Comment submitted by Environmental Arsenic Council [W-00-19-I-C1-4]

Summary: The Environmental Arsenic Council (EARC), a trade organization representing chemical and mining companies, opposes the EPA's proposal to lower the arsenic maximum contaminant level (MCL) from 50 pg/L to 5 pg/L. They argue that the EPA's risk assessment relies on outdated, conservative, and non-linear models while ignoring more recent, relevant scientific data and significantly underestimating the associated compliance costs.