ACWA sent a letter and a package of supporting materials, including an analysis of the Bipartisian American Affordability and Jobs Act of 2026 (BAAJA) would significantly change how states, EPA, and the Army Corps implement the Act: the changes would require APA rulemaking for Section 304(a) criteria, substantially rewrite Section 401 certification standards and procedures, double the maximum NPDES permit term to ten years, and reshape Section 404 permitting and judicial review. Because states carry out these programs day to day, our analysis focuses on what the changes would mean for state procedures and workload.
BAAJA Letter and Materials
