There’s no shortage of state and federal legislation related to safety and security of our community water systems. There’s good reason for that. Without question, clean drinking water contributes to every aspect of quality of life; including residential development, economic vibrancy, and the ability to attract investment by visitors and developers alike.
America’s Water Infrastructure Act (AWIA) became law in 2018 to update previous regulatory frameworks. The tragedy and emerging risks associated with the September 11, 2001 terrorism acts spurred requirements for vulnerability assessments of community drinking water supply, including treatment and distribution systems, to review and enact measures to bolster security of this critical infrastructure. Those assessments were required to be submitted to the US Environmental Protection Agency (EPA).
Today’s regulations require water utilities serving populations of more than 3,300 to complete Risk and Resilience Assessments and Emergency Response Plans (ERP), and to certify the completion of these documents to the EPA.
The newer AWIA requirements are a much more comprehensive evaluation of system security and preparedness. The new assessments not only include risks of malicious acts, but also serve to review the all types of emergency situations, and to conduct planning for utilities to become as resilient as possible in order to maintain operations.
Plans are intended to ensure the provision of a safe and reliable supply of public drinking water during times of heightened risk. Federal regulators are looking to replace the older, possibly outdated vulnerability assessments with these new measures. That said, previously completed vulnerability assessments may be used as a template and/or basis for an update to the more comprehensive documents. Likewise, many communities have existing Emergency Response Plans for their public water supply systems and these may also be updated and certified to comply with the new rule.
Chances are, your community is already subject to these new rules. Feel free to contact us with questions. Certifications of Emergency Response Plan updates are due 6 months after the compliance deadlines for the Risk and Resilience Assessments. Risk and Resilience Assessment Certifications must be updated every 5 years from the deadlines listed above.
Where do I start?
Efforts to meet the requirements will vary greatly depending on community size, the scope of previous vulnerability assessments/response plans, and the information your community has developed on various aspects of your water assets.
The first step to compliance is to determine what existing information you have available, including previous Vulnerability Assessments, active Emergency Response Plans, Capital Program Inventory Data, Asset Management Plans, Engineering Reports and Studies, Record Plans, etc. GASB 34 Financial Asset inventories will also be useful if these have been completed.
If a water model has been completed, you’ll find lots of the required information on the distribution system there. A list of critical and hard to obtain parts and supplies will also be beneficial. These documents and associated information will be critical for the Assessment of Risk and Resilience.
Other information, including agreements and plans related to maintenance of operations during critical times will be beneficial with the evaluation of risk to continuity of operations. These might include Operations Manuals, Business Continuity Plans, Mutual Aid Agreements, NIMS/Emergency plans, Staff Training/Cross Training Plans, etc.
You’re Not Alone!
Compliance with AWIA can seem daunting, especially if your community has had trouble maintaining solid records over the years. However, the EPA has provided a great deal of information and useful tools to assist public water supply entities with AWIA compliance. The EPA’s AWIA Website contains many resources at: www.epa.gov/waterresilience. There is also a vulnerability self-help tool that municipalities may use to run scenarios and determine where they stand. American Water Works Association (AWWA) also has many risk and resilience tools and documents to assist your community with compliance with challenging regulatory requirements.
Regulatory compliance is never the best part of your day, but in this case, it does translate directly to resilience of one of your greatest community assets. Stay up to date on requirements, and keep investing in your critical infrastructure. It pays off in more ways than you think!
