The Association of Metropolitan Water Agencies (AMWA) supports strong federal action to research and respond to the impacts of global climate change on the nation’s drinking water supplies, treatment, and infrastructure. Specifically, these impacts include changes to weather, precipitation, and hydrological systems and changes in the occurrence and intensity of extreme weather events, such as fires, hurricanes, tornadoes, droughts, floods, and other storms.. 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 and funding program is essential for developing decision support tools, adaptation and mitigation strategies, and clear information on the regional impacts of these phenomena on drinking water quality and quantity.
The Environmental Protection Agency (EPA), the National Oceanic and Atmospheric Administration (NOAA), the Department of Interior, and other federal departments and agencies currently conducting research related to changing climatic conditions must increase their efforts to develop decision relevant science, including reliable modeling systems and regional to localized projections of freshwater quality, quantity, and flow.This information should offer clear guidance on how water utilities may prepare for changing climatic conditions over the next several decades. These analyses should also include considerations of how changing patterns may impact future human migration patterns, and 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 extreme weather and changing climatic conditions on water systems and infrastructure, and to take steps to mitigate the anticipated changes to the hydrological cycle that will impact water utilities. Specifically, increased federal assistance and investment are necessary to help water systems adapt to changing climatic conditions and deliver uninterrupted water service to rapidly growing service populations. Significant federal funding investments should be devoted to research, adaptation, mitigation, and other initiatives that will evaluate and address the impacts of extreme weather events and changing hydrological, weather, and precipitation conditions on water resources and public water systems 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 necessary mitigation and adaptation efforts. 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 applicable local, state, and federal greenhouse gas reduction emissions standards.
Congress should carefully evaluate greenhouse gas 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 changes in the intensity and frequency of extreme weather events and changes in weather, precipitation, and hydrologic systems. 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:
- Scientific research has found that changing climatic conditions are 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 faster snowmelt, and increased water contamination as a result of heavier storm intensity, increasing temperatures affecting evapotranspiration rates, more prevalent wildfires, and increased turbidity and sedimentation.
- 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.
- Water utilities must begin planning now for their expected water supply needs and water availability realities over the next several decades. Changing climatic conditions threaten to make current forecasting models irrelevant, so new regional projections are needed to help water utilities plan for the next 20 – 50 years.
- 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 extreme weather events and changing climatic conditions. Increased investment in this infrastructure and the development of alternative water supplies will help utilities adapt to these serious challenges.
- 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.1
1 EPA. 2023. Overview of Drinking Water Treatment Technologies.