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AMWA submitted comments to EPA on October 30 in response to the agency’s September 16 request for feedback on its “Notice of Intent To Develop a Policy on the Determination of a Harmful Algal Bloom (HAB) and Hypoxia as an Event of National Significance in Freshwater Systems.” Such a determination would enable mobilization of federal resources to assess and mitigate the HAB’s detrimental effects, subject to the availability of appropriations, under the Harmful Algal Bloom and Hypoxia Research and Control Amendments Act (HABHRCA) of 2014.

AMWA’s comments assert that any HAB that affects a drinking water utility should be considered nationally significant and should be given the highest priority, stating “a community’s access to clean and reliable drinking water is paramount to the day to day life of its citizens.” The letter goes on to outline four points for EPA to consider when prioritizing federal resources for multiple, simultaneous events:

  • The number of drinking water utilities impacted and/or the size of the population served by the affected utilities;
  • Whether the impacted water body is the sole or majority source for a drinking water utility or community;
  • Whether impacted utilities have the technologies and capabilities to treat, monitor, characterize and test for algal populations and harmful algal toxins; and
  • Whether utilities will have to utilize treatment technologies onsite that are not routinely operational (i.e. granular activated carbon, membrane technology etc.) as this can be very costly to utilities, particularly if harmful algal blooms are a recurring event.

The letter concludes by encouraging EPA to “continue its partnership with USDA and other federal partners in prioritizing source water protection initiatives, particularly in regard to nutrient transport from point sources and non-point sources, as this will help to prevent HABs from occurring in the future.”