(August 28, 2018) – EPA’s National Environmental Justice Advisory Council (NEJAC) recently released a draft report providing recommendations to the Agency on water infrastructure investment. The document, entitled EPA’s Role in Addressing the Urgent Water Infrastructure Needs of Environmental Justice Communities, outlines suggested actions EPA should take to address water infrastructure challenges in disadvantaged communities.
Among the report’s recommendations is the need for additional federal funding for water infrastructure from Congress. While this is a welcome recommendation, a number of the report’s other suggestions unfortunately fail to adequately address the affordability challenges facing public clean water utilities and the communities they serve, especially in the context of environmental justice (EJ) issues.
In particular, the report does not seem to recognize that discussion around the affordability of federal water mandates, and concern over how these mandates impact the financial burden on EJ/low income communities, are in fact inextricably linked topics. Instead, the document appears to suggest that the two are entirely separate issues.
Additionally, while the report acknowledges the role customer assistance programs and tiered rate strctures can play in helping address affordability concerns, it does not recognize that these approaches will not work for all communities and utilities.
NACWA was not consulted by the NEJAC during development of this report, and is not aware of any other associations in the water sector that were consulted. NACWA has already reached out to EPA with an offer to provide insights to the NEJAC on the draft report in the hope that the final report can better reflect the public clean water utility pespective on the complexities of this very challenging topic. Any members with questions can contact Nathan Gardner-Andrews, NACWA’s Chief Advocacy Officer.