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April 2026 Regulatory Update

May 1, 2026

Regulatory Perspectives

Beyond PFAS: Keeping Our Nose to the Grindstone on Emerging Contaminants

For nearly the last decade, per- and polyfluoroalkyl substances (PFAS) have been seen as the preeminent emerging contaminants capturing national concern and regulatory attention. This era continues for the clean water community who is closely monitoring state actions and awaiting federal regulatory decisions on biosolids management, human health water quality criteria, and liability protections as downstream receivers of these pollutants. 

At the same time, a new wave of contaminants is gathering potential regulatory attention: microplastics and pharmaceuticals. Like PFAS, these pollutants present myriad challenges for water professionals—widespread presence, problematic analytical methods, incomplete toxicity profiles coupled by an unclear definitional framework for microplastics, and a lack of practical, existing treatment control strategies.  

Notably, these broad contaminant groups were recently listed in the U.S. Environmental Protection Agency’s (EPA) recent Draft Contaminant Candidate List 6 (CCL 6), reinforcing a simple message: the portfolio of potential drinking water concerns is expanding, not narrowing. While the CCL 6 guides EPA’s research on new contaminants, it also is the first step towards potential future regulations under the Safe Drinking Water Act. This is something the clean water community must take notice of, as it mimics the way PFAS regulations came to be for drinking water utilities.  

NACWA has partnered with the American Water Works Association (AWWA) in a state-of-the-science effort to better understand microplastics and their potential impacts to water and wastewater utilities. Currently, there are many unanswered questions on source inputs, laboratory standards and quantification, and treatment feasibility along with uncertainty on the risk these pollutants pose to human health and the environment. This effort helps to close some of those knowledge gaps. 

Parallel to our endeavor, EPA is actively working to refine analytical methodologies for sampling microplastics in drinking water. The EPA may also incorporate microplastics into its upcoming Sixth Unregulated Contaminant Monitoring Rule. If implemented, this rule would require drinking water utilities to begin monitoring for microplastics, marking a significant shift toward greater regulatory oversight of these emerging contaminants. And, as we have seen with PFAS, if regulations are developed on the drinking water side, they are bound to spill over to the clean water side eventually. 

All to say, the clean water community must stay alert to emerging contaminant concerns headed our way beyond PFAS.  

NACWA Continues Focus on Affordability – Register Now for Our Affordability & Revenue Virtual Event!

As clean water agencies grapple with unprecedented costs and growing affordability pressures on their customers – as detailed in NACWA’s latest Cost of Clean Water Index – NACWA is working to provide additional resources to help utilities navigate these issues in their community. 

Next month, NACWA is holding a Virtual Workshop: Ensuring a Stable Revenue Future for Your Utility. This virtual workshop, held over two afternoons, will explore practical and innovative approaches to building long-term financial sustainability. The Workshop will include case studies and build on a recently released free member resource addressing financial resilience strategies for public clean water utilities. 

To learn more, visit NACWA’s events page. Contact Kristina Surfus, NACWA Managing Director of Government Affairs, with questions about these resources or to discuss additional areas you’d like to see NACWA focus on to support utility affordability. 

 

HRSD’s Dr. Charles Bott Named Chair of EPA’s Science Advisory Board

The U.S. Environmental Protection Agency (EPA) has named Dr. Charles Bott, Chief Technology Officer for NACWA Member Agency the Hampton Roads Sanitation District (HRSD) in Virginia Beach, Va. to serve as Chair of its Science Advisory Board (SAB)—a major recognition of his leadership in clean water innovation. 

NACWA strongly supported Dr. Bott’s nomination and congratulates him on this well-deserved appointment to the SAB chairman position. With more than 25 years of experience, Dr. Bott is widely respected for advancing innovative, science-based solutions that protect public health and the environment while remaining practical and cost-effective for communities. At HRSD, Dr. Bott leads nationally recognized research programs in nutrient removal, potable reuse, biosolids management, and the treatment of emerging contaminants such as PFAS. 

NACWA believes Dr. Bott’s appointment will strengthen the SAB’s ability to deliver sound, real-world scientific advice as EPA addresses increasingly complex clean water challenges. His leadership will also bring an important municipal utility perspective to the SAB’s work. Congratulations Dr. Bott! 

Separately, EPA has opened nominations for its Environmental Financial Advisory Board (EFAB), with applications due June 22. NACWA members interested in being considered are encouraged to reach out—NACWA can submit a letter of support on your behalf. 

Please contact Emily Remmel, NACWA’s Senior Director of Regulatory Affairs to learn more about the SAB’s work or express interest in the EFAB candidate nomination invitation. 

Emerging Contaminants

EPA Publishes 3rd Iteration of Draft Interim PFAS Destruction and Disposal Guidance

The U.S. Environmental Protection Agency (EPA) released its 2026 Interim Guidance on the Destruction and Disposal of PFAS and Materials Containing PFAS on April 20. This updated guidance, now in its third iteration, is mandated by the 2020 National Defense Authorization Act to be revised at least every three years, though last year EPA Administrator Zeldin pledged annual updates to incorporate the latest treatment technologies. 

EPA continues to prioritize disposal methods that minimize PFAS release into the environment, recommending techniques with lower risks when costs and other factors are comparable. The Agency highlights three widely used, commercially available technologies: underground injection via permitted Class I wells, landfilling in RCRA Subtitle C hazardous waste landfills, and thermal treatment at permitted hazardous waste combustors (HWCs). However, the draft guidance reflects new scientific findings, noting that some disposal methods may have greater environmental impacts than previously believed. Read the full story in the Clean Water Current

Contact: Emily Remmel, 202-533-1839. 

Funding & Finance

EPA Announces $80 Million in Grants to Help Communities Tackle Stormwater and Sewer Overflows

EPA announced the availability of approximately $80 million in funding through the Sewer Overflow and Stormwater Reuse Municipal Grant Program to help communities address stormwater and sewer infrastructure needs and reduce sewage overflows into local waterways. This is a program that NACWA helped establish via federal legislation and has strongly supported since. 

The new funding—drawn from Fiscal Year 2025 and Fiscal Year 2026 appropriations—will be awarded to states and distributed to communities nationwide. NACWA members are encouraged to engage with their state clean water funding agencies to highlight local project needs that could benefit from this funding if interested in engaging in this program. Read the full story in the Clean Water Current

NACWA Comments on Federal Proposals Concerning Hazardous Substances Discharge Rule, Pharmaceutical Disposal

NACWA provided recommendations to the U.S. Environmental Protection Agency (EPA) and the Food and Drug Administration (FDA) with comment letters on two proposals. 

In the first comment letter, NACWA supported EPA’s proposal to extend the compliance date by three years for facilities to develop Clean Water Act Hazardous Substance Facility Response Plans. These Plans will be required for certain industries, including some clean water utilities, for a “worst-case discharge” of hazardous substances if located within a certain proximity to a water of the United States. 

In the second comment letter, NACWA asked the FDA to consider the potential environmental impacts of in-home disposal systems for opioid analgesics. NACWA has previously supported a requirement that mail-back envelopes be provided as a safe and effective method for returning unused opioid prescriptions for destruction by incineration. The FDA is now considering adding a requirement that in-home disposal systems also be available as a disposal method for unused opioids to further prevent unauthorized use of these drugs. Read the full story in the Clean Water Current

Contact: Cynthia Finley, 202-533-1836. 

Water Reuse

EPA Launches Water Reuse Action Plan (WRAP) 2.0 to Expand Water Reuse, Cut Costs and Strengthen National Water Supply

EPA Administrator Lee Zeldin launched the Water Reuse Action Plan (WRAP) 2.0 on April 16 at a standing-room only event at EPA Headquarters that was scheduled to coincide with Water Week. The WRAP 2.0 is a renewed initiative that builds upon the foundation started in 2020 from the National Water Reuse Action Plan and is designed to further promote and facilitate innovative water reuse practices to help address the nation’s growing water supply challenges. 

NACWA provided input to the development of WRAP 2.0 and participated in a panel discussion as part of the launch event to offer the clean water utility perspective on water reuse issues. Read the full story in the Clean Water Current

Contact: Kaitlyn Montan, 202-533-1814. 

 

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