(February 20, 2018) - NACWA staff and utility members of the Association — including the Massachusetts Water Resources Authority, Boston Water & Sewer Commission, Springfield Water & Sewer, Narragansett Bay Commission, and The Metropolitan District, Hartford — met with Alexandra Dunn, Regional Administrator, EPA Region 1, and several senior EPA staff members on February 15.

Regional Administrator Dunn was eager to hear “on-the-ground” perspectives of challenges and ways she could work cooperatively with clean water agencies to achieve the common goals of environmental and public health protection. Dunn indicated that EPA Administrator Scott Pruitt had visited Region 1 the previous day, and they discussed the importance of increased transparency, cooperative federalism, and more productive communication with the regulated community.  She also conveyed her clear understanding of the essential role of clean water agencies and her appreciation of, and respect for, the work and accomplishments of NACWA members. 

With regard to enforcement, NACWA discussed the need for a “Compliance Assistance First” approach, with enforcement initiated only if assistance fails; the importance of addressing affordability challenges; and the need for EPA Regions to embrace and encourage delegated states to partner in promoting integrated planning, adaptive management, and holistic solutions centered around net environmental improvements.

Three specific concerns that NACWA highlighted were the Long Island Sound Enhanced Nutrient Reduction Strategy, the small municipal stormwater permits issued by EPA Region 1 to Massachusetts and New Hampshire, and the nexus of drinking water and clean water issues around the use of orthophosphates for corrosion control under the Lead and Copper Rule.

Dunn formerly served as Executive Director and General Counsel for the Association of Clean Water Administrators and as General Counsel for NACWA and, therefore, has extensive knowledge about the local and state role in Clean Water Act compliance.  NACWA will be advancing this discussion at the Region 1 Forum to be held on July 23 in conjunction with the NACWA Utility Leadership Conference & 48th Annual Meeting, which will be held in Boston July 23-26, 2018. 

NACWA believes that similar meetings in the other EPA Regions could be productive and is interested in working with members in each Region to ensure regional priorities are being addressed. Members interested in setting up such meetings should contact Chris Hornback, NACWA’s Chief Technical Officer.