Fast Approaching Deadline: AWIA Compliance on risk assessment and emergency response plans

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The America’s Water Infrastructure Act (AWIA) of 2018 established requirements and deadlines for community water systems that serve more than 3,300 people. These requirements include completing a risk and resilience assessment (RRA) and an emergency response plan (ERP). The assessments require water utilities to examine risks to their systems "from malevolent acts and natural hazards." If a utility does not certify that they have complied with the AWIA, the EPA can assess a penalty of up to $25,000 per day.

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Certification Process

The first step is an assessment of several critical components of the system including the following:

  • Pipes and constructed conveyances
  • Physical barriers
  • Source water
  • Water collection and intake
  • Pretreatment, treatment, storage and distribution facilities
  • Electronic, computer or other automated systems

In addition to the physical components, the assessment includes:

  • Monitoring practices
  • Financial infrastructure
  • Chemical use, storage and handling
  • Operation and maintenance of the system
  • May include an evaluation of capital and operational needs for risk and resilience management for the system

Once the assessment is completed, the Director or another leader of the utility, must send a certification letter to the EPA with the date the RRA was completed. Within six months of submitting the letter, the utility must prepare and submit an ERP.

The ERP must include:

  • Strategies and resources to improve the resilience of the system, including the physical security and cybersecurity
  • Plans and procedures that can be implemented and identification of equipment that can be utilized, in the event of a malevolent act or natural hazard that threatens the ability of the community water system to deliver safe drinking water
  • Actions, procedures and equipment that can obviate or significantly lessen the impact of a malevolent act or natural hazard on the public health and the safety and supply of drinking water provided to communities and individuals. These could include the development of alternative source water options, relocation of water intakes and construction of flood protection barriers
  • Strategies that can be used to aid in the detection of malevolent acts or natural hazards that threaten the security or resilience of the system

Systems must maintain a copy of the assessment and emergency response plan for five years after certifying the plan to the EPA.

Certification Deadlines

The law includes staggered deadlines. Larger systems, defined as those serving 100,000 people or more, had until March 31, 2020 to complete the assessment. Medium sized utilities, those serving between 50,000 and 100,000, have until the end of 2020 and smaller utilities have until June 30, 2021. The ERP must be completed within six months of the certification. See the table below for details.

Population Served Risk and Resilience Assessment Emergency Response Plan
>100,000 March 31, 2020 September 30, 2020
50,000-100,000 December 31, 2020 June 30, 2021
3,301-49,999 June 30, 2021 December 31, 2021
3,300 or less Exempt Exempt

More information about the requirements and guidance documents are available on the EPA website.

Not Sure How to Proceed?

Bartlett & West has experienced professionals that have completed the requirements for the AWWA Utility Risk and Resilience Certificate Program. In addition to facilitating AWIA compliance, we provide a foundation for supporting utilities in the development of an all-hazards approach to risk and resilience management and in preparing sound mitigation action plans.

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