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The Association of Metropolitan Water Agencies (AMWA) supports strong federal action to research and respond to the impacts of global climate change upon the nation’s drinking water supplies and infrastructure. The long-term viability,sustainability, and resiliency of the nation’s water supply is integral to a viable national economy and therefore a comprehensive, unified, and coordinated federal research program is essential for developing decision support tools, adaptation and mitigation strategies, and for helping local utility managers access better information on the regional impacts of climate change on drinking water quality and quantity. The Environmental Protection Agency (EPA), the National Oceanic and Atmospheric Administration (NOAA), and other federal departments and agencies currently conducting climate change research must increase their efforts to develop decision relevant science, including reliable modeling systems and regional to localized projections of freshwater quality, quantity and flow.1 This information should offer clear guidance on how water utilities may prepare for changing climate conditions over the next several decades.These analyses should also include considerations of how climate change may impact future human migration patterns, and how these changing patterns will affect regional water usage and availability.Similarly, the work of the US Global Change Research Program in issuing a periodic National Climate Assessment in accordance with the 1990 Global Change Research Act plays an important role in summarizing the latest global climate change science that is relevant to the United States

AMWA urges Congress to take into account the impacts of climate change on water resources during development of any legislation to regulate greenhouse gas (GHG) emissions, and to take steps to mitigate the anticipated environmental damage that warming is expected to cause. Specifically, climate change legislation must recognize that water resources and infrastructure in much of the United States are significantly threatened by changing hydrological conditions. Therefore, increased assistance and investment are necessary to help water systems adapt to changing climate conditions and deliver uninterrupted water service to rapidly growing service populations. A percentage of federal revenues derived from any cap-and-trade or carbon tax system should be set aside for research, adaptation, mitigation, and other initiatives that will evaluate and address the impacts of climate change on water resources and public water utilities in the United States.

AMWA encourages EPA to consider a holistic, systematic, long-term assessment of how statutory obligations under the Safe Drinking Water Act and Clean Water Act could impact climate change mitigation and adaptation efforts. Concerns about unintended climate impacts or challenges related to SDWA and CWA regulations are at the top of minds of many AMWA utility managers. For example, some of the most advanced treatment technologies available, such as reverse osmosis (RO), nanofiltration, and ultraviolet photolysis (UV) or UV and advanced oxidation processes (UVAOP), are energy intensive and will increase energy consumption of drinking water utilities. As EPA develops regulations, especially National Primary Drinking Water Regulations, under SDWA, it is important that EPA considers and plans holistically for such impacts, particularly how achieving compliance with important public health regulations could impact local, state, and federal greenhouse gas reduction goals

Congress should carefully evaluate mitigation strategies, such as experimental carbon capture and storage (CCS) technology, which could result in harm to underground sources of drinking water. CCS or similar technologies that place harmful chemicals underground should not be deployed until comprehensive protections for drinking water sources are put in place, including a clear standard outlining who is liable for any unforeseen damages caused by the technology.

AMWA supports its members’ efforts to assess their vulnerability to climate and hydrologic change, including the increase in intensity and frequency of extreme events that are attributable to these changes. AMWA supports member efforts to take steps to adapt to these changes in their long-term strategic plans. AMWA also supports members’ efforts to evaluate their GHG emissions and take appropriate steps to reduce emissions and increase energy efficiency when feasible. Likewise, the federal government should offer incentives for carbon-emitting operations, including water utilities, to take proactive steps to reduce their emissions and increase the efficiency of both their plants, and their customers’ water usage.

Rationale:

  1. Scientific research has found that climate change is impacting the hydrological cycle and threatens drinking water supplies in the United States in a number of ways, including increased evaporation reducing water storage capacity, rising sea levels threatening inland water supplies, changes in seasonal rainfall patterns, reduced mountain snowpack, and increased water contamination as a result of heavier storm intensity and increased turbidity and sedimentation.
  2. Some policymakers cite CCS technology as an attractive strategy to reduce greenhouse gas emissions while enabling the continued use of abundant energy sources such as coal. In the past Congress considered several climate change bills that would rely on CCS to achieve mandated carbon dioxide emissions reductions, and in 2010 EPA promulgated a rule to regulate the long-term sequestration of carbon dioxide under the Safe Drinking Water Act’s Underground Injection Control program.
  3. Water utilities must begin planning now for their expected water supply needs and water availability realities over the next several decades. Climate change threatens to make current forecasting models irrelevant, so new regional projections are needed to help water utilities plan for the next 20 50 years.
  4. America’s water infrastructure is in need of billions of dollars worth of improvements in the coming decades, even absent the additional stresses that will be imposed by climate change. Increased investment in this infrastructure and the development of alternative water supplies will help utilities adapt to these serious challenges.
  5. Regulations under CWA and SDWA, like a new NPDWR, may require utilities to implement advanced treatment technologies to meet a certain maximum contaminant level or treatment technique. Advanced treatment technologies that achieve high removal of a broad array of contaminants include RO, nanofiltration, and UVAOP, all of which the EPA describes as energy intensive.2

1  The latest techniques for downscaling general circulation model climate projections has resulted in climate variable outputs with spatial resolutions of better than 1/8° latitude-longitude (~12 km x ~12 km). See: https://gdo-dcp.ucllnl.org/downscaled_cmip_projections/#About31these changes.

EPA. 2023. Overview of Drinking Water Treatment Technologies.