As a State with primacy for implementing the National Primary Drinking Water Regulations, the Michigan Department of Environment, Great Lakes and Energy (EGLE) is expected to fully implement all aspects of its safe drinking water statues and rules on which primacy is based. By regulation, EPA conducts reviews for state programs annually: the End-of-Year (EOY) evaluation. An additional tool used by EPA to evaluate a state’s drinking water program is an in-depth drinking water program review conducted approximately every 6 years. In 2016, U.S. EPA conducted an on-site review of the Michigan Drinking Water Program. As a result of the October 24, 2017 Final Program Review Report, Region 5 and the State developed a Corrective Action Plan (CAP) to address its findings.

Corrective Action Plan (CAP)

The CAP was drafted in late 2017 and has continued to undergo changes with regular updates on status of commitments. See the link below for the latest version of the CAP. The CAP prioritizes activities into 3 categories, which correspond to Tab 1, Tab 2, and Tab 3 of the CAP:

1. Required activities: Activities that are required to be completed first, such as those required by regulation and directly related to public health protection; also includes activities in the Implementation Plan (see below).
2. Prioritized recommended activities: Activities that support the completion of required activities in Tab 1, including Inadequate Resources, Lead and Copper Rule, Data Management, and Laboratory Support.
3. Recommended activities for the State’s consideration.

Region 5 reviews EGLE’s accomplishments throughout the year and discusses updates to the CAP at a minimum every quarter, including during the EGLE/Region 5 semi-annual evaluation call and the EGLE/Region 5 Joint Evaluation call conducted each year. As work is done by EGLE to complete the required activities, the CAP is updated (i.e. the CAP is a living document) to show progress over time.

In addition to the CAP, there are some activities with commitments that are included in the federal PWSS grant. These activities are included in an “Implementation Plan”, prepared by the State as a part of each year’s federal PWSS grant workplan. The three activities documented in EGLE’s FY 2020 Implementation Plan are currently highlighted in the CAP as findings/deficiencies. While these three activities are documented in the CAP, the Implementation Plan provides much greater detail necessary to indicate to EPA Region 5 that the State is making progress in achieving full implementation of the PWSS program, as required by EPA grant regulations.

For FY 2018 - FY 2020, a condition has been included in the PWSS grant that states that a revised Implementation Plan and schedule must be submitted within 45 days of the award of the PWSS grant. The State has met this deadline each year.

In FY 2021 and future years, Region 5 will continue to add specific grant conditions related to full implementation, as needed. State and Region 5 efforts to obtain additional resources necessary to fill the gaps associated with workplan activities that the State is not able to fully implement is also being tracked in the CAP. Ultimately, State progress in implementing the essential activities is formally documented in each year’s EOY report.

2016 Michigan Program Review Followup Progress and Tracking Corrective Action Plan (XLSX)(70 K, April 30, 2020) (170K, About PDF)

Please note that EGLE's progress on addressing EPA's recommendations in Tabs 2 and 3 will be updated and posted by June 30, 2020 due to ongoing COVID-19 emergency response activities.

The PDF below provides the FY 2020 PWSS grant workplan, which provides clear expectations, roles and responsibilities between EPA and Michigan EGLE.

• FY 2020 PWSS Grant Workplan (PDF)(9 pp, 195 K, April 30, 2020)