Advocacy & Analysis
For more than 40 years, NACWA has been the leader in national clean water advocacy, and the strongest voice for publicly owned wastewater and stormwater utilities. Whether educating lawmakers on key clean water issues in the halls of Congress, advancing critical regulatory priorities with the U.S. Environmental Protection Agency (EPA) or other federal agencies, or litigating in courts across the nation on behalf of municipal clean water interests, NACWA is always at the forefront of the advocacy effort, representing clean water utilities, their communities and their ratepayers.
We invite you to learn more about NACWA’s current advocacy initiatives and read in-depth analyses of how current legislative, regulatory, and legal developments will impact public clean water agencies. From late-breaking news in our Advocacy Alerts to more comprehensive coverage of key advocacy priorities in our Updates, NACWA’s resources provide a comprehensive source of clean water information. This page also highlights current NACWA advocacy campaigns and contains critical advocacy tools to help clean water agencies add their voice to that of others around the country in elevating clean water as a national priority.
Advocacy
Alerts
April 2026 Regulatory Update
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.
Contact: Matt McKenna, 202-533-1825.
Regulatory Policy & Pretreatment
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.
Regulatory Updates
April 2026 Regulatory Update
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.
Contact: Matt McKenna, 202-533-1825.
Regulatory Policy & Pretreatment
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.
Legislative
Updates
April 2026 Regulatory Update
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.
Contact: Matt McKenna, 202-533-1825.
Regulatory Policy & Pretreatment
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.
Legal
Updates
April 2026 Regulatory Update
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.
Contact: Matt McKenna, 202-533-1825.
Regulatory Policy & Pretreatment
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.
Advocacy Priorities
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Biosolids Explained
PFAS are released into the environment in many ways, such as through the products that contain them, through improper disposal by manufacturers, and by fire-fighting foam when it is used. Because PFAS are a part of so many products, they are often found in soil and water samples, too. Your wastewater service provider receives water from homes and businesses that contains PFAS, likely from our bodies, dishes, and clothes.
While wastewater systems were not designed to specifically treat or remove PFAS, your providers are prepared to – and have already begun to – study and assess PFAS’ impacts on their treatment facilities, the quality of the water they discharge, and the amount of PFAS that may be found in biosolids.
Your wastewater utility does not generate PFAS
Your wastewater utility receives PFAS when they get into the wastewater from homes, businesses, and industrial processes. While the utility and its customers cannot be expected to bear the full costs involved in addressing PFAS, they are strong partners in reducing PFAS in our communities.
Stormwater
As the nation’s leading advocacy voice for municipal stormwater utilities across the country, NACWA is dedicated to protecting water quality; addressing large scale watershed impacts, such as flooding and erosion; and solving related modern-day challenges, such as water quality impairment from stormwater runoff and land-use impacts.
The Association and its individual members are committed to advancing robust, innovative programs and working collaboratively with regulators and stakeholders. The U.S. Environmental Protection Agency’s (EPA) MS4 General Permit Remand Rule, issued in early 2017, represents a change in the development and issuance of National Pollution Discharge Elimination System (NPDES) permits for small Municipal Separate Storm Sewer Systems (MS4s).
Climate Adaptation & Resiliency
Climate change impacts are already affecting clean water agencies and are projected to grow in the years ahead. Increased intensity of storm events and flooding, the threat of sea level rise at treatment works—traditionally located on low-lying coastal land in a community—and increased attention to water scarcity and reuse are just some of the ways in which clean water agencies are seeing impacts from a rapidly changing climate. As the public and government at all levels becomes more concerned, legislative, regulatory and legal pressures to control greenhouse gas emissions and mitigate climate change impacts will grow. Given the critical services clean water agencies provide in their communities, our sector needs to be closely engaged in climate and resiliency conversations.
NACWA believes that climate change is primarily a water issue. The Association’s advocacy focuses on the interrelationships between water resources and climate change. NACWA is also committed to ensuring that greenhouse gas emissions from wastewater treatment are accurately estimated, and that any efforts that impact the wastewater sector are reasonable.
Toilets Are Not Trashcans
NACWA's Toilets Are Not Trashcans campaign is focused on protecting the pipes, pumps, plants, and personnel of wastewater utilities across the nation by reducing the materials that are inappropriately flushed or drained into the sewer system.
Products such as wipes, paper towels and feminine hygiene products should not be flushed, but often are, causing problems for utilities that amount to billions of dollars in maintenance and repair costs—costs which ultimately
pass on to the consumer. Other consumer products contain ingredients, such as plastic microbeads and triclosan, which may harm water quality and the environment. Fats, oils and greases (FOG) and unused pharmaceuticals should also be kept
out of the sewer system.
Nutrients & Farm Bill
Pursuing New Tools to Address Nutrient-Related Water Quality Challenges
Nutrient pollution remains a substantial challenge to the water resources of the United States. Deficiencies in the federal regulatory and policy framework, as well as the lack and inflexibility of financial resources, have constrained needed progress. These factors are driving a strong interest across nutrient management stakeholders in developing and implementing alternative nutrient management approaches.
At the same time, as outlined in more detail below, NACWA played a leading role in securing legislative language in the 2018 Farm Bill that will help public clean water utilities better engage upstream with agricultural partners to achieve meaningful water quality improvements through a holistic, watershed approach.
Integrated Planning
Over the last 45 years, communities have been responding to a growing list of Clean Water Act (CWA) regulatory mandates to improve the nation's water quality. Often taking on compounded wastewater and stormwater responsibilities, many communities are struggling to adequately allocate strained financial resources to these clean water needs.
Thanks to advocacy efforts by NACWA, the U.S. Conference of Mayors and others, EPA recognized the regulated community’s need for flexibility, and developed its Integrated Municipal Stormwater and Wastewater Planning Approach Framework (IP Framework) in 2012. NACWA and its members have been working with EPA and state water regulators ever since to ensure the Framework can be utilized by communities when appropriate.
Affordable Water, Resilient Communities
There is no issue more central to NACWA’s advocacy than increasing the availability of infrastructure funding for public clean water utilities, which includes increased federal funding to support this critical infrastructure sector.
Originally founded in 1970 as an organization focused on ensuring appropriate distribution of federal construction grant dollars under the Clean Water Act, the Association has maintained a strong commitment to advancing federal clean water funding.
At the same time, NACWA has also evolved over the years to recognize the importance of other water infrastructure funding mechanisms including municipal bonds, innovative financing approaches, and public-private partnerships.
PFAS
Publicly owned clean water utilities are “passive receivers” of PFAS, since they do not produce or manufacture PFAS but de facto “receive” these chemicals through the raw influent that arrives at the treatment plant. This influent can come from domestic, industrial, and commercial sources and may contain PFAS constituents ranging from trace to higher concentrations, depending on the nature of the dischargers to the sewer system.
Although the influent is not generated by the utility, the utility is responsible for treating it under the Clean Water Act. Municipal clean water utilities were not traditionally designed or intended with PFAS treatment capabilities in mind. Today, there are no cost-effective techniques available to treat or remove PFAS for the sheer volume of wastewater managed daily by clean water utilities.
NACWA’s advocacy priorities on PFAS include urging source control, empowering the Clean Water Act pretreatment program, preventing public utilities and their customers from unintended liabilities and costs of PFAS management, and advancing research to support sound rulemaking that protects public health and the environment.
Congressional Toolbox
NACWA encourages all of its public utility members to arrange regular meetings with their Senators and Representatives.