On January 2, AMWA submitted comments to EPA on its Draft Office of Water (OW) Climate Change Adaptation Implementation Plan.
In the letter, AMWA also urges the agency to more formally bring local utility officials into its process for implementing adaptation activities and to work with AMWA on any follow-up activities related to developing screening criteria to identify coastal water sector facilities at risk for storm surge. The letter also urges OW to work with EPA’s Office of Compliance and Enforcement to recognize how climate change affects the agency’s assumptions for compliance and enforcement activities. "As water utilities are being encouraged to make climate-ready, adaptive planning and investment decisions, these decisions cannot be made outside the regulatory framework." It also urges the water and enforcement offices to recognize how climate impacts on water resources "affect the assumptions for compliance and enforcement activities, which are, in many cases, based on 'steady state' environmental assumptions," AMWA commented.
AMWA also recommended OW consider reframing its discussion of an integrated planning framework to look holistically at water management challenges across both the SDWA and CWA to promote the sustainable management of water resources for protection of public health and the environment.