,arch 2009
slational Advisory Council f
Environmental Policy am
"~" Wf
\
Encouraging Regional Solutions to
Sustaining Water Sector Utilities
NACEPT
Snaping the Nation's Environintjntat Policy
-------
The National Advisory Council for Environmental Policy and Technology (NACEPT) is an
Independent federal advisory committee that provides recommendations to the Administrator of
the U.S. Environmental Protection Agency (EPA) on a broad range of environmental issues.
This report has not been reviewed for approval by the Agency, and hence, its contents do not
necessarily represent the views and policies of EPA, nor of other agencies in the Executive
Branch of the federal government, nor does mention of trade names or commercial products
constitute a recommendation for use. Reports of NACEPT are posted on the EPA Web Site at
http://www.epa.gov/ocem/nacept.
EPA 130-R-09-001
U.S. Environmental Protection Agency
Office of Cooperative Environmental Management
http ://epa ,gov/ocem/nacept
March 2009
-------
National Advisory Council for
Environmental Policy and Technology
Encouraging Regional Solutions to
Sustaining Water Sector Utilities
March 2009
-------
This page left intentionally blank.
-------
NACEPT
Shaping the Nation's Environmental Policy
The Honorable Lisa Jackson
Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460
Dear Administrator Jackson:
From the early days of the American West came the saying, "Whiskey's for
drinking, water's for fighting." Unfortunately, too many battles are still being waged
within the water sector over resources and coordination. Your National Advisory
Council for Environmental Policy and Technology believes the time has come to call
a stop to the fighting and get on with the work of making America's water
infrastructure responsive to the needs of the 21st century.
The attached report outlines six key strategic recommendations for achieving
sustainability in the water sector. This advice was developed from the collective
experience of the Council's membership, which cuts across multiple sectors of the
American economy, geography, and political philosophies. The Council's work was
led by an outstanding Work Group of its members; Work Group members were
Howard Neukrug, Jeff Crane, Suzanne Goss, Clayton Matt, Bill Mullican, Arleen
O'Donnell, Harrison Rue, and Dan Watts. The full Council endorses the
recommendations in the report.
We believe the six recommended strategies can be readily implemented by
EPA. The most critical need is for principled and strong support of regional and
watershed collaboration and partnerships to fulfill essential water services to the
nation's growing population. EPA must continue to move to watershed-based,
regional solutions to solve the water sector's infrastructure challenges.
This transition, while essential, will not be simple. The water sector's infrastructure
system has been built over the past 150 years. It is largely fragmented among
political jurisdictional boundaries and divided among the drinking water supply,
wastewater, stormwater, and water storage components of the water sector. The
structures of current environmental regulations, the water sector business, and EPA
do not easily accommodate locally-based, holistic solutions that are needed to
sustain the water sector and the communities that depend upon the sector.
-------
This report calls on EPA to move quickly and forcefully in adopting integrated
water resource planning and watershed management as the governing framework
for all Office of Water regulations and policies. We recommend that the Office of
Water integrate across its own programs and work more intentionally and vigorously
with other federal agencies to address regional water issues. We also highlight the
need for EPA to work more directly with local and regional collaborative efforts; to
provide new economic, regulatory, policy, and enforcement incentives for
collaboration; and to improve technical guidance, education, and outreach in
support of such collaborations.
The recent American Revitalization and Recovery Act provides the Agency with
a fresh opportunity to tackle the water infrastructure challenge. It can do so best by
focusing on sustainable, green infrastructure strategies that consider the entire water
cycle and are balanced with other elements of the nation's environmental, societal,
and economic needs. Business as usual will keep us fighting about water in the
future as we have in the past. Channeling the substantial investment provided by
the stimulus into sustainable, green infrastructure concepts is essential to rebuilding
the Nation's water infrastructure for the 21st century.
We hope you find this report and its recommendations useful. We look forward
to working with you on any next steps.
Erik J. Meyers
NACEPT Chair
-------
Table of Contents
Executive Summary.
1
I. Introduction 5
A. Purpose of this Report 5
Concerns abouf fhe Long-ferm Sustainability of Water Sector Utilities 5
Regional Collaborations and Partnerships are One Possible Solution 5
Defining a Role for EPA 6
B. Background 6
Today's Funding Gap 7
The EPA Response -The Sustainable Water Infrastructure Initiative 7
Integrated Water Resource Planning and Watershed Management 8
Regional Collaboration is not Structural Consolidation 9
C. NACEPT Sustainable Water Infrastructure Workgroup 10
EPA Charge fo NACEPT and the Phase / Reporf 10
Approach Used for this Investigation / /
ni^pff3iiLffij^^Bffliniinilllllllllllllllllllllllllll^^
A. What is meant by regional collaborations and partnerships? 13
B. Are there indicators that would help EPA identify the types of utilities that
would benefit from such collaborations? 14
C. What do successful regional collaborations have in common? 15
D. What are the barriers to collaboration? 16
E. What can EPA do to promote, encourage, and support water integrated
resource planning, watershed management, regional collaboration, and a
sustainable water sector? 18
|fl!H«^^mimn«TiL«ffl3llllllllllllllllllllllllllllllllllll^^
Recommendation #1: Integrated Water Resource Management 19
Recommendation #2: Encourage the collaborative process 20
Recommendation #3: Provide new economic incentives 22
Recommendation #4: Provide new regulatory and policy incentives 23
Recommendation #5: Reduce internal barriers 25
Recommendation #6: Provide better technical guidance, education, and
outreach 25
o
-------
Appendix I: Sustainable Water Infrastructure Workgroup Members and
Acknowledgements 27
Appendix II: Expert Presenters,
29
Appendix III: List of Acronyms
31
Appendix IV: Charge to NACEPT
33
Appendix V: References.
39
-------
EXECUTIVE SUMMARY
One of the most critical challenges facing the nation's water and wastewater
systems is how to sustain its infrastructure network to ensure that the public continues
to enjoy the environmental, health, social, and economic benefits that clean and
safe water provide.
The traditional business model for water sector utilities typically focuses on
providing one or two specific services (e.g., provision of drinking water, wastewater
collection, storm water management, water resource management, etc.) within a
defined service area. This system works well when populations are isolated and the
impacts of communities on their water resources are small relative to the
abundance of the supply.
However, this business model is ill-equipped to deal with current infrastructure,
regulatory, ecological, political, and economic realities. Today, it is hard to make a
clear distinction between wastewater, drinking water, and storm water issues and
needs. It is difficult, if not impossible, to separate the long-term ability of a utility to
deliver essential services from the planning and political realities of the surrounding
community, or the resource limitations of the surrounding watershed. The long-term
viability of water-sector systems needs to be examined and addressed on a more
comprehensive basis with these interrelationships in mind.
Further, the issues of environmental sustainability, energy management, and
global climate change are altering the environmental landscape forever. At some
point, environmental priorities will need to be re-examined with possible legislative
changes in light of the shifting landscape. Until then, EPA should do everything within
its power to shift away from an emphasis on single media and single programs
towards recognizing and rewarding positive, collaborative, broad-based behaviors
within the Agency and in the regulated and stakeholder communities. Across the
country, changes are being made by water utilities to become more financially
sustainable. It is important that utilities and stakeholders also consider the larger
environmental context to ensure that their strategies are viable in the future.
To meet the growing challenges of sustainable water management, EPA needs
to think beyond a single statute's regulatory requirements to solve problems. Today,
watersheds are the more appropriate unit and scale of management for an
integrated approach to managing the nation's water resources. Applying the
watershed approach across EPA water programs would better inform the effective
application of regulations and resources to solve the most pressing problems. By
recalibrating EPA's agenda internally, a strong "lead by example" message is sent,
lending credibility to EPA efforts to support sustainable water resources
management and innovative approaches.
-------
In sum, while EPA recognizes regional collaboration as an effective tool for
improving the long-term service of water sector utilities, identifying the specific
function that EPA could play in promoting this approach is more challenging. The
answer is not straightforward because many of the activities needed to create
regional cooperation and partnerships lie outside the traditional roles of EPA.
This report identifies specific tasks that EPA can implement to strengthen the
framework of regional or watershed-based partnerships in an effort to create
sustainable water systems throughout the nation. These tasks include:
1. Adopt integrated water resource planning and watershed management as the
governing framework for all Office of Water regulations and policy.
Integrated water resource planning and watershed management are the basic
building blocks for a sustainable water sector. The Office of Water needs to
revisit opportunities to integrate across its programs for: EPA to ensure that
federal agencies provide a coordinated effort when addressing regional water
issues; regional EPA offices to expand their watershed-based programs and
resources to support local dialogue; and EPA to offer more support to local and
regional collaborative efforts.
One of the predominant themes throughout the National Advisory Council for
Environmental Policy and Technology (NACEPT) deliberations was the need for
EPA to "break down the walls!" NACEPT recommends a number of actions
including revisiting the current EPA organizational structure to reduce internal
barriers, and focus policies, activities, and resources away from single-media,
single-issue programmatic goals. Instead, NACEPT recommends using the
broader, more collaborative watershed approach as the unifying theme and
ethic; this includes integration of enforcement staff to work in collaborative
settings.
2. Encourage the collaborative process.
By creating a positive environment for regionally linked water sector utilities to
work more collaboratively, EPA can help almost all utilities and their communities
create efficiencies. EPA can encourage local and regional collaborative efforts
by offering regional EPA office support to local groups. EPA regional offices can
provide venues where stakeholders can meet; offer support to local groups for
identifying and training effective, respected leaders; and help water sector
utilities and leaders recognize their long-term sustainability interests and needs.
In addition, EPA can foster implementation of the recommendations by
stakeholder groups by organizing an advisory group representative of these
involved organizations and individuals to assist in developing specific action
plans for how best to initiate the broadened initiatives.
-------
3. Provide new economic incentives.
EPA can support collaborations by: (1) strengthening its public message
regarding the gap between available, sustainable water financial resources
and the need to address the problems successfully, whether under the banner
of the infrastructure crisis, water system security, emerging contaminants, water
resource planning, or water quality; (2) working to identify and establish new
financial incentives to encourage water sector systems to pursue regional
collaboration opportunities by leveraging existing funded programs; and (3)
reactivating and revitalizing Section 208 as the Clean Water Act's cornerstone of
watershed-based infrastructure planning.
4. Provide new regulatory and policy incentives.
EPA can encourage collaborations by regulatory and policy incentives such as:
(1) identifying and establishing regulatory and policy flexibility to encourage
water sector systems to explore integrated watershed management and
regional collaborative opportunities; and (2) working to effectively utilize
enforcement tools, including flexibility in enforcement and permitting schedules
to encourage collaboration.
5. Reduce internal barriers.
EPA needs to do more in support of internal focus on collaborations beyond the
significant strides it has already made. While legislative and regulatory
mandates can inhibit the Agency's ability to advance broader environmental,
public health, and sustainability goals, EPA should revisit its organizational
structure to identify and overcome any internal barriers to water system
collaboration. One action recommended is to use the broader, collaborative
watershed approach as the unifying theme and ethic. Additional progress
toward collaboration could be achieved by detailing members of the
enforcement staff to work in collaborative settings.
6. Provide better technical guidance, education, and outreach related to
integrated water resource planning and watershed management.
EPA should: (1) review the Agency's existing body of literature and programs to
update, consolidate, and streamline the information and, if necessary, conduct
research and gather new information; (2) partner with water sector professional
organizations to create new, utility-focused initiatives in education,
communication, and outreach; (3) partner with watershed stakeholder
organizations to create a new "sustainable watershed" initiative through
education, communication, and outreach; (4) revise its Web site, particularly
that of the Office of Water, to align with the watershed and regional
collaboration approach; (5) create an accessible, centralized, Web-based
repository of tools and resources; (6) train and educate its regional offices, the
states, and tribes on these tools and methods so that a clear and consistent
message is communicated to the water sector and other stakeholders from
-------
policy makers and regulators; and (7) redeploy staff to increase dialogue and
face-to-face meetings to determine how to promote the long-term sustainability
of systems effectively on a local or regional level.
Where necessary and appropriate, NACEPT recommends that EPA conduct
research and publish guidance regarding the benefits of watershed and
regional collaborative approaches using case studies and other analyses.
In conclusion, EPA has the opportunity to be a leader, visionary, motivator,
catalyst, mentor, partner, financier, peer, supporter, and facilitator in strong
support for the water sector and other stakeholders to develop sustainable
water resource management solutions. EPA needs to assist with guidance,
encouragement, and education; while also recognizing and rewarding those
who are successful, thereby helping to move forward regional solutions through
partnerships.
-------
i. INTRODUCTION
A.
The purpose of this report is to provide advice to EPA on strategies it can
implement to promote and support water sector utility sustainability by encouraging
regional or watershed-scale partnerships through changes in Agency policy,
outreach, internal operations, and incentives or disincentives.
Concerns about the Long-term
Sustainability of Water Sector Utilities
Water sector utilities include systems
that provide drinking water, wastewater
and/or storm water services, and/or are
responsible for the protection of our
water resources. A combination of
forces—including population shifts, aging
infrastructure, droughts, and economic
constraints—impose increased stress on
the country's water resources and
society's ability to maintain or improve
quality water sector systems. It is
recognized that many water systems will
witness tremendous cost pressures over
the next several decades due to
increasing infrastructure, operation, and
maintenance expenses. Given current
funding mechanisms, and existing
infrastructure and system constraints, EPA,
Congress, water sector organizations and
others are concerned that a growing
number of water systems are not
sustainable in their current form. They
anticipate that the number of
unsustainable water systems will continue
to increase as new demands and costs
are realized.
In May 2006, EPA requested that the
NACEPT " Identify ways EPA can better
advance sustainable approaches to
water resource management and
infrastructure to meet watershed goals."
The report, NACEPT's Initial Findings and
Recommendations on EPA's Sustainable
Infrastructure Watershed Pillar (July 2007),
was submitted to EPA Administrator
Stephen L. Johnson offering a large set of
recommendations that fall within four
categories of specific steps EPA should
take: (1) lead by example; (2) educate,
communicate, and provide information;
(3) encourage, facilitate, and fund
collaboration; and (4) develop, use, and
fund specific tools.
In August 2007, the Agency amended
its request to NACEPT by asking that the
Council "recommend to EPA changes in
policy, outreach, internal operations,
and/or incentives and disincentives to
foster collaborative partnerships in the
water utility sector." This NACEPT report
specifically addresses this amended
request from EPA.
Regional Collaborations and Partnerships are One Possible Solution
There are numerous management, operational, financial, and technical
approaches, alone or combined, being used to address the looming financial,
environmental, and sustainability issues within the water sector. This report addresses
only one such approach; creating new regional collaborations and partnerships. By
O
-------
using this approach, water sector systems can resolve a key weakness found in
many of our nation's water systems - a profusion of discreet water utilities planned,
designed, built, operated, regulated, and managed independently of each other.
By creating a positive environment for independent, regionally-linked water
sector utilities to work more collaboratively or in partnership, utilities and their
communities can better identify, prioritize, and integrate a regional approach to
long-term water system planning and infrastructure needs. This approach not only
can reduce future water utility costs, create gains in efficiency, and limit new
infrastructure needs, it can also provide a comprehensive approach to
environmental and ecological improvement while expanding water utility and
community sustainability.
Defining a Role for EPA
EPA recognizes regional collaboration as an effective tool for improving the
long-term sustainability of water sector utilities. However, identifying the specific
function that EPA could play in promoting this approach is more challenging. The
answer is not straightforward because many of the activities needed to create
regional cooperation and partnerships lie outside the traditional roles of EPA.
This report identifies specific tasks that EPA can implement to strengthen the
framework of regional or watershed based partnerships in an effort to create
sustainable water systems throughout the nation.
B. Background
Beginning with the creation of the National Environmental Protection Act (NEPA)
in 1969 and EPA as an agency one year later, there has been a dramatic decrease
in levels of pollution throughout the United States. As this "veil of pollution" lifted and
basic understanding of environmental systems matured, the overall approach to
meeting environmental, public health protection, and ecological mandates
changed. Today, EPA uses a mix of regulatory, enforcement, mentoring, leadership,
and partnering relationships to achieve these goals.
Unfortunately, federal legislation and resulting regulation, has not kept up with
changing environmental realities. Many of the legislated requirements have created
inflexible mandates and organizational structures that can, at times, result in a
compartmentalized approach to problem solving.
EPA's current organizational structure and programs mirror the authority
provided the Agency under federal environmental legislation such as the Safe
Drinking Water Act and the Clean Water Act. Similarly, states and water utilities have
also structured their programs, functions, and organizations using the same
categories offered by EPA and the original federal legislation. Today, the water
sector includes four major areas:
• Water resources management and source water protection
-------
• Drinking water treatment and distribution
• Wastewater collection and treatment
• Wet weather management (storm water)
This approach served the nation and environment well when addressing the
large, almost insurmountable, water pollution and infrastructure challenges of the
1970s and 1980s. Major programs targeted highly polluted rivers and streams and
limited regulations to protect the public drinking water supply. This resulted in large,
federally funded infrastructure programs, such as the construction grants program
for new water pollution control plants under the Clean Water Act.
Today's Funding Gap
Today, there is growing discussion of the water sector's enormous infrastructure
and capital investment crisis. While the primary issues of concern vary across the
country and by water sector utility, increasing regulatory burdens, deferred
maintenance, a "natural" convergence of aging infrastructure demands, poor
system management, jurisdictional limitations, and new system capacity needs have
created an estimated $1 trillion funding gap between known sources of capital and
the anticipated future costs for maintaining and upgrading the nation's water,
wastewater, and storm water infrastructure systems.
When also considering new challenges posed by global climate change,
shifting and growing US populations, and their anticipated impacts on water
resources—water supplies, flooding, drought, river and lake water quality, and
changing industrial and agricultural water requirements—the future becomes even
more ominous.
As the problem has become better defined over the past decade, so has the
reality that federal, state, local, and tribal governments will be largely unable (or
unwilling) to provide the necessary funds to bridge the funding gap. Additionally,
the traditional remedy of passing these increased costs directly onto the consumer is
unaffordable in many urban and rural communities.
The EPA Response - The Sustainable Water Infrastructure Initiative
In response to growing concerns expressed by Congress, states, tribes, and
water sector stakeholders, EPA, led by the Office of Water, established a new
program called the Sustainable Water Infrastructure (SI) Initiative. EPA Administrator
Johnson noted that sustainability of the water sector "is everyone's challenge:"
"By supporting collaborations...we are working with our utility and private sector
partners to develop solutions for managing and sustaining our shared
infrastructure assets."
SI activities are organized around four priority areas:
• Better utility management
-------
• Full-cost pricing of water
• Water efficiency and conservation
• Watershed approaches to water management
Progress is being made on many fronts. For example, a group of utility experts
and executives are working with EPA on a manual entitled "Effective Utility
Management."' This manual is designed to assist utility managers with improving
their business skills, especially those skills unique to the water sector.
In addition to these activities, the Agency is moving forward with innovative
approaches to best utilize the remaining federal and state funds, especially those
available through the State Revolving Fund (SRF) program support for small systems,
including tribal set asides. For example, EPA is providing tools and technical
assistance to small water and wastewater systems to improve technical,
managerial, and financial capacities in a series of newly released EPA documents1
and programs: National Capacity Development Strategic Plan2, Analysis on the Use
of Drinking Water State Revolving Fund Set-Asides: Promoting Capacity
Development3, and The Check Up Program for Small Systems (CUPSS)4. EPA believes
that these tools will help bridge the growing financial gap faced by small drinking
water and wastewater systems as they repair and replace infrastructure.
Integrated Water Resource Planning and Watershed Management
Integrated Water Resource Planning (IWRP) is the management of water
resources over an entire watershed, providing integrated solutions to meet drinking
water, water supply, wastewater, and storm water needs and requirements. IWRP
allows communities to collaborate as they identify, prioritize, and balance resource
needs within a watershed. IWRP can be a catalyst to bring about cooperation
among the officials responsible for managing water sector systems.
The importance of IWRP was alluded to in the first NACEPT report on Sustainable
Water Infrastructure which emphasized the importance of this approach to EPA:
"...build upon and leverage its existing partnerships and alliances to promote
collaboration among water, wastewater, and storm water utilities, and industries
in a given watershed area. This would give them a more effective voice with
local decision makers and stakeholders. EPA, tribes, states, and utilities should
elucidate the benefits of working together to the many different types of
organizations that might participate in the watershed approach."
1 http://vosemite.epa.aov/water/owrccataloa.nsf/HomePaae?OpenForm&CartlD=8189-102727
2EPA#816K07003
3EPA#816R06004
4 http://www.epa.aov/safewater/cupss/index.html
o
-------
NACEPT recognizes that it is difficult to
communicate among people, agencies,
utilities, and other stakeholders when there is
no venue to articulate one's needs and
interests. IWRP, as well as utility collaboration
and partnerships, can be difficult to organize
and make successful. As stated in the first
NACEPT report on Sustainable Water
Infrastructure:
The primary recommendation of
this NACEPT report is for EPA to re-
invigorate its active support and
participation in IWRP, and for the
Agency to use Watershed-Based
Management as its organizational
foundation for supporting regional
collaboration and partnerships
throughout the United States.
"Promotion of this type of collaboration will require clear demonstration in the
local context of advantage. Without that, natural resistance to the uncertainties
of change will interfere with movement to collaboration."
Even so, as described in the next section of this report, regional collaboration
holds significant promise as a tool to remedy some of the water sector's issues of
sustainability.
Regional Collaboration is not Structural Consolidation
A word of caution is in order- regional collaboration is not the same as regional
facilities. Expanding regional facilities into new areas can promote sprawl and
encourage development in exurbia/rural areas instead of redeveloping brownfields
and other developed areas. From the first NACEPT report on Sustainable Water
Infrastructure:
"When the authors of this report speak about regional collaboration,
regionalization, partnerships, etc, we are speaking about a functional,
operational, communicative, supportive arrangement among stakeholders and
not necessarily are we promoting structural or infrastructure consolidation."
The Infrastructure Action Group of Southeastern Pennsylvania First Suburbs Project
An example of the new way of approaching water sector sustainability is being
attempted in the Philadelphia suburbs by a group of citizens, academicians, political
leaders, and clergy. They have worked to identify the biggest issues in these first-ring
suburbs and narrowed their focus to affordable housing, education, social services, and
water infrastructure. The Infrastructure Action Group of Southeastern Pennsylvania First
Suburbs Project prescribes that the goals of system regionalization and sound infrastructure
investment involve the following five principals:
• Efficiency- fix existing infrastructure before building new facilities and systems
• Fiscal Sustainability- adopt full-cost pricing policies that build future maintenance and
renewal costs into current rate structures
• Environmental Sustainability - encourage a comprehensive approach to water
management that protects water quality, conserves ground water, prevents
ecologically harmful withdrawals from rivers and streams, and coordinates infrastructure
investments with sound land use management
• Equity - water flows across municipal boundaries, therefore the cost of water needs to
be shared among all in the watershed
• Coordination - new investments should be accompanied by new institutional
arrangements for improved coordination and more efficient service delivery
-------
C. NACEPT Sustainable Water Infrastructure Workgroup
EPA Charge to NACEPT and the Phase I Report
EPA asked NACEPT to assist the Agency in advancing cost-effective and
sustainable approaches to water resource management and infrastructure to meet
water quality goals. A workgroup, a subset of the Council, was established to assist
NACEPT to respond to the charge. The full charge and additional background
material are contained in Appendix IV.
Specifically, in May 2006, EPA requested that NACEPT:
"(I) Identify ways that the EPA can better advance sustainable approaches to
water resource management and infrastructure to meet watershed goals, and
(II) Analyze the primary and secondary benefits of non-traditional, or alternative,
approaches to water infrastructure management."
The report NACEPT's Initial Findings and Recommendations on EPA's Sustainable
Infrastructure Watershed Pillar (July 2007), also known as Phase I of the charge, was
submitted to EPA Administrator Johnson offering a large set of recommendations
that fall within four categories of specific steps EPA should take. These steps include:
Lead by exam pie
Educate, communicate, and
provide information
Encourage, facilitate, and fund
collaboration
Develop, use, and fund specific
tools
In October 2007, EPA amended the charge to NACEPT, requesting that the
group focus on the current issue. Specific recommendations include:
"(II) Recommend to EPA changes in policy, outreach, internal operations,
and/or incentives and disincentives to foster collaborative partnerships in the
water utility sector."
This is in direct support of a recommendation in the first NACEPT report:
"Another opportunity is for EPA to build upon and leverage its existing
partnerships and alliances to promote collaboration among water, wastewater,
and storm water utilities, and industries in a given watershed area. This would
give them a more effective voice with local decision makers and stakeholders.
EPA, tribes, states, and utilities should elucidate the benefits of working together
to the many different types of organizations that might participate in the
watershed approach."
-------
This report deals specifically with this amended charge. However, this current
effort recommends that EPA prepare a progress report regarding actions taken in
response to the Phase I report and other actions taken or underway to move these
approaches forward within the Agency. Moreover, periodic reporting of measures of
collaborative effort success would help focus EPA headquarters and regional efforts
to support collaboration at all levels.
Approach Used for this Investigation
The NACEPT Sustainable Water Infrastructure Workgroup held a number of
meetings and conference calls to gain an initial understanding of the charge from
EPA, as well as to understand current approaches and activities within the Agency.
It also met with stakeholders from professional water organizations, private
consultants, and utility mangers to learn about perceptions, activities, and plans. In
addition, one-on-one interviews were held with various state, tribal, local, non-profit,
and private groups from around the country. Significant reference resources
became available to the group from various sources. This information was used to
inform the Workgroup during its reflections, deliberations, and writing of these
recommendations. Appendix II lists the experts brought in to speak with the
Workgroup and Appendix V provides the list of references.
-------
This page left intentionally blank.
O
-------
II. KEY QUESTIONS ANSWERED
This section uses a question and answer format to address some of the issues
raised during the NACEPT Sustainable Water Infrastructure Workgroup investigation
on regional collaboration and the role EPA plays.
A.
NACEPT met with experts involved with inter-organizational partnership, utility
management, and regulatory compliance and reviewed many case studies and
examples of successful regional utility collaborations.
In its most simplistic form, regional collaborations are a partnership between two
or more utilities to form cost-sharing agreements in order to more effectively provide
services. Many utilities today utilize some form of these partnerships or agreements.
Examples include:
" Purchase equipment, chemicals, office supplies, etc.
" Contract services for engineering, operations, billing, call center
management, meter reading, training, etc.
* Provide mutual aid in case of drought, flood, terrorism, or other emergencies
* Consolidate infrastructure by constructing physical interconnects
" Consolidate and centralize management
These cost-sharing agreements can be very effective tools, especially for small
water sector utilities. However, this form of partnership does not address the
structural sustainability issues described earlier. That is, for water sector utilities to
become sustainable, they must operate within the context of a sustainable system.
This can only be accomplished when the collaborative approach is used within the
context of Integrated Water Resource Planning or a watershed management
approach. Under this definition of regional collaboration, water sector utilities would
be working with regional stakeholders to:
" Develop comprehensive, regional assessments and plans to tackle the
infrastructure, ecological, and economic needs within the watershed or
region
* Address regional issues of water resources, environmental regulations, and
community sustainability
* Influence policy, legislation, regulation, and financial aid on federal, state,
tribal, and regional levels
* Provide broad education, communication, and/or outreach efforts
* Prioritize environmental projects on a regional basis
Conclusion: EPA should restructure and align its programs to more effectively promote
Integrated Water Resource Planning and watershed management as the key building blocks
that communities can use to ensure the sustainability of the nation's water infrastructure.
-------
B. Are there indicators that would help EPA identify the types of
utilities that would benefit from such collaborations?
NACEPT was asked if there were any specific utility characteristics or indicators
that would help EPA identify utilities that could benefit from collaborative, regional
efforts. In particular, it was hypothesized that small systems would be especially
good candidates for region a lization for demographic, resource, and financial
reasons. While results indicate that small systems represent an important subset of
utilities that would benefit from the regional collaborative approach, NACEPT found
the applicability of this approach to be significantly broader.
NACEPT also found that there are many reasons why a utility may want to
consider a collaborative, regional approach to watershed management, and that
multiple categories of utilities may be well served by a partnering relationship.
Characteristics of utilities that would particularly benefit from collaborative
approaches include:
• Customer Demographics
Water systems serving small customer bases
Systems anticipating or experiencing significant growth/decline in
population
Affordability, driven by a low per capita income
• System Revenues
Systems with revenues unable to support adequate staffing
Utilities unable to recover operations, maintenance, and capital
expenditures
• Regulatory Program Burdens
Combined Sewer Overflow/Sanitary Sewer Overflow (CSO/SSO)
communities limited by affordability considerations
Phase II Municipal Separate Storm Sewer System (MS4) (i.e., a separate
storm sewer system) without sufficient resource capacity for its
management structure or revenue base
Wastewater systems experiencing compliance concerns due to permit or
consent order restrictions; or that are discharging to impaired water
bodies where Total Maximum Daily Loads (TMDLs) are required
Water systems experiencing compliance concerns such as:
Arsenic, trihalomethanes (THMs), chlorination, lead, cryptosporidium
• Resource Limitations
Insufficient water supply, resources, or impairments
Repeated or prolonged droughts, system reliability, water quality,
vulnerable supplies, competition, environmental restrictions, climate
change, increased flooding, or significant population shifts
Growing communities with septic systems or other decentralized systems
without sufficient infrastructure or management support
©
-------
• Jurisdictional and Geographic Constraints
Systems that are limited by political, geographic, or infrastructure
constraints may be great candidates for collaborative efforts if these
limitations can be addressed and overcome
Systems that are impacted by out-of-jurisdiction upstream
activities/development/ water withdrawals
Conclusion: By creating a positive environment for regionally linked water sector utilities to work
more collaboratively, EPA can help utilities and their communities create efficiencies and
integrated systems that are more sustainable and benefit the community in multiple ways.
C. What do successful regional collaborations have in common?
NACEPT found that successful regional collaborations typically exhibit four
common attributes:
• There is a leader who recognizes that some critical needs, issues, or challenges
are beyond the community's or utility's ability to control or resolve
independently.
Typical drivers include utility-specific problems or larger regional problems
such as population growth, growing infrastructure costs, transportation
needs, environmental protection, education, or community development.
Awareness of these issues may have been generated within the utility (by
management or board members) or externally (by local government
officials or policy makers).
In rural watersheds, with smaller utilities and limited staff, an outside agent
(e.g., local, regional, or non-profit) was often instrumental in initiating
awareness and organizing partnerships.
• There is some motivating factor—such as a financial incentive, compliance
penalty, drought, or flood—that encourages the utility to consider solutions
outside its traditional boundaries.
Existing funding sources are unable to meet system needs and new
increases in revenues are unacceptable or unaffordable to the
community.
There are new incentives in the form of federal, state, tribal, and local
grants, matching funds, new revenues, profits, or other monetary
incentives that reward the collaborative approach.
Even relatively small dollar amounts available for planning beyond
immediate system needs help encourage collaborative efforts.
Regulatory requirements or enforcement actions, when used with
innovative direction, can encourage regional collaboration. However, if
not used carefully, they can also inhibit broader discussions and regional
solutions.
Drought, other natural or manmade resource challenges, or other crises,
provide a short-term opportunity to open discussions among regional
players.
Longer-term issues that are on the minds of citizens such as climate
change, water security, aging infrastructure, sprawl, energy, population
growth, or affordability concerns can help motivate localities to consider
collaborative options.
©
-------
• There is a safe, neutral venue where regional stakeholders can congregate,
discuss shared regional visions and goals, and explore solutions that address all
potential issues, costs, and benefits.
There is typically a strong leading partner, whether a utility manager or
board member, an elected local policymaker or administrator, or
community leader who can champion regional solutions among the
stakeholders.
There is typically recognition among the stakeholders that they share a
common resource and that the use of this resource affects others.
There is either a history of, or a desire for, working across political
jurisdictions, between government, business, and non-profits, and across a
wide range of issues.
• The collaboration process should ultimately result in a written agreement.
For the collaborative process to work it must ultimately result in a written
agreement, which can take time.
If there are EPA or state impending enforcement actions, inflexible
regulatory timeframes, or mounting penalties, water sector systems
typically make quick, bad investment decisions to reduce overall costs
and risks. This may inhibit innovation and outside-the-box thinking that
could result in better and more cost effective solutions.
Conclusion: EPA can encourage the collaborative process by: (1) helping utility and
community leaders recognize their long-term local needs; (2) providing incentives to motivate
groups to work together; (3) creating a safe, neutral venue where EPA can act as a credible
convener of stakeholders; and (4) allowing some regulatory flexibility in schedules and penalties
to accommodate collaborative partnerships that lead to better or equivalent environmental
results.
D. What are the barriers to collaboration?
NACEPT identified several significant barriers at the federal, state, tribal, local,
and utility level that may inhibit or prevent water sector systems from moving
forward with collaborative partnerships.
• Individual and Organizational Barriers
Unaware of potential advantages. In the absence of a perceived benefit,
collaborative opportunities are not pursued.
No perceived need for change. Operations, reliability, and costs may
present no current issues; longer-term capacity and sustainability
concerns may be left unaddressed. Alternatively, line management may
be so intently focused on current issues and operational problems, that
there may be little capacity to consider utility sustainability.
Budget cycles. Budget cycles and planning horizons may inhibit or
discourage collaborative approaches which often are time consuming
and on different timeframes than local government political and
budgetary cycles.
Concerns over loss of local control. Unknown risks, costs, and a perceived
(or real) loss of independence, influence, oversight, or control over
policies, budgeting, hiring, decision making, risk management, and rates
©
-------
may deter utility managers or the local community from considering
collaborative options.
• Regional and Jurisdictional Issues
Water rights. There may be concern that collaborative partnerships may
lead to a forced sharing of water rights and potential shortfalls of
available water for one system to the benefit of another.
States' Board of Public Utilities. Many states have utility boards that
regulate pricing for non-municipal water sector utilities. The political,
technical, and economic complexities of some collaborative agreements
can make bringing such matters before a state utilities board daunting.
The state board may become a barrier to even exploring the idea of
collaboration without a clear understanding of the process and a clear
concept of the benefits that might result.
Regional dynamics. Neighboring jurisdictions—whether they are states,
counties, municipalities, or school districts—often have political,
demographic, historical, economic, or community-based rivalries (i.e.,
sports) that make it difficult to develop trust and equity among parties.
Using water as a regional planning tool. The availability of water to
promote or limit growth is an unfortunate reality in many communities.
Without the availability of alternate community planning mechanisms,
water is often a political tool that inhibits the formation of regional
collaborations due to competing local interests and the lack of clear
understanding of the benefits of collaborative approaches.
• Lack of Enterprise Funding
The true cost of water service is a fundamental component of sustainable
water resource systems. Many communities rely on a portion of water
sector revenues as financial support for other municipal services, or for
their general fund. In other instances, such as storm water management,
the cost of water sector services is hidden in the general real estate tax
base. Lack of an enterprise fund based on the true cost of service
confounds collaborations that involve cost or revenue sharing. In addition,
potable water is heavily subsidized and consumers do not pay the full
costs of supply and delivery, which reduces revenues and in some cases
negatively affects management approaches and potential collaborative
efforts to promote conservation and efficient management approaches.
Similarly, apprehension about agreements with existing bondholders and
solutions for handling unequal debt, particularly if the debt is municipal,
may hinder the exploration of collaboration.
• Limited Ability of Regional Stakeholders to Take a Holistic View
Success in establishing collaborative partnerships depends on individuals
who can imagine the advantages of regional sharing of service
responsibilities and the benefits reaped because of the partnership.
Conclusion: Many barriers to regional collaboration are outside the boundaries of traditional
EPA approaches to resolution. For EPA to be effective in this arena, the Agency will need to
consider significant new organizational directions such as those described in the NACEPT
Report, Everyone's Bus/ness: Working Towards Sustainability Through Environmental Stewardship
and Collaboration5. Key recommendations include that EPA should: (1) reframe its mission with
' http://www.epa.aov/ocem/nacept/reports/pdf/2008-0328-evervones-business-final.pdf
©
-------
stewardship as the unifying theme and ethic; (2) strive to become the world's premier
stewardship model and catalyst by integrating regulatory programs, grants, voluntary
partnerships, information, in-house operations, and other tools into a common framework; (3)
foster stewardship by providing leadership in collaborative governance and participating in
partnerships organized by others; (4) systematically invest in the skills and competencies
necessary for the Agency's domestic and global leadership in environmental stewardship; and
(5) drive the ethic and practice of stewardship deep into the culture of the Agency.
E. What can EPA do to promote, encourage, and support water
integrated resource planning, watershed management.
regional collaboration, and a sustainable water sector?
EPA needs to take a broader perspective on how water sector utilities are
planned, managed, and regulated. EPA needs to connect and, in many cases,
reconnect with grassroots organizations to support collaborative efforts by
communities to consolidate resources and thereby improve the benefits and cost
effectiveness of integrated approaches to managing drinking water, wastewater,
and storm water resources. To accomplish this collaboration, EPA should take
advantage of the opportunities provided by other federal, state, tribal, regional,
and local agencies, as well as non-governmental organizations (NGOs), to break
down parochial barriers and build consensus within neighboring communities.
Conclusion: EPA needs to be a leader, visionary, motivator, catalyst, mentor, partner, financier,
peer, supporter, and facilitator in strong support for the water sector and other stakeholders to
use an integrated, watershed-based approach that explores regional collaborative
opportunities to develop sustainable, water resource management solutions. EPA needs to
assist with guidance, encouragement, and education; recognizing and rewarding those who
are successful, and help to move forward regional partnerships.
-------
RECOMMENDATIONS
The National Advisory Council for Environmental Policy and Technology
(NACEPT) recommends the following.
Action: EPA needs to more fully adopt Integrated Water Resource Planning and
Watershed Management as the governing framework for Office of Water (OW)
regulations and policy. Increased demands on the nation's water resources—
whether due to population growth, pollution, regulations, recreational and fish and
wildlife concerns, competing water needs from energy, agriculture or industry, or
climate change—will continue to place pressure on the water sector to find new,
more sustainable business strategies. Since most of these issues involve stakeholders
and resources outside the control of the local water sector utility and its local pipe
network, a collaborative, watershed-based approach to problem solving will be
necessary.
This situation is complicated by a community of water systems not well
configured to address multi-media environmental concerns, or even issues involving
the entire water cycle within its jurisdiction.
In order for EPA to support the sustainability of the water infrastructure system,
whether through regional collaboration or other methods, the Agency will need to
move fully and quickly to a new water resource management strategy. This resource
management strategy should endorse, encourage, and ultimately require water
sector stakeholders to take advantage of all opportunities for coordinated regional
or watershed-based collaboration, planning, operations, and management.
Action: The EPA Office of Water should revisit opportunities to integrate across its
programs. There are tremendous opportunities for the water sector to begin to work
across its four segments - drinking water, water resources, wastewater
management, and storm water management. Examples include:
* Integrating drinking water source protection rules for contaminants such as
cryptosporidium with water quality standards and controls under the Clean
Water Act.
* Expanding the "green infrastructure" strategy, which has great potential and
enormous support for storm water management, into other aspects of water
resources management such as wastewater, CSOs, Storm water Phase I and II
programs and Capacity, Management, Operations, and Maintenance
(CMOM).
* Reintroducing Section 208 of the Clean Water Act, redesigning the program
for watershed-based Integrated Water Resource Planning, and creating
financial (e.g., SRF) incentives for collaborative watershed based planning
and infrastructure funding.
-------
Action: EPA should ensure that federal agencies provide a coordinated effort
when addressing major regional water issues. EPA should work to ensure clear
communication and coordination with other federal agencies that have
programmatic responsibilities that may impact the water sector (e.g., the US Forest
Service, US Army Corps of Engineers, Bureau of Land Management, National Park
Service, Fish and Wildlife, Federal Highways, Department of Defense, and Natural
Resources Conservation Service). Where possible, the Agency should assume a
leadership role.
Action: Regional EPA offices should expand their watershed-based programs
and resources to support local dialogue. Each of the ten regional offices should
increase its capacity to support local and regional dialogue and facilitation, thereby
encouraging stakeholders to meet, discuss, and solve common environmental and
infrastructure sustainability issues. Where this is not immediately possible due to
resource or political concerns, EPA should enlist the support of local foundations or
non-profit organizations to fill this void.
EPA needs to return to its original central tenet for water sector policy: Comprehensive Planning
for Total Water Management. During the 1970s and 1980s, EPA focused many of its efforts on
improving the water environment by requiring the development of Clean Water Act Section
208 Regional Water Quality Management Plans. These plans encouraged citizen-group
participation and comprehensive watershed planning to assist federal, state, tribal, regional,
and local decision makers to focus on priority water quality issues, and provide local input and
guidance to overall water quality programs.
At that time, the Section 208 process had three significant shortcomings: (1) it was developed
prior to the emergence of citizen-based watershed groups and therefore generally did not
include significant stakeholder input; (2) although the process allowed for the identification of
all sources of pollution, the process was generally limited to EPA's primary concerns - point
source dischargers; and (3) there was neither a mandate nor long-term funding for
implementation of the Section 208 plans.
Today, the stakeholder partnerships imagined decades ago under Section 208 have come to
fruition in the form of hundreds of watershed groups across the nation. In addition, the total
water management concepts of Section 208 fit well with today's focus on a collaborative
watershed approach to comprehensive total water management. Section 208 deserves serious
consideration as a viable mechanism that could be reinvigorated based on today's
challenges to foster collaborative watershed-based infrastructure planning.
Recommendation #2: Encourage the collaborative process
Action: EPA needs to offer more support to local and regional collaborative
efforts. Often, the best role for EPA is supportive, not directive. EPA needs to get
more involved in regional planning issues, especially identifying where there is
crossover between community issues and water sector needs.
In Southeastern Pennsylvania, the Resource Conservation and Development Council (RC&D) is
seeking funds from EPA and others to assist six municipalities with a pilot cooperative program
to develop economically feasible options for dealing with storm water management issues,
including current MS4 and upcoming TMDL requirements. These municipalities are highly
urbanized, and relatively small. They have severe technical and economic constraints when
-------
dealing with storm water related regulatory requirements and other activities identified in
regional watershed plans. The total cost for this project is $2 million dollars. Clearly, federal
support from EPA is needed to implement technical transfer and provide regulatory flexibility.
This pilot program provides significant examples of collaborative strategies for communities in
similar circumstances.
Action: EPA regional offices should offer local groups support with identifying
and procuring safe, neutral venues where stakeholders can meet. Strong
collaborative efforts often start at the grassroots level. These individuals or
organizations require a safe, attractive, and neutral venue that encourages
stakeholders to attend meetings and hold open and honest dialogue. EPA should
recognize and embrace this basic requirement of collaboration by facilitating
logistical and other resource support for states, tribes, NGOs, and local groups to
meet.
Action: EPA regional offices should offer local groups support for identifying and
training effective, respected leaders. Every collaborative effort requires effective,
respected leadership. Identifying an individual or organization that is highly
regarded in the community who can broker, facilitate, organize, and direct the
collaborative process is critical when building successful collaborations. EPA should
recognize and embrace this basic requirement of collaboration, and provide the
capacity and resources to reach out to local groups as well as provide leadership
training using effective practices gleaned from successful partnering examples.
Action: EPA should help water sector utilities and leaders to recognize their long-
term sustainability interests and needs. Strong leadership is required to ensure that
EPA program managers are encouraged to maintain a collaborative facilitator role.
Good recent examples of water sector utilities and stakeholders working together for
long-term sustainability include the Chesapeake Bay Program6 (Region 3), the
Schuylkill Action Network7 (Region 3), and the Mystic River Workshop8 (Region 1).
For example, a major effort is underway to improve the Schuylkill River and its
tributaries by the Schuylkill Action Network (SAN), a national leader in collaborative
watershed protection. The SAN is a group of more than 60 government, business,
and non-profit partners convened by EPA to tackle the challenges in restoring the
river. With guidance from EPA Region 3 and the Philadelphia Water Department, the
SAN has grown from four members in 2003 to over 200 members today -
representing government agencies, local watershed organizations and land
conservation organizations, businesses, universities, water suppliers, and citizens. SAN
members use the network to coordinate activities, pool resources, promote policy
changes, and implement priority projects that protect and improve the water
resources of the Schuylkill River- a source of drinking water for over 1.5 million
people in Southeastern Pennsylvania.
6 http://www.chesapeakebav.net
7 http://www.schuvlkillactionnetwork.ora
8http://www.epa.aov/reaion1 /mvsticriver/basicinformation.html
o
-------
The SAN provides an effective means of exchanging new information among a
diverse and large audience. It promotes efficient implementation of measures
intended to protect and improve the Schuylkill watershed. For these reasons, the
SAN is good model of how EPA can support water utilities and other leaders in
recognizing, and addressing, their long-term sustainability interests and needs.
EPA should strengthen its position as a partnering agency for purposes of
enhancing all of its programs, both regulatory and non-regulatory. More effective
partnering is particularly important for non-regulatory programs where voluntary
action, based on trust, assistance, and persuasion is fundamental. This
recommendation is from the National Academy of Public Administration for EPA,
April, 2007: Taking Environmental Protection to the Next Level9.
Action: EPA should establish a Sustainable Water Resources Stakeholder
Advisory Group to assist EPA in the planning and the implementation of the
recommendations in this report. This could be done through NACEPT. EPA would
benefit from a forum of stakeholders that would be able to provide perspective and
feedback about the recommendations contained in this report and others. An
important activity that could be carried out with the assistance of such a group
would be the development of an action plan and a schedule of implementation.
Participation by respected stakeholders in this level of planning could be expected
to enhance credibility and acceptability to the activities that emerge from the
process, thereby increasing the probability of widespread participation. The impacts
of implementation of the recommendations will increase significantly with the
support of key stakeholders, such as business and environmental leaders and
government officials who are integrally involved in land-use policies and programs.
The nature and longevity of the advisory group would depend on EPA procedures
and the confirmed value of the advice provided.
Recommendation #3: Provide new economic incentives
Action: EPA needs to strengthen its public message on the need for additional
federal funding for water sector initiatives, whether under the banner of the
infrastructure crisis, water system security, research and development, water
resource planning, or water quality. In an effort to reverse the trend of declining
federal financial support for the water environment, EPA needs to work with the
water sector professional organizations to explain the coming crisis in water
infrastructure sustainability.
Financial incentives are on the decline. In the past decade, Community Based Environmental
Protection Watershed Teams have been eliminated from EPA regional offices. Smaller funding
programs and other incentives used by local groups such as the Regional Geographic
Initiatives and 104(b)(3) grants have also been eliminated. Larger Targeted Watershed Grants
have replaced smaller watershed programs better suited for local collaborative efforts with
watershed groups. In 2007, ten Targeted Watershed grants were awarded, but only two last
year.
http://www.napawash.org/pc management studies/EPA Summary Report 5-17-07.pdf
-------
Action: EPA should work to identify and establish new financial incentives to
encourage water sector systems to investigate regional collaboration opportunities.
Although there are very limited funds available for existing financial incentive
programs such as the Drinking Water State Revolving Fund (DWSRF) and the Clean
Watersheds State Revolving Fund (CWSRF), there may still be opportunities to
leverage these funds to encourage collaboration. Opportunities include:
• Provide technical assistance to states and tribes based on accessing the 15
percent DWSRF or tribal set-asides to support regional collaboration efforts. For
the CWSRF regional facility planning grants, EPA should work to provide a
similar dedicated funding stream.
• Encourage states to use a system similar to the Texas Intended Use Plan (IUP)
Program to create collaborative incentives.
Texas uses the EPA IUP ranking process to award infrastructure projects additional "ranking
points" for regionalization and consolidation. This can be a very powerful incentive, especially
since the CWSRF and DWSRF are currently oversubscribed and underfunded. However, these
projects are typically offered to the SRF boards for ranking near the completion of the design
process and not during the concept/planning period.
Action: EPA should renew Section 208 grant funding. The Section 208 process
appears particularly well-suited to re-join the EPA toolbox of financial and regulatory
incentives to encourage the watershed approach.
Section 208 Plans. EPA should reinvest in comprehensive watershed management planning
and foster collaborative partnerships between utilities and all other stakeholder groups in the
watershed as initially envisioned by Section 208. Non-profit citizen watershed groups in
partnerships with utilities have demonstrated a greater potential to leverage dollars from a
multitude of sources and use the watershed planning process as a means to develop wide
consensus within communities. The implementation of these plans will result in healthier
watersheds and lower costs for water and wastewater utilities over the long term.
Recommendation #4: Provide new regulatory and policy incentives
The use of consent orders, penalties, and other enforcement actions often shuts
down communication and collaboration. As a result, reactive investment decisions
can be made by water sector system administrators that are not sustainable in the
long run. Care must be taken by EPA to provide the time to engage the regional
stakeholders and determine if alternative watershed-based solutions exist.
Action: EPA should work to identify and establish regulatory and policy flexibility,
which would encourage water sector systems to explore integrated watershed
management and regional collaborative opportunities.
• An excellent example of EPA following this approach is the March 5, 2007
memorandum from Ben Grumbles to EPA Regional Administrators on using
Green Infrastructure to Protect Water Quality in Storm Water, CSO, Non-point
Source, and other water programs.
• Provide regulatory flexibility and relief to utilities that provide a mentorship
program to other systems in the same watershed.
-------
Colorado proposes a utility mentorship program. Colorado is proposing an Environmental
Results Program (ERP) for the National Pollution Discharge Elimination System (NPDES) municipal
wastewater dischargers. In exchange for a less expensive and less difficult permitting,
compliance, and inspection process, a large utility system can establish a mentorship program
with a small system. The ERP elements require that: (1) the state develops baseline compliance
and establishes performance metrics; (2) the facility self-certifies compliance; (3) the
enforcement agency conducts statistically-based, random audits/inspections to evaluate
overall compliance for the sector, and takes enforcement actions as necessary to address
compliance issues; and (4) the large facility provides mentoring to at least one NPDES minor
wastewater discharger to help it improve compliance.
Action: Use enforcement tools to encourage collaboration. EPA should explore
regulatory and policy changes that can "legitimize" integrated watershed
programs. EPA should create an opportunity for utilities to gain deference—or
primacy—from regulatory programs in both permitting and enforcement activities if
they are pursuing a strong, collaborative, watershed approach to regional problem
solving.
EPA should investigate the creation of a certification process which gives the
Agency "reasonable confidence" that a utility's planning and investment objectives
are recognized as delivering multiple environmental and community benefits. These
benefits transcend narrow compliance objectives over limited timeframes.
Action: Provide flexibility in enforcement and permitting schedules. EPA should
reward rather than inhibit communities that are moving forward with regional
collaborative solutions.
• Provide the time and support necessary for communities to achieve their
broad environmental and sustainability goals.
• Recognize that the standard 5-year permit cycles, 15-year consent orders,
and drinking water Maximum Contaminant Level (MCL) schedules may not
provide sufficient time to invest fully in collaborative approaches to problem
solving.
• Pursue regulatory and voluntary approaches that use adaptive management
principles coupled with the necessary evaluation and assessment processes to
ensure that progress is occurring.
• Provide flexibility for municipalities facing storm water Phase II regulations to
form regional storm water utilities (perhaps in collaboration with local water
and/or wastewater utilities) in order to share costs and implement
comprehensive storm water management planning.
• Synchronize monitoring, reporting, and permitting schedules to facilitate a
watershed-based program delivery. Many states have already moved in this
direction. EPA should convene a workgroup to assess how these programs are
working, how to institutionalize watershed-based practices, and how to
develop incentives for state and tribal participation.
O
-------
Recommendation #5: Reduce internal barriers
Action: Re-visit EPA's organizational structure to reduce internal barriers. EPA is to
be commended for the significant strides it has already made in support of
watershed management and system collaboration, but much more is needed. Part
of the challenge for EPA has been that its legislative and regulatory mandates inhibit
its organizational, resource, and bureaucratic abilities to focus on its broader
environmental, public health, and sustainability goals.
Action: Focus policies, activities, and resources away from single-media, single-
issue programmatic goals. Instead, use the broader, more collaborative watershed
approach as the unifying theme and ethic.
• Reaffirm, to staff and the public, the Agency's top-down policy commitment
to collaborative watershed management through memos, speeches, policy
statements, directives, activities, resource allocations, and actions.
• Regularly and systematically grow collaborative partnership activities and
programs. As a benchmark, each regional office should initiate five new
collaborative processes each year.
• Re-direct human and financial resources to encourage and support regional
collaborations. Such collaborations should become the Agency standard
rather than an exception.
• Replicate existing models and programs that have successfully integrated
regulatory programs, grants, voluntary partnerships, information, technology,
and other tools.
• Create new pilot programs that integrate various EPA programs and
encourage watershed stakeholders to work together to solve environmental,
ecological, and sustainability goals.
Action: Detail enforcement staff to work in collaborative settings. Assign
additional Office of Enforcement and Compliance Assurance (OECA) staff to a non-
enforcement role in regional collaboration initiatives. EPA can increase the cross
training of staff in this vital activity. Enforcement personnel have a lot of knowledge
and experience to offer stakeholders.
Recommendation #6: Provide better technical guidance.
education, and outreach
Action: Review the existing body of literature and programs. Update,
consolidate, and streamline the information. If necessary, conduct research and
gather new information. There appears to be no significant level of effort, within
EPA, to summarize, publicize, or promote existing information on regional
collaboration approaches to water sustainability even though there is an
abundance of information and educational tools (i.e., reference documents,
training materials, webcasts, etc.). Many of the existing collateral tools were
developed through funding or participation by EPA. NACEPT recommends that any
necessary research focus on determining the energy-related benefits of integrated
-------
water resource planning, watershed, regional, and green infrastructure approaches,
including the energy related benefits of regional and integrated approaches as
they relate to infrastructure design, the use of decentralized systems, regional water
supply management, materials selection, operation and maintenance and pollution
prevention strategies.
Action: Partner with water sector professional organizations to create new, utility-
focused initiatives in education, communication, and outreach.
• Develop peer-based water sector utility workshops that promote the use of
tools currently available that demonstrate regional collaborative solutions and
provide detailed examples of successes in regionalization.
• Develop a utility decision-making "toolbox" to evaluate the opportunities and
challenges of regional solutions.
• Create new tools specifically designed for small systems, including model
agreements/arrangements to spur discussion and illustrate the possibilities.
Action: Partner with watershed stakeholder organizations to create a new
"sustainable watershed" initiative through education, communication, and
outreach. Like the water sector utility, in order for other stakeholders to get involved
in regional collaborative discussions and agreements, local politicians, homeowners,
institutions, planners, farmers, industry, and other stakeholders need to understand,
"What is in it for me?" EPA should educate and demonstrate to these stakeholders
that the political, economic, and social barriers are worth overcoming in order to
create a more financially and environmentally sustainable community.
Action: EPA should revise its Web site to align with the watershed and regional
collaboration approach. EPA should revise its Web site to align with the watershed
and regional collaboration approach. During this revision, the Web site design needs
to be more user-friendly and easier to navigate.
Action: Create an accessible, centralized, Web-based repository of tools and
resources. EPA should cross-reference available tools (including the incorporation of
the aforementioned "toolbox") and categorize them by media type, file format,
interactive functionality, etc. Access needs to be simple and flexible to maximize its
use. EPA should incorporate links to external sites that provide additional tools from
other key stakeholders.
Action: EPA should train and educate its regional offices, states, and tribes on
these tools and methods so that a clear and consistent message is communicated
to the water sector and other stakeholders from policy makers and regulators.
Action: EPA should re-deploy staff to increase dialogue and face-to-face meetings to
determine how to promote the long-term sustainability of systems effectively on a local level.
-------
APPENDIX T: SUSTAINABLE WATER INFRASTRUCTURE WORKGROUP
MEMBERS AND ACKNOWLEDGEMENTS:: v:::: [
Mr. Jeff Crane
Executive Director
Colorado Watershed Assembly
Hotchkiss, CO
Mr. Clayton Matt
Department Head
Natural Resource Department
Confederated Salish and Kootenai Tribes
Pablo, MT
Mr. William Mullican
Deputy Executive Administrator
Texas Water Development Board
Austin, TX
Mr. Howard Neukrug
(NACEPT Workgroup Chair)
Director
Office of Watersheds
Philadelphia Water
Philadelphia, PA
Ms. Arleen O'Donnell
Board of Directors
Massachusetts Environmental Trust
Boston, MA
Mr. Harrison Rue
Executive Director
Thomas Jefferson Planning District
Commission & Charlottesville-Albemarle
Metropolitan Planning Organization
Charlottesville, VA
Dr. Dan Watts
Executive Director
New Jersey Institute of Technology
University Heights
York Center for Environmental Engineering
and Science
Newark, NJ
EPA of
Mr. Andrew Crossland
Office of Water
U.S. Environmental Protection Agency
Mr. Robert Goo
Office of Water
U.S. Environmental Protection Agency
Mr. John L. Howard, Jr.
NACEPT Chair, Jan. 2006-Jan. 2009
Partner
Vinson & Elkins, LLP
Erik Meyers
NACEPT Interim Chair
Vice President
Sustainable Programs
The Conservation Fund
Ms. Sonia Altieri
U.S. Environmental Protection Agency (1601M)
Office of Cooperative Environmental
Management (OCEM)
1200 Pennsylvania Avenue, NW
Washington, DC 20460
Tel. (202) 564-0243
altieri.sonia@epa.gov
Ms. Suzanne Goss
Government Relations
JEA (electric, water, sewer)
Jacksonville, FL
-------
Acknowledgements
NACEPT thanks the members of the Sustainable Water Infrastructure Workgroup,
especially Howard Neukrug who devoted many hours as the Workgroup Chair. We
would also like to express our gratitude to experts from the water sector--including
Ralph Jones, Bruce Tobey, Dominick DiGangi, Normand Labbe, Jackie LeClair, Peter
Shanaghan, John Cromwell, Ken Kirk, Tom Curtis, and Dave Clark - who provided
invaluable perspectives relevant to our charge. And we thank Andy Grassland and
Robert Goo from EPA's Office of Water for guiding the Workgroup throughout this
effort. NACEPT acknowledges the outstanding support we received from Rafael
DeLeon, the Director of the Office of Cooperative Environmental Management
(OCEM) and his staff, including Megan Moreau, and especially the Council's
Designated Federal Officer (DFO), Sonia Altieri.
-------
APPENDIX II: EXPEITTRESENTERS
Ma me
Ralph Jones
Bruce Tobey
Dominick
DiGangi
Normand Labbe
Jackie LeClair
Peter
Shanaghan
John Cromwell
Ken Kirk
Tom Curtis
Dave Clark
Organization
The Cadmus Group
Massachusetts Municipal Association
Greater New Haven Water Pollution
Control Authority
Southern Maine Regional Water Council
EPA Region 1
EPA Office of Ground Water and Drinking
Water
Stratus Consulting
National Association of Clean Water
Agencies (NACWA)
American Water Works Association
(AWWA)
Rural Community Assistance Partnership
(RCAP)
www.cadmusgroup.com
www.mma.org
www.gnhwpca.org
www.epa.gov/region01/
www.epa.gov/safewater/
www.stratusconsulting.com
www.amsa-cleanwater.org/
www.awwa.org/
www.rcap.org/
-------
This page left intentionally blank.
-------
APPENDIX
AWWA
CMOM
CSO/SSO
CUPSS
CWA
CWSRF
DWSRF
EPA
ERP
IUP
MCL
MS4
NACEPT
NACWA
NEPA
NGO
NPDES
OECA
OW
RC&D
RCAP
SDWA
SI
THMs
TMDL
WRDA
LIST OF ACRONYMS
American Water Works Association
Capacity, Management, Operations and Maintenance
Combined Sewer Overflow / Sanitary Sewer Overflow
Check Up Program for Small Systems
Clean Water Act
Clean Water State Revolving Fund
Drinking Water State Revolving Fund
US Environmental Protection Agency
Environmental Results Program
Intended Use Plan
Maximum Contaminant Level
Municipal Separate Storm Sewer System
National Advisory Council for Environmental Policy and
Technology
National Association of Clean Water Agencies
National Environmental Protection Act
Non-Governmental Organization
National Pollution Discharge Elimination System
Office of Enforcement and Compliance Assurance
EPA Office of Water
Resource Conservation and Development Council
Rural Community Assistance Partnership
Safe Drinking Water Act
Sustainable Water Infrastructure
Trihalomethanes
Total Maximum Daily Load
Water Resources and Development Act
-------
This page left intentionally blank.
-------
APPENDIX IV: CHARGE TO NACEPJ
Background
The EPA Administrator has identified Sustainable Water Infrastructure (hereafter
referred to as Sustainable Infrastructure (SI)) as one of the Agency's highest priority
initiatives. In January 2003, the Administrator convened a Forum - Closing the Gap:
Innovative Responses for Sustainable Water. At this Forum, the Assistant Administrator
for Water highlighted the "Four Pillars of Sustainable Infrastructure"-- Better
Management, Full-Cost Pricing, Water Efficiency, and Watershed Approaches to
Protection (hereafter referred as the Watershed Pillar). The SI initiative aims to
decrease the gap between growing infrastructure (drinking water plants, piping,
etc.) needs and spending, by promoting sustainable infrastructure through the four
Pillars.
This charge is being developed to address the challenges specific to the
Sustainable Infrastructure (SI) Watershed Pillar. The goal of the Watershed Pillar is to
enable utilities (i.e., drinking water and wastewater) and other stakeholders (e.g.,
local and State agencies, Tribal Governments, local planning and ordinance
organizations, environmental advocacy groups, watershed decision makers) to take
advantage of opportunities offered by watershed approaches to minimize
infrastructure cost and/or operating and maintenance expenses to achieve water
quality and quantity and human health protection goals.
One of the most critical challenges facing the Nation is how to sustain our water
and wastewater infrastructure to ensure that the public can continue to enjoy the
environmental, health, social, and economic benefits that clean and safe water
provide.
Our wastewater and drinking water systems are aging, with some system
components older than 100 years. Our growing and shifting population requires
investment for new infrastructure and maintenance of existing infrastructure. Current
treatment strategies and technologies may not be adequate to address emerging
issues, investment in research and development has declined, and the prospects for
continued large federal investment are limited.
EPA's Clean Water and Drinking Water Infrastructure Gap Analysis (2002)
estimated that if capital investment and operations and maintenance remained at
current levels, the potential gap in funding between 2000 and 2019 would be
approximately $270 billion for wastewater infrastructure and $263 billion for drinking
water infrastructure.
-------
Meeting these challenges requires a multi-faceted approach to managing and
sustaining our infrastructure assets. The Nation must change the way we manage,
view, value, and invest in our water infrastructure. This can only come about if all
parties embrace a collaborative approach that encourages new and innovative
solutions to the challenges we all face. All levels of government and the private
sector have a shared responsibility for seeking effective, efficient, and fair solutions
for sustaining our precious water infrastructure.
Through collaboration with all key stakeholders, the use of effective and
innovative approaches and technologies, and a commitment to long-term
stewardship of our water infrastructure, we can make better use of our resources,
potentially reduce the funding gap and move the Nation's water infrastructure
down a pathway toward sustainability over the next fifteen years. For example,
more than 4,000 local watershed organizations are at work in the United States. They
are advocating watershed restoration, source water protection, improved site
design, erosion control, land conservation, and storm water management - to
name just a few activities.
The watershed approach is generally invoked to mean broad stakeholder
involvement, hydrologically defined boundaries, and coordinated management
across all aspects of policy that affect water. "Source water protection" is the
watershed approach's analog under the Safe Drinking Water Act. The watershed
approach and source water protection are grounded in science and allow for
prioritization and cost-effective interventions, as appropriate.
The EPA Office of Water's 2003 guidance on watershed-based permitting and
water quality trading allow for strategic, cost-effective actions to meet water quality
standards. Watershed goals and the impact of multiple pollutant sources and
stressors, including nonpoint sources, are considered when National Pollutant
Discharge Elimination System (NPDES) permits are written for multiple sources in a
watershed. The goal of this approach is to issue permits that take into account the
conditions of the entire watershed and address diverse pollution sources, not just
individual point sources. Often, such permits carry a trading component. A current
example of a successful watershed-based permit with trading can be found along
Long Island Sound, where nitrogen trading among dozens of publicly owned
treatment works in Connecticut is expected to save more than $200 million in control
costs.
Source water protection, targeted to protect current and future sources of
drinking water, also holds the promise of substantial benefits. EPA has determined
that preventing contamination can be up to 40 times more cost effective than
remediation of a drinking water source or finding a new one.
Development decisions are another important approach to the watershed
paradigm. Development decisions are generally made at the local level. While local
governments have direct authority over land use and development decisions, many
states play important roles in setting statewide approaches to planning for growth.
-------
The EPA cannot and should not be a national or regional development board, but
the federal government can help states, Tribes and municipalities better understand
the impacts of development patterns. The Source Water Collaborative's10 recent
Vision Statement notes that drinking water protection should be integrated into
land-use planning and stewardship; road, sewer and water projects; farming,
industry and development practices; waste disposal methods; watershed planning,
protection and clean-up; and the routine decisions Americans make every day. EPA
is working to help states and communities (and should be working to help Tribes)
realize the economic, community, and environmental benefits of smart growth by:
1) providing information, model programs, and analytical tools to inform
communities about growth and development; 2) working to remove federal barriers
that may hinder smarter community growth; and 3) creating new resources and
incentives for states and communities pursuing smart growth.
A key objective the Agency wishes to advance under the sustainable
infrastructure effort is the merger of watershed management principles into utility
management, so that key decision makers consider the watershed approach
alongside the traditional treatment technology investments. As part of this effort, the
Agency needs information regarding whether: 1) a bias exists in favor of
technological investments due to existing governmental policies, institutional
structures, scientific uncertainties, or problems in valuing the benefits of using a
watershed approach; and 2) if such a bias exists, how can this bias be eliminated?
The SI now seeks to develop more robust information, data, case studies, and
lessons-learned with respect to the use of watershed approaches to avoid or reduce
current or future infrastructure costs and/or operating and maintenance expenses.
EPA is specifically interested in gathering data on the cost savings and ecological
and public health benefits that the use of such an approach may accrue while still
achieving compliance with the requirements of the Clean Water Act and Safe
Drinking Water Act.
Charge to the NACEPT Water Infrastructure Workgroup
The Water Infrastructure Workgroup of the National Advisory Council for
Environmental Policy and Technology (NACEPT) is asked to assist the Agency in
advancing cost-effective and sustainable approaches to water resource
management and infrastructure to meet watershed goals. It is the Agency's position
that the watershed approach is critical to protecting and restoring the nation's
waters. The Agency furthermore suspects that in order for the benefits of the
watershed approach to be fully realized it must be integrated into the
comprehensive planning processes at the state, regional and local levels.
10 The Source Wafer Collaborative consists of a broad set of constituencies that include the U.S. EPA and 13
national premier organizations (representing state agencies, water utilities and environmental groups) that
have agreed to combine their efforts to protect drinking water sources.
-------
There are several areas where NACEPT can assist the Agency in determining
how to best use its expertise and resources to promote the watershed approach, as
it specifically applies to Sustainable Infrastructure, and its integration into state,
regional and local comprehensive planning processes.
Overall Goals:
A. Promote the development of sustainable infrastructure by elevating water
resource and infrastructure protection and management as a state, regional
and local government priority in the comprehensive planning process on a
par with transportation planning, public safety and schools.
B. Encourage widespread adoption of an integrated planning approach
focused on water resource and infrastructure protection and management.
C. Provide information, data, tools and tools necessary for state and local
governments and their communities to adopt these approaches.
Research and Recommendations
The Charge encompasses two distinct focus areas. Consequently, the Office of
Water is proposing that NACEPT adopt a phased approach for addressing the
charge over a two-year period.
A. Phase 1: Comprehensive Planning and Decision-Making
No later than May, 2007 NACEPT would identify incentives, drivers, barriers, and
other factors that encourage or inhibit the prioritization of water resource
infrastructure and management into the comprehensive state, regional and
municipal planning frameworks and decision making processes.
Also no later than May, 2007 NACEPT would provide recommendations to the
Agency on:
1. Actions the Agency can take to help states and local governments
overcome the barriers and impediments that prevent the full integration
of water resource management as a priority in their respective planning
and decision making processes. For example:
a. How can the Agency more effectively promote increased collaboration
among drinking water, wastewater and storm water utilities, local
governments, planning boards and other stakeholders that result in
collective water infrastructure priority setting under a watershed
management context through education and other means?
b. How can municipalities and other local government/regional planning
entities build support for promoting a watershed approach to water
infrastructure planning?
c. Using relevant examples from the recent Cooperation Conservation
Conference, what are the ways in which "cooperative conservation" or
"coordinated resource management" has been or can be used to
overcome barriers to promoting a watershed approach to water
infrastructure planning?
-------
d. How can EPA, States, or others influence various community stakeholders to
adopt and promote such an approach?
e. What are the specific barriers embodied in existing EPA and state policies or
practices that need to be remedied to help EPA and states further
encourage and assist entities to consider and implement alternative and
integrated approaches for water infrastructure planning and management?
Phase 2: Benefits of Traditional versus Alternative Approaches to Water Resource
Infrastructure and Management
No later than May, 2008 NACEPT would identify, analyze and report on the
actual or potential benefits that accrue to local governments and utilities that
use alternative and integrated approaches to manage wastewater, drinking
water, and storm water, and the factors that affect whether alternative or
traditional approaches are more cost-effective. Examples of these alternative
approaches include centralized management of decentralized technologies
and systems, soft path technologies, conservation designs, smart growth
strategies, water conservation and reuse policies and low impact development
approaches.
In doing so, NACEPT would examine specific examples and associated factors
from communities where centralized approaches are predominant and those
where alternative approaches have been used, along with the key factors that
caused these communities to adopt these approaches.
In addition, NACEPT would identify, analyze and report on the actual or
potential incentives for local governments and utilities to use alternative and
integrated approaches to manage wastewater, drinking water, and storm
water.
Also no later than May, 2008 NACEPT would provide recommendations to the
Agency on:
1. Specific actions (e.g., policy, guidance, technical and programmatic tools,
research) that the Agency can take to encourage and promote the
investigation of alternative approaches that could meet water quality and
service objectives at lower life-cycle cost than traditional approaches. For
example, assist EPA in identifying mechanisms for promoting consideration of
centralized management and oversight of decentralized systems as a cost-
effective alternative to physical consolidation of infrastructure.
Potential Future Work
EPA would be open to identifying additional research areas, upon completion
of the current charge, to further improve the understanding of sustainable
infrastructure issues. The additional research topics may include new areas or may
build upon the results of the current research charge.
-------
NACEPT Charge Addendum (Phase II): August 15, 2007
This Addendum is intended to clarify and refine Part II of the charge. Part II deals
primarily with the benefits and cost effectiveness of integrated approaches to
managing drinking water, wastewater and storm water. With the progress achieved
in some areas since the charge was written, EPA believes it would receive the
greatest benefit from the workgroup focusing on collaborative opportunities or
partnerships (COoP) between utilities (water, wastewater and/or storm water)
and/or other stakeholders within a watershed or region.
EPA would like to better understand the barriers and incentives to achieving
cost efficiencies and economies of scale that result from COoPs and reduce the
infrastructure gap and enhance sustainability.
Examples include outsourcing of certain functions; circuit rider programs; pooled
purchasing arrangements; central management of decentralized water and
wastewater systems; physical connection and merging of systems; watershed
partnerships, etc.
NACEPT will talk with experts in the field and study key examples to determine
what COoPs are most effective in achieving efficiencies.
NACEPT will consider whether there are characteristics (e.g. size, growth rates
etc.) that prevent a utility from being cost effective without entering into some form
of COoP.
NACEPT would consider barriers and actual or potential incentives that exist (at
the Federal, State, Tribal and Local level) to foster successful COoP.
NACEPT would identify specific stakeholder (utilities, States, tribal and local
governments, citizen groups, etc) actions that could be taken and recommend to
EPA changes in policy, outreach, internal operations, and/or incentives and
disincentives to foster COoPs.
-------
APPENDIX V: REFERENCES
Theriault, B. [March 21, 2005] "Small and Large Water Utilities Will Benefit from a Bill
that Creates Regional Councils." Column in Portland Press Herald. [Southern
Maine Regional Water Coalition]
Southern Maine Regional Water Council. [October 25, 2006] Mutual Aid Agreement
for the Southern Maine Regional Water Council.
U.S. Environmental Protection Agency, Office of Water. 2008. "Factoids: Drinking
Water and Ground Water Statistics for 2007." EPA document 816-K-07-004.
March 2008. Online at: www.epa.gov/safewater/data.
Massachusetts Coalition for Water Resources Stewardship. 2007. "The Case for
Environmental Regulatory Reform: Clean Water Act NPDES Permitting." White
paper, November 14, 2007.
Raucher, B. 2007. "Sustainability: What Does it Really Mean and How Do Water
Utilities Get There?" PowerPoint presentation. Prepared for the American Water
Works Association, Annual Conference and Exhibition, Toronto, Ontario. June 27,
2007.
U.S. Environmental Protection Agency, Office of Water. 2002. System partnership
solutions to improve public health protection. EPA Document 816-R-02-022.
September 2002.
U.S. Environmental Protection Agency, Office of Water. System partnership solutions
to improve public health protection: Volume 2. EPA Document 816-R-06-005.
U.S. Environmental Protection Agency, Office of Water. 2001. "Building water system
capacity: A guide for tribal administrators." EPA document 816-K-01-08. July
2001.
[Water Environment Federation] 2007. "Case studies addressing innovative utility
approaches to watershed management." August 8, 2007. Draft #5.
Yeager, T., R. Ehrhard, and J. Murphy. 2006. Business attributes of successful
responsible management entities.
Western Governors' Association. 2006. "Water needs and strategies for a sustainable
future." June 2006.
U.S. Environmental Protection Agency, Office of Water. 2007. Restructuring and
consolidation of small drinking water systems: A compendium of state
authorities, statutes, and regulations. EPA Document 816-B-07-001. October
2007.
-------
U.S. Environmental Protection Agency, Office of Water. 2008. National capacity
development strategic plan. EPA Document 816-K-07-003. January 2008.
U.S. Environmental Protection Agency, Office of Water. 2000. Report of the National
Drinking Water Advisory Council, Small Systems Implementation Working Group.
EPA Document 816-R-00-012.
Raucher, R.S. et al. 2006. Regional solutions to water supply provision. Report
prepared for: AWWA Research Foundation and U.S. Environmental Protection
Agency. Under Cooperative Agreement R829679-01. Document 1 P-3.5C-91146-
10/06-NH.
NACEPT. 2008. "Everyone's Business: Working Towards Sustainability Through
Environmental Stewardship and Collaboration." EPA Document 130-K-08-001.
March 2008.
Cadmus Group et al. 2002. Selections from: A study of best practices in the water
and wastewater sector for the Ontario Superbuild Corporation. Final report. April
1,2002.
-------
NACEP
------- |