On January 2, AMWA submitted comments to EPA on its Draft Office of Water (OW) Climate Change Adaptation Implementation Plan and its Draft FY 2014-2018 Strategic Plan. The letters are available on AMWA’s website.
In its comments on the adaptation implementation plan, AMWA asks the EPA to specifically detail its criteria for identifying priority implementation actions. 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 its 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.
Both letters encourage EPA to consider climate change across the spectrum of both the Clean Water Act and Safe Drinking Water Act, noting that affects of climate change impact not only considerations for rule development, but also implementation and enforcement.