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The Association of Metropolitan Water Agencies (AMWA) supports a local water utility’s ability consider direct and indirect potable reuse for various fit-for-purpose contexts, as additional water supply flexibility is essential to ensuring the nation’s water resilience, security and sustainability.

As more water will potentially become reclaimed and reused for drinking water, having information to effectively characterize health risks and develop risk assessments is critically important. This underlying science informs the key building blocks to the processes to set treatment performance objectives under fit-for-purpose reuse. Fit-for-purpose standards and criteria must be developed to ensure that public health and the environment are protected.


AMWA believes that the federal government should continue to fund research to review the public health implications of indirect and direct potable reuse. EPA should coordinate its research with the water sector and other stakeholders to identify a water reuse research plan and commit to funding research related to understanding the health implications of microbial and microconstituents of concern in water and the health implications of indirect and direct potable reuse, particularly for areas of agriculture and stormwater reclamation. In addition, AMWA recommends additional research is necessary to understand the constituents present in oil and gas produced water and other industrial process water before it should be considered for indirect or direct for potable use. This research should be completed before considering these process waters for reuse outside of the processes on site.

At water utilities around the country, indirect potable and direct potable reuse projects will differ due to the source water quality and regulatory framework of the state where the project is being implemented. Reuse for industrial use, military operations or oil and gas production will also have different regulatory frameworks and best practices. It is imperative that procedures and policies for implementing direct potable reuse be irrefutable regarding the safety for public health.

The federal government should continue to promote advances in reuse technologies and approaches through leveraging current programs and mandates and developing and piloting reuse projects within the federal family.

Rationale:

  1. While some utilities may choose to employ direct and indirect reuse methods and treat water to varying degrees, not all communities may wish to take advantage of water reuse or potable uses. Communities and local stakeholders should therefore carefully evaluate potable water reuse proposals and have the flexibility to only select and implement the approaches most suitable for their community. For example, some utilities may choose to reserve water reuse for non-potable purposes –thus saving traditional water supplies for human consumption.
     
  2. The deployment of reuse technology is not a one-size-fits all endeavor. Just because technology provides a way to reuse process water from industrial processes and oil and gas extraction does not mean that we should proceed to reuse this water without understanding implications to public health and the food chain.
     
  3. Progress in advancing water reclamation and reuse within the federal family could inspire action among other stakeholders and industries to consider fit-for-purpose applications of water reuse and strengthen the public’s trust in reuse practices, which in turn could positively affect utilities considering the expansion of their drinking water resource portfolios via implementation of water reuse applications.
     
  4. Direct and indirect potable water reuse technology has the potential to augment traditional water supplies. Approaches to potable water reuse may involve diverting a portion of return flows either into an existing supply reservoir or directly into a water treatment facility.  Water utilities must be diligent while implementing these new technologies to ensure continued protection of public health. This new supply may serve both human consumption and emergency response purposes.