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NACWA Submits Letter to EPA with Recommendations on Infrastructure Bill Implementation

December 16, 2021

NACWA submitted a letter to EPA earlier this week outlining the Associations’ initial thoughts and recommendations around how the recently passed Infrastructure Investment and Jobs Act (IIJA) is implemented. The letter builds on conversations NACWA has had with senior EPA Office of Water leadership to date and the initial recommendations and concerns received from NACWA members.

In the letter, NACWA emphasizes that clean water agencies will be key to the efficient, effective implementation of IIJA. To ensure maximum success in advancing the IIJA’s goals, the letter urges significant flexibility for how IIJA funds can be used on a broad array of clean water investments – especially through distribution of the “additional subsidy” or grant portions of the IIJA funding across disadvantaged communities and disadvantaged segments of communities/service areas.

Because the majority of IIJA funds are being funneled through the SRFs, NACWA urges EPA to provide technical assistance and guidance that helps the states reach eligible communities and encourage innovation in how the funds are administered. NACWA has heard that EPA plans to require new Intended Use Plans (IUPs) for IIJA funds, so the letter urges against complicating the process for utilities that already have projects submitted to IUPs. NACWA further seeks clarity on how the multiple pots of federal funding (e.g. traditional SRFs, IIJA SRFs, WIFIA) will work together.

IIJA expanded Buy America requirements to all federal infrastructure investment programs moving forward and brings new categories including manufactured products into the fold. The White House established a Made in America Office, housed within the Office of Management and Budget (OMB), during President Biden’s first week in office.

NACWA supports direct collaboration between EPA and this new OMB office to ensure understanding of the unique circumstances clean and drinking water agencies face around infrastructure implementation. NACWA is particularly concerned with how the expanded Buy America requirements may hamper implementation of the new infrastructure funding and is advocating for maximum flexibility in how the requirements are applied.  

These and other recommendations and concerns, including related to the funds targeting emerging contaminants/PFAS, are detailed further in the letter. NACWA plans additional conversation on these key issues between EPA and utility leaders on NACWA’s Executive Committee and a Board task force focused on IIJA implementation.

Individual clean water utilities have also begun sending letters to EPA regarding IIJA. NACWA encourages this utility outreach and asks utilities to share their letters/concerns with the Association as well so we can ensure they are reflected in our advocacy.

In addition to these direct efforts with EPA, NACWA continues participating in dialogues across the municipal and water sector on IIJA implementation (see related story). We expect significant progress and announcements by EPA in implementing IIJA over the next 1-2 months and will keep the membership up to date.

Members with questions can contact Kristina Surfus, NACWA’s Managing Director of Government Affairs.


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