requests more information on transparency. 2. What happens if the Laboratory Accreditation Program has a surplus at the end of year? Will any surplus generated by the fees result in a reduction in fees the following year? 3. If Pennsylvania laboratory fees are subject to increase, then we believe that the out-of- state onsite reimbursement fee also needs to be increased in Chapter 252.206 (Out-of- State onsite reimbursement). 4. Increased fees will eventually affect the residents of Pennsylvania with increased cost. The fees will increase expenses of laboratories which must be recovered by increasing fees to water and wastewater systems, which in turn will need to increase rates to customers. 5. Pennsylvania has fewer laboratories to accredit with more staffing in accreditation than other states. 6. According to the DEP’s fee report, it shows the highest cost is personnel. Why does the program need the same number of personnel if there has been a decrease in accredited