The U.S. Environmental Protection Agency (EPA) is urging states to take a more proactive approach to protecting drinking water systems, with new guidance designed to help officials identify and address vulnerabilities before they disrupt service or threaten public health.
The EPA released its Systemic Issues Checklist on Aug. 13, providing guidance for state drinking water agencies on identifying, documenting and tracking problems that could become more serious if left unresolved. The checklist is designed to be incorporated into existing sanitary survey and capacity development programs rather than replace existing enforcement or deficiency processes.
According to the EPA, systemic issues can include a water system approaching the maximum capacity of its sources, poorly maintained or malfunctioning treatment equipment, frequent water main breaks, inadequate backup pumping equipment and other longstanding problems that may not individually rise to the level of a significant deficiency but could contribute to one over time.
The checklist encourages state officials to use routine sanitary surveys to look beyond individual deficiencies and consider whether recurring or unresolved problems point to broader weaknesses within a water system. Surveyors are encouraged to review at least the two most recent surveys, compliance records and complaints, then talk with water system operators about any unresolved issues. Officials should also check whether a system has an asset management plan in place and whether it is being implemented and updated.
Any systemic issues should be included in the final sanitary survey report, along with an explanation of why the issue was identified, how it could threaten public health and what should be done about it. The primacy agency’s capacity development program should also be made aware of the issue. Problems that rise to the level of a violation or significant deficiency should be handled through the appropriate existing process.
The EPA also lays out guidance on how to address any identified problems. The agency encourages states to use their existing authorities and capacity development programs. Depending on the type of assistance needed, officials can connect water systems with technical help, training and funding.
The EPA’s Real Water Technical Assistance (Real Water TA) resources include:
- Environmental finance centers.
- Training and technical assistance for small systems.
- Water resilience.
- Areawide optimization.
- Cybersecurity.
- Get the Lead Out Initiative.
- Engineering support.
- Tackling emerging contaminants.
The EPA calls on primacy agencies to consider the $6.5 billion in Drinking Water State Revolving Fund (DWSRF) loans made available this year as a source of funding for addressing systemic issues. These loans help water systems meet the health objectives of the Safe Drinking Water Act. Another $11 billion in flexible financing is available through Water Infrastructure Finance and Innovation Act (WIFIA) loans, which can finance up to 80 percent of project costs in small and rural systems. The guidance also points to restructuring, physical consolidation, financial or administrative consolidation, transfer of ownership or operational changes as potential solutions.
The agency directs primacy agencies to report identified issues to their EPA regional office annually. Reports should include the water systems affected, what actions are being taken and any additional resources needed. The EPA says this documentation can help regional offices coordinate technical assistance or, when appropriate, enforcement.
The checklist gives states a framework for identifying and tracking problems before they contribute to more serious deficiencies. The EPA says safe, reliable water is essential to public health and national security, and the agency encourages states to use the guidance to address systemic issues before they threaten a water system’s ability to provide reliable service.
Photo by Kindel Media from Pexels
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