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Recommendations
THURSDAY, MAY 17, 2001
I. Implementing New Regulations: Review State
Capacity Analysis - Mr. Larry Wright/Ms. Elizabeth Corr/Ms. Vicki Ray
- Ms. Elizabeth Corr discussed the work plan. The basis for the understanding
is the impending wave of new rules and programs to protect public health
under the 1996 SDWA Amendments. States are already playing and will
continue to play a critical role in turning these amendments into reality.
With that opportunity comes a big workload and the states and EPA must
work together to make the best use of available resources and figure
out solutions to barriers within the program.
- The GAO report of August, 2000, spurred a lot of interest in the program.
EPA feels that although the report raises some interesting points, it
may oversimplify the situation, and a comprehensive look is necessary
at this time. In addition, the recently released WIN report is currently
being discussed in Congress. This report includes a recommendation to
phase out the drinking water SRF and replace it with a Grants program.
- At the national level, EPA wants to identify program shortfalls. At
the state-specific level, they are looking for a problem-solving tool
that individual states and regions could use to work together.
- The scope of the work plan is broad. EPA wants to look at workload,
available funding resources, barriers to implementation, and program
and resource solutions for the federal and state levels.
- EPA hopes to get data from all 50 states, the Pacific Islands, the
Virgin Islands, and the Commonwealth of Puerto Rico. The analysis would
not include tribes.
- EPA has a five-part approach to accomplishing goals:
- designing the data collection instrument;
- analyzing data;
- identifying solutions;
- determining who will do what; and
- target opportunities for action at the federal and state levels.
- Progress to date includes establishing a work plan, setting up a work
group, conducting work group meetings, and utilizing a subgroup to develop
a data collection model.
- The next steps include sending a model out to pilot states, having
a conference call with the work group, sending the data collection model
out to all the states, getting the data back, and working together in
the work group to draft a report. The goal is to have something available
for the October ASDWA annual conference, and eventually to release a
final report.
- Mr. Larry Wright discussed the model EPA used to come up with the
projection of future needs and the projected funding to meet those needs
over the next ten years for the drinking water program.
- The model used was based on a 1999 model developed by ASDWA and EPA.
The model will be sent to each state for evaluation of their specific
program requirements, as opposed to relying strictly on default values.
The 1999 model had been updated then to include the new requirements
of the SDWA Amendments. In addition, another category: "Other State
Programs", looks at not only rules, specific requirements, but things
such as lab certification and cross-connection control. The time frame
has been extended to cover 2001 to 2010.
- The default values present in the model are intended for the states
to use as benchmarks to determine if they are applicable, or if in their
particular instance, those default values need to be changed. This should
allow the composite national needs estimate to be more accurate than
previous models that have relied on more general information. In addition,
the default values are being broken into five state categories, versus
three in the previous model.
- In addition, a format was established for barriers and innovative
solutions in the model. The state can rate the barriers and this will
allow for a national picture of the most significant barriers in terms
of implementation of the drinking water program.
- Mr. Wright conducted a detailed review of the highlights of the model.
- Ms. Vicki Ray discussed a template developed to present information
in state program capacity and barriers. The model will be run and then
the blanks of the analysis template will be filled in. There are five
categories:
- identify the current capacity of the states;
- estimate future state program needs;
- identify the state-specific barriers to implementation;
- identify possible solutions to these barriers; and
- provide solutions to these problems.
- Ms. Ray conducted a detailed review of the template.
II. Council Discussion
- EPA requested input from NDWAC members on the following discussion
topics:
- How does EPA ensure the maximum level of state participation?
EPA plans to ensure receipt of the completed state models and agree
to a return date; do reminders; assess the non-responders; and target
phone calls. One member suggested use of local environmental groups
to help ensure that the states complete the model. Dr. Yohe suggested
a note from EPA to the supervising official above the person actually
conducting the model work for the state would help to ensure that
the work is done. Another member suggested provision of a tutoring
group to help those that need it. Dr. Spath noted that there are
some states that may not want to fill out the model because it will
bring to unfavorable notice the current administration's environmental
policies. Numbers also will be regarded as estimates and not written
in stone. Dr. McMullen noted that many surveys are received and
not completed; possibly use a cash or training credits or some other
incentive to encourage returns.
Who, in addition to those identified by EPA, are additional
audiences for the report? EPA listed key audiences to include:
federal and state regulators, state/EPA senior management, federal
and state elected officers, governors and legislators, industry
associations, regulated industry and GAO. Several members stressed
that the public needs to be included.
- What is the incentive for the public and others to support
this initiative?
- What level of sign-off on the report is needed?
What format should the report be in? One member
suggested that the report should be tailored to the audience and
a short executive summary in plain English should be provided
(Note: the recommendation for an executive summary was seconded).
Note: in order to keep on schedule, EPA will accept comments
from NDWAC members at a later time.
III. Infrastructure Gap Subcommittee: Review
of Infrastructure Issues and Plan for Subcommittee - Dr. David Spath and
Mr. Joshua Joseph
- Mr. Joshua Joseph discussed infrastructure and included the following
points:
- Drinking water in the U.S. is among the best in the world. At
the same time, there is widespread consensus that infrastructure
is a concern.
- The 1999 Drinking Water Infrastructure Needs Survey estimated
that there are about $150.9 billion in needs over the next 20 years,
and this estimate is conservative (the largest part of that need,
~56%, is transmission and distribution).
- If looked at in terms of size: large, medium and small systems,
the average 20-year need per household will involve a larger amount
of investment for the small systems.
- In examining the infrastructure challenge, both Clean and Safe
Water infrastructure, EPA is considering the capacity of water systems
to meet expanding public health and financial demands. What will
be needed to maintain the progress that has been gained over the
last number of years in providing safe and affordable water to the
nation? How will this then influence our policy agenda?
- One report, "Recommendations for Clean and Safe Water in the 21st
Century," produced by the Water Infrastructure Network, suggested
that about $23 billion per year over the next 20 years must be invested
to address the public health priorities of the CWA and the SDWA.
Another report, "Water Infrastructure Now," recommended a series
of public and private actions were needed to meet the coming infrastructure
funding challenges. These reports have done a lot to increase national
dialogue on this issue, as has the Help to Optimize Water Coalition.
- Re-examination of the role of federal assistance involves looking
at 1) affordability; 2) what are the needs that go beyond the Drinking
Water Needs Survey; 3) what is happening at the systems level; 4)
what are some of the root causes of the issue; 5) what are some
of the barriers to improvement; 6) how to ensure that the drinking
water utilities can meet compliance requirements; 7) effects on
systems' growth and ecological sustainability; 8) how can PWSs access
new planning and management tools; 9) what partnerships can be achieved;
and 10) how can stakeholder involvement be maximized?
- EPA will gather additional information of the numbers and magnitude
of the infrastructure problem; next fall, NDWAC may establish a
subgroup to look at findings and provide recommendations toward
a policy agenda.
IV. Council Discussion
- EPA has done some analysis of cost, affordability, and what is being
spent on infrastructure for water and wastewater. EPA wants to gather
greater detail on the drinking water side over the next several months.
One member commented that the $150.9 billion figure was low as it did
not account for variability within the Regions.
V. AWWA Accreditation Policy Program - Ms.
Eva Nieminski
- AWWA is hoping accreditation will result in a status of a seal of
approval that is different from just compliance with existing regulations.
Accreditation should result in demonstrating that accredited utilities
do implement the best standards of the best management operations and
provide the highest quality of drinking water for the customers.
- Accreditation will be voluntary: it is up to participating utilities
to seek accreditation or not. However, with the incentives in place,
it is expected that the program will reach all system sizes.
- AWWA is hoping that this will be something that will result in measurable
difference in water quality and effectiveness of management. The project
is outcome oriented. It is not a replacement of future regulations.
An accredited facility would lose accreditation if it failed to comply
with regulations.
- For primacy agencies, a program like this would allow a state to decide
which utilities pose the highest challenges and where to focus efforts.
- Dealing with consumer confidence and improving the image of tap water
is another area that accreditation can help with.
- Pathogens and disease outbreak occurrences happened when facilities
were in full compliance. Accreditation will provide a tighter goal above
and beyond compliance to address this issue as well.
- The policy and procedures are being developed right now by a consultant
hired by AWWA. The consultant has stressed that people must see the
financial benefits in the outcome of this program. Another consultant
is looking at the way interest rates on loans to water utilities for
plant expansions or modifications can be lowered if it is accredited.
In addition, liability insurance rates are being examined in this light
as well. A priority list could be developed for the SRF.
- The AWWA would like feedback on the standards lists for different
sizes and types of utilities. AWWA is looking first at the distribution
and source water protection standards because there is opportunity for
partnership with EPA here. As soon as these standards are ready to be
piloted, the AWWA will go into additional areas.
- AWWA also designed a program called QualServe that offers utilities
a step-by-step approach into water quality improvement. Accreditation
can use this and other tools but QualServe will not be used as a prerequisite
to accreditation.
- Once concerns have been identified, an action panel has been established
to address these concerns, a stakeholder process will be engaged in
to help build the program.
- A budget has been approved by the board and an active committee is
working. Outside consultants have been hired. The distribution system
manual has been given to a standards committee, which will provide a
list of standards for the utilities to go through and a list of questions
for the accreditors to ask.
VI. Council Discussion
- The Council members discussed the notion of keeping the momentum going.
Financial incentives such as those discussed above might be difficult
for a utility that is part of a city and would need to be part of a
larger group to be accredited. This might lose a good portion of the
utilities in a state. One member suggested partnership with the National
League of Cities might benefit attempts to connect with the right people
within cities. Dealing with small-town governments can be just as challenging.
- Costs would be in proportion to the system size. There are still questions
remaining on how to maintain accreditation. A comparison to universities
has been initiated.
- Concerns related to accrediting the entity and not the individual
were raised. There may be some redundancies.
- One member questioned the perceived benefits of less state oversight
and those utilities already with low interest rates as not providing
much incentive in some cases.
VII. Council Recommendations
The Council made two formal recommendations which are listed below:
- Resolution on Clean Water Act/Safe Drinking Water Act Coordination
The quality of water in the United States is not only important to
the health of our environment but it is the vital, common link to
our nation's public health. Ensuring clean, sufficient and reliable
sources of water for public and environmental health is a principal
goal and responsibility of the U.S. Environmental Protection Agency
(EPA).
For more than 25 years, EPA has independently administered the provisions
of the Clean Water Act and Safe Drinking Water Act. Separate administration
of these programs has led to conflicting, confusing and duplicative
requirements. The inefficiencies and frustration of separate administration
are shared by all stakeholders.
The National Drinking Water Advisory Council (NDWAC) commends the
efforts by all participants to coordinate programs, however the NDWAC
also recognizes that coordination of these programs requires support
and direction from the Administrator. Therefore, the NDWAC recommends
that the Administrator develop an integrated and coordinated application
of the Clean Water Act and Safe Drinking Water Act programs to effectively
and efficiently use all the tools within the agency to achieve the
goal of clean, sufficient, and reliable water for all public and environmental
health needs of the United States.
- Recommendation on Benefits Analyses
The National Drinking Water Advisory Committee recommends that the
Environmental Protection Agency review the report of the former NDWAC
Benefits Working Group to: 1) determine if the agency's actions to
develop the January, 2001, Arsenic rule were consistent with the NDWAC
recommendations; and 2) consider the NDWAC recommendations on benefits
analyses while reconsidering the Arsenic Rule in 2001.
VIII. Next Meeting/Announcements
- November 7-9, 2001, Washington, D.C. Fall Meeting
- August 22 and 30, 2001 Conference Call (on Arsenic Cost Review)
- Drinking Water Symposium sponsored by EPA, NAWC, and NARUC will be
held in St. Petersburg, Florida on September 12 through 14, 2001.
IX. Update on EPA Regulatory Actions - Mr.
Ephraim King
- Unfinished business includes:
- Arsenic Rule;
- Final Long-Term 1 Enhanced Surface Treatment Water Rule;
- Final Radon Rule;
- Final Ground Water Rule;
- Long-Term 2 Enhanced Surface Water Treatment Rule; and
- Stage 2 Microbial and Disinfection By-Product Rule.
- National Academy of Science Report on Contaminant Candidate List:
A regulatory determination will be made late summer or early fall on
whether or not to regulate for nine chemicals on which information is
adequate.
- Six-year Review: EPA will be offering a preliminary sense of where
they think things are headed in late fall of 2001 or early spring of
2002.
- Radon: EPA will brief the new administration in June.
Note: The meeting concluded at 1:51 p.m.
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