Member Input Needed as NACWA Prepares to Comment on FCA Document Revisions
The official 60-day comment period on EPA’s latest revisions to its Financial Capability Assessment (FCA) document began February 23 with the release of the draft guidance in the Federal Register. Comments are due to EPA by April 25.
NACWA provided an initial summary of the revised document in last week’s Clean Water Current. NACWA encourages members to review the document and share any feedback via email to Chris Hornback.
NACWA is particularly interested in hearing from utility members about the new Financial Alternatives Analysis that will be required of utilities and how onerous it may be, as well as EPA’s new, strict cap on schedule length.
Both of these policy changes were added to the document by the Biden Administration based on input from internal EPA offices and external stakeholders after the January 2021 document was put on hold.
NACWA will be working with its partners at the American Water Works Association (AWWA) and the Water Environment Federation (WEF), together with the experts who prepared the water sector recommendations document in 2019, to review the new metric EPA is proposing to use, which compares a community’s lowest quintile income to a national average instead of looking at household impacts. NACWA will provide members with additional information once this analysis is complete.
NACWA encourages members with concerns about the FCA document to consider filing their own comments, and NACWA will develop and share a list of key points to highlight prior to the deadline. Members with questions can contact Chris Hornback, NACWA’s Deputy CEO.