Association of Clean Water Administrators

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Developing a New Framework for Household Affordability and Financial Capability Assessment in the Water Sector

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AWWA, NACWA and WEF developed recommendations for the EPA on a new methodology and guideline for assessing household affordability and community financial capability to replace its current guidance document: Combined Sewer Overflows – Guidance for Financial Capability Assessment and Schedule Development (EPA, 1997). This effort was prepared in anticipation of the EPA updating its financial capability assessment (FCA) guidelines after the 2017 National Academy of Public Administration (NAPA) Developing a New Framework for Community Affordability of Clean Water Services (NAPA Report).

Sec. 401 Process Improvements

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States are the primary authority for allocating, administering, protecting, and developing water resources, and they are primarily responsible for water supply planning within their boundaries. States have the ultimate say in the management of their water resources and are best suited to speak to the unique nature of western water law and hydrology. Under the Clean Water Act (CWA), Congress deliberately preserved states’ authority to manage and protect their water resources by establishing a system of cooperative federalism through which states serve as co-regulators for the implementation and enforcement of federal statutory programs. CWA Section 401 represents a critical state authority which protect states’ authority over water resources and ensures that states have a meaningful role in the certification of federal permits and licenses for projects that may affect water quality in a state.The CWA Section 401 Process Improvements have been developed in collaboration with associations of state officials and are intended to identify possible reforms to the water quality certification program that do not compromise or curtail states’ well-established legal authority to manage and protect their water resources. As states are co-regulators with the federal government in administering the CWA, it is critical that states be afforded early, meaningful, substantive, and ongoing consultation in the development of any changes to the Section 401 program or to the balance of state and federal authority under the statute.

EPA 2018 Year in Review

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“This report highlights key steps we have taken to achieve this goal and to protect the environment and public health. In 2018, we have been particularly focused on providing greater certainty to the American public: certainty in our EPA programs; certainty to the states, tribes, and local governments; and certainty on how we communicate risk. The American public have a right to know the truth about the risks they face in their daily lives and how we are responding. It is our responsibility to explain it to them clearly and consistently.”

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