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Winter 2018


The Time Is Now For Congress And EPA To Address The Twin Challenges Of Aging Infrastructure And Affordability pg. 35


Clearing the Air on Arid States


Growing Organic Advocates


A Day in the Life of a Clean Water Worker

We Clean It. For Everyone’s Sake.

Fortune Favors the Bold Large-scale water infrastructure funding & solutions make up clean water’s biggest undiscovered territory for 2018. Will you be part of the expedition to discover it?


Winter 2018


EXPLORE NEW FRONTIERS at NACWA’s 2018 Summer Conference

NACWA Utility Leadership Conference & 48th Annual Meeting Boston, MA | July 23 – 26, 2018









the Storms 5 Weathering —President’s Message —Catherine R. Gerali

(Ret.) District Manager of Metro Wastewater Reclamation District, Denver, CO NACWA Board President (2017)

the Air 9 Clearing on Arid States —By Adel Hagekhalil, Brian Wheeler and Emily Remmel

Watershed 19 The Moment —By Bruce Roll

Nutrient 24 Tackling Pollution at the Watershed Scale

The Time Is Now For Congress And EPA To Address The Twin Challenges Of Aging Infrastructure And Affordability —By Rudolph S. Chow and Adam Krantz

—By Chris Hornback


Permits: The Moving 27 MS4 Target —By Philip D. Guerin and Joshua D. Schimmel

30 The Year of Stormwater —By Erica Spitzig and Emily Remmel

Winter 2018



Growing Organic Advocates —By Pamela H. Perez and Anthony Viardo

A Day in the Life of a Clean Water Worker —By Oliver Hamilton


53 58

Breaking the Mold —By Timothy Potter

Advocacy, It Works —By Cynthia Finley



Tax-Exempt Municipal Bonds Preserved!


Clean Water Impact

For nearly five decades, the National Association of Clean Water Agencies (NACWA) has been the nation’s recognized leader in legislative, regulatory and legal advocacy on the full spectrum of clean water issues. NACWA represents public wastewater and stormwater agencies of all sizes nationwide, and is a top technical resource in water quality, water management and sustainable ecosystem protection. NACWA’s unique and growing network strengthens the advocacy voice for all member utilities, and ensures they have the tools necessary to provide affordable and sustainable clean water for all communities. Our vision is to represent every utility as a NACWA member, helping to build a strong and sustainable clean water future.

Rudolph S. Chow Cynthia Finley Catherine R. Gerali Philip D. Guerin Adel Hagekhalil Oliver Hamilton Chris Hornback Adam Krantz Pamela H. Perez Timothy Potter Emily Remmel Bruce Roll Joshua D. Schimmel Erica Spitzig Brian Wheeler MANAGING EDITOR Anthony Viardo ART & DESIGN DIRECTOR Sarah Bixby PUBLISHED BY: The National Association of Clean Water Agencies (NACWA) Images c iStockPhotos & Adobe Stock CONTACT NACWA 1816 Jefferson Place, NW Washington, DC 20036 (202) 833-2672 Advertising & Marketing Anthony Viardo – Director, Communications & Marketing Membership Kelly Brocato – Director, Membership Development & Retention FOLLOW NACWA Facebook - @NACWAOfficial Twitter - @NACWA

DISCLAIMER: The opinions expressed in contributed articles are exclusively those of the authors alone, and do not necessarily represent official positions taken by NACWA.

3 Winter 2018










President’s Message

Working Together Through NACWA For A Better Water Future

ing as both the District Manager of the Metro Wastewater Reclamation District in Denver and the President of NACWA. I have learned one thing over my career, and it is that dedicated people, working together for a common cause larger than themselves, are the recipe for success. NACWA has made great strides in ensur-

ing a strong and growing network that can help address the complex challenges our communities face. In recent months, we have witnessed hurricanes, wildfires, and now, along the East Coast, a new foreboding term, the “bomb cyclone.” It brought frigid temperatures and widespread water and sewer main breaks to numerous communities, underscoring the need for continued investment in our aging water

infrastructure nationwide. We will withstand these challenges, however, because of our collective sense of service and because of organizations, like NACWA, that help us marshal our local strength into a national force. NACWA has changed its dues structure to be more equitable for small communities, ensuring the broadest possible participation in setting policy that reflects the needs of all public utilities—large or small, in the East or the West, in arid or wet regions, and in urban or rural communities. NACWA added more than 35 new members over this past year and already has 12 new members going into Fiscal Year 2018 (FY18)—a banner year—underscoring the unique value proposition and return on investment to be gained from a proactive national agenda.



t has been a remarkable experience serv-

Winter 2018


By Catherine R. Gerali

We created a new Arid State and Water 6

Quantity Workgroup—headed by accomplished leaders from California and Florida—to give


voice to water quantity issues and ensure these issues are fully integrated into NACWA’s strategic plan and advocacy agenda. NACWA, together with a broad array of allied organizations, successfully defended the tax exemption for municipal bonds as well as solid funding levels for the State Revolving Funds (SRFs) and the Water Infrastructure Financing and Innovation Authority (WIFIA)

Utility leaders and their staff have proven, time and again, to be the water sector’s chief innovators, forging a clear path toward our collective vision: the Utility of the Future.

in both the FY17 budget and the Trump Administration’s proposed FY18 budget (notably, these are the only major programs

As a farmer, I know full well that many hands

in these budgets that avoided deep cuts).

make for lighter work, and no great accom-

NACWA has also expanded its Engage®

I am most proud of how the incomparable

online peer-to-peer networks, providing a venue, and an invaluable opportunity, for utility executives and the entire utility’s staff to share best practices and solutions that lift up the sector as a whole—with an equal focus on large, medium, and small agencies.

plishments are achieved by only one person. NACWA staff and membership have consistently displayed a tireless spirit of collaboration with fellow water sector organizations to accomplish great things. This collaboration will no doubt be embodied by Water Week 2018 in Washington, DC, where we can build on

of water sector organizations and more than 1,000 Capitol Hill office visits by water sector leaders, who specifically elevated clean and safe water as a top national priority. Ultimately, there is reason to be optimistic. NACWA, and its members, know that hard, daily work, not slogans, advance the water sector and quality of life for all ratepayers. Utility leaders

respect we so very much deserve. By doing so, we will build on an already unparalleled legacy of water quality protection and sustainability. On behalf of NACWA, I thank you for your support.

Catherine R. Gerali Catherine R. Gerali

and their staff have proven, time and again, to be the sector’s chief innovators, forging a clear path toward our collective vision: the Utility of the Future. There are over 55,000 drinking water utilities and 16,000 publicly owned treatment works in our country. The governance challenge will only grow as the population expands, climate and resilience challenges persist, agriculture and industry advance, and technological capabilities evolve. Whether we represent a large, medium, or small utility; an urban, rural, or suburban region; or a wet or arid climate; we will only maximize our chances of success by sharing our stories, learning from

Catherine R. Gerali recently retired from her position as the District Manager of Metro Wastewater Reclamation District (MWRD) in Denver, CO, and served as NACWA’s Board President in 2017.

7 Winter 2018

include record participation from a broad array

one another, and collectively demanding the


the successes of last year’s Water Week. These

Clearing the air on CLEAN WATER ADVOCATE Winter 2018


By Adel Hagekhalil and Brian Wheeler, with Emily Remmel, Contributor

Clean Water Utility Leaders From Arid California And Temperate Florida Explore Water Reuse As The Primary Solution To Water Supply Challenges

California meteorologist comparing

supply challenges in meeting the evolving water

the weather conditions in Los Angeles

quantity and quality demands. These challenges,

to those in Orlando. Conventional wisdom would have you believe that the only thing that Southern California

however, provide an extraordinary opportunity for water sector leaders across the country to come together and advo-

and Florida have in common are

cate for “water reuse” as a solution

balmy temperatures and relatively

to long-term supply concerns.

predictable sunshine.

However, there is another lesser-known, or perhaps less-acknowledged, commonality between these two regions of the country: water issues. Although these states do not have even nearly analogous annual rainfall amounts—with areas in Southern California receiving an order of magnitude less than Florida’s average of 50+ inches—they do have comparable long-term water quantity issues.

Yes, it will take meticulous planning, innovative research and technology, and leadership—mixed with sustained determination—to proverbially quench these complex and historically entangled water quantity issues. But as clean water stakeholders and thought leaders, it is imperative to pay heed to this challenge, both for the sake of the communities we serve and the future generations that depend on an ongoing supply of clean water

As precipitation patterns

and a healthy environment in which

change and populations surge,

to thrive.

arid states, and even more

9 Winter 2018

temperate states like Florida, are encountering



t is not too often one would hear a

Clearing the air on arid states

The Florida Challenge —Brian Wheeler



What does Florida, a state with the Everglades and approximately 50 inches of annual average rainfall, have in common with the “arid west?” Besides having strong college football teams (relatively), Florida is also increasingly confronted with significant water supply challenges—a surprise to many people. Even with the state’s ample rainfall, its full rivers, and a landscape dotted with lakes and wetlands, Florida is often combatting water shortfalls.

THE POPULATION BOOM In 1980, Florida’s population was less than 10 million. Water supply was not a problem. However, today’s population exceeds 20.6 million and is growing at a rate of 800–1,000 people per day. Securing water supplies is now a paramount concern in Florida.

More than 30 years ago, Florida required that all discharges of wastewater effluent to surface waters be eliminated in Central Florida. Resourcefully, and innovatively for that time, utilities implemented reuse practices as a primary means of effluent disposal. With population growth and changing water supply needs, reuse has evolved from

The reasoning: most of Florida obtains its water supply from freshwater aquifers. An aquifer’s water supply is limited by its recharge capacity, and if there is no water replenishing the aquifer, it is impossible to continue to make groundwater withdrawals. In fact, the over-pumping of groundwater supplies is causing some areas of Florida to experience these aquifer limits. But, Florida has a solution.

Last year, Florida utilized 720 MGD of reuse – laying claim to more reuse than any other state.


water,” into their water supply plans. Reuse—a key driver in addressing community water supply needs—is a tool in a community’s water supply and resource toolbox. Once used as a tool to meet water quality requirements, reuse is now being used to address local supply needs.

to a water supply (quantity) strategy. Last year, Florida utilized 720 million gallons per day (MGD) of reuse, laying claim to more reuse than any other state, including California, which is a notorious friendly rival in the pursuit of water reuse initiatives. Technically, Florida’s reuse activities—which include landscape and agricultural irrigation, power plant cooling water and/or

11 Winter 2018

incorporated water reuse, or “reclaimed

an effluent disposal (water quality) strategy


To meet future needs, Florida utilities have

off-gas scrubbing, and industrial process or wash water, among others—produce enough water to meet the population’s essential needs, and can offset aquifer withdrawals and reduce demands on public water supply sources. Water reuse is an invaluable, growing resource tool for the general water sector in clean water management. With these longterm opportunities in play, state lawmakers should be more keen to develop—or make it as easy as possible for utilities to develop— water reuse programs that are protective of public health and the environment, and that complement the advancements that utilities have already achieved. DEVELOPING ALTERNATIVES There is a need to develop alternative water



supplies to supplement the traditional supplies. Brackish groundwater and highly variable and environmentally sensitive surface waters are substantially more expensive to develop than traditional resources. Developments and advances in indirect potable reuse (IPR) and direct potable reuse (DPR) technologies have made these reuse alternatives competitive with the development of other alternative water supplies. Some Florida communities are pursuing IPR or DPR alternatives to supplement their future water supply, including the city of Altamonte Springs, which was recently recognized with the WateReuse Project of the Year distinction for its innovative DPR pilot project. A NEWER, HOLISTIC APPROACH It is becoming evident that a holistic approach is the only approach. Florida takes a holistic approach to

By 2035, the population is projected to be 4.1 million people with a water demand of 1.1 BGD. The Upper Floridan Aquifer can only sustain a continuous withdrawal of 850 MGD – leaving a deficit of 250 MGD supply.

supply plan and identify the most feasible

ing a regional water supply plan. The Central

projects to meet long-term needs.

Florida Water Supply Initiative (CWFI) showcases this evolving holistic approach to water supply planning and the incorporation of water reuse.

Florida may not fit the climate mold of an arid state, but the challenges are comparable to more traditional water-supply-limited states. As more states begin to face water

Currently, 2.7 million people reside in five

supply and quality issues, there are tremen-

county planning areas, and they have a

dous opportunities for states and utilities to

demand of 800 MGD drawn from the Upper

learn from each other.

Floridan aquifer, which has a withdrawal limit of 850 MGD. Both population and demand are predicted to increase. However, over 150 potential projects—87 involving water reuse

When looking holistically and in tandem, conquering acute and chronic water supply challenges is no longer unreachable.

with capabilities of adding 106 MGD—were identified in a cooperative stakeholder regional supply plan. Approaches that consider holistic water supply sources and water reuse, such as the CFWI, demonstrate how communities can develop a robust water

Brian Wheeler is the Executive Director for Toho Water Authority in Kissimmee, FL. Brian is also the co-chair of NACWA’s newly formed Arid State and Water Quantity Workgroup.


integrating all water resources by develop-

Winter 2018


Clearing the air on arid states

The California Dilemma —Adel Hagekhalil



Conditions in the arid west have become more acute, and solving water quality and quantity challenges will take a new, more subtle approach. We hope all agencies, not just those in the arid states, can learn from our struggles.

California and other arid western states are experienced in dealing with extreme drought conditions and long-term water supply challenges. Transferring water between basins, constructing desalination projects, and utilizing groundwater reserves have been long-standing practices (among others) to meet these water quantity challenges. Because of California’s tenure in dealing with water supply issues, utilities in the state have the knowledge, expertise, and resources to guide utilities nationwide in the water quan-

As holistic as this stormwater approach sounds, the cost of compliance for Los Angeles alone is a staggering $8 billion over the next 25 years.

tity and quality practices that work and those

there is considerable dependence on importing water, which has become even more magnified by the recent drought. Because of longterm supply concerns, many of California’s communities are having to invest heavily in water conservation, water reuse projects, and stormwater capture and reuse. MINUSCULE RAINFALL, MASSIVE PRICE TAG

Even though California and other arid states receive significantly less precipitation than

faced with unique compliance challenges relating to stormwater regulations in permits. For example, Los Angeles has over 22 total maximum daily loads (TMDLs) across four watersheds. Recognizing the need for additional, longterm water supplies, California is taking a different approach with stormwater. Through collaboration with the region’s regulatory agencies and environmental partners, the latest municipal separate stormwater system (MS4) permit recognizes the need to address stormwater as a resource, not just a pollution

15 Winter 2018

In Southern California, especially Los Angeles,

more temperate states, many utilities are


that don’t.

source. The permit requires permittees to develop enhanced watershed management plans (EWMPs) by taking a regional watershed-based approach that is predicated on capturing the 85th percentile storm. As holistic as this stormwater approach sounds, the cost of compliance for Los Angeles alone is a staggering $8 billion over the next 25 years. If tied to community benefits, like green infrastructure projects, funding this stormwater project may be more feasible and affordable. However, many regulatory agencies are concerned with green infrastructure and

Advocating for regulations that allow for flexibility provides the highest benefit to communities...

how utilities can “guarantee� a reduction in stormwater pollution and a recharge of local groundwater supplies. One solution would be for Congress to clarify in the Clean Water Act that green infrastructure is a preferred approach, and compliance and enforcement policies should be more flexible in arid states.



FINDING FLUID SOLUTIONS Many of the streams and rivers in the west are effluent-dominated and extremely dependent

on discharges from publicly owned treatment works (POTWs). As greater emphasis is placed on stormwater capture and water reuse, the designated beneficial uses of many streams are being challenged. By reducing the discharges into surface waters, these reuse and capture practices can lead to reduced instream flows. With an increase in population and demand, coupled with a limited supply, the paramount question becomes how to balance maximizing water reuse initiatives

while maintaining the designated uses of sur-

current regulations make it difficult to do so

face waters. Keep in mind that many of these

without impacting permit requirements. A

designated uses require streams and rivers to

potential solution would be to regulate the

maintain a high velocity of flow.

augmentation of recycled water discharges to

lished through evidence-based science, and informed by community input; and right now, this is not happening. In recognition of these needs, however, the California State Water Resources Control Board recently held a workshop in Los Angeles to bring these issues to the surface and develop a balanced plan to move forward. DEVELOPING ALTERNATIVES As cities in the arid west look to conserve more water and reduce the waste of high-quality, potable water, alternative sources of water are needed to supplement recreational surface waters. Recycled water, or “captured stormwater,” is a great alternative source to augment traditional potable discharges to these water bodies. However,

order to encourage conservation of potable supplies. KEYS TO ADVANCING RESILIENCY Developing resiliency strategies and longterm sustainability is necessary. Whether resiliency is addressed in projects like redundant force mains, stormwater cisterns or capture projects, groundwater recharge projects, or waste-to-energy projects, it is imperative to have regulatory agencies prioritize funding for projects that contain resiliency components. Therefore, it is even more important for utilities to incorporate resiliency components in all projects by offsetting some of the costs. Synonymous with this effort, advocating for regulations and guidelines that allow for flexibility will provide the highest benefit to the community and to the environment. Whether by increasing stormwater capture, investing in green infrastructure projects, increasing recycled water, or revitalizing communities and waterways, it is more critical than ever that utility leaders ensure community engagement and a net environmental benefit approach are the key drivers for regulatory proposals moving forward.

Adel Hagekhalil is the Assistant Director of the City of Los Angeles – LA Sanitation, and a member of the NACWA Board from 2008 – 2017, serving as an officer and Association President (2015 - 2016)

17 Winter 2018

must be more reflective of reality, estab-

groundwater, or surface waters, differently in


To reflect modern needs, beneficial uses



The Watershed Moment By Bruce Roll

As The Innovative “Tree For All” Approach Matures From Pilot Projects To Landscape Conservation Programs, Historic Opportunities And Challenges Emerge We have come a long way with the “One Water” concept—that is, the idea that all water moves in a closed system through cycles of use and reuse in watersheds throughout

resource recovery, ecological health, and renewable energy production. It is inspiring that we are now talking about water and its benefits in a way that brings utilities and communities together and begins to knock down the regulatory silos of the Clean Water Act and the Safe Drinking Water Act. We are clearly at a tipping point where we are beginning to have clarity on the kinds of One Water projects we want to

We are clearly at a tipping point where we are beginning to have clarity on the kinds of One Water projects we want to implement.

implement. This transformation has been a long time coming. And it is now setting the stage for some historic challenges as we seek to create healthy watersheds in an era of unusual weather patterns and rapid urbanization. There is also an elephant in the room that we are only beginning to think about. That elephant is scale. We will need to act on an unprecedented scale, with new kinds of partners and resources that reach beyond utility-based user fees, if we want to create watersheds that are resilient and able to thrive in the face of these historic challenges.

19 Winter 2018

conversations about direct potable reuse,


the world. Throughout the water sector, we are witnessing groundbreaking community

To work at scale, we also need to take on new approaches to planning and project delivery. Having spent the first half of my career doing watershed, stormwater, source water protection, and Endangered Species Act plans, it has become evident to me that the vast majority of plans never move beyond pilot projects and a few months or years of pounding the pavement in search of more funding. More times than not, new shelf art is created, and we start the process all over again when a new topic triggers another planning effort.


“Landscape conservation” is a concept that has arisen in response to the challenges of changing weather patterns and urbanization, as well as a perceived excessive focus on sitebased conservation. It aims to take a holistic approach, looking not just at biodiversity, but also at local economies, working lands, and the health and social benefits of the environment (see Figure 1).

As often happens when dealing with major issues on the ground, a large, important question comes together like gathering droplets forming a burgeoning stream: could there be a different approach that opens the door to landscape-scale conservation in our watersheds?

The Tualatin River Watershed in Northwestern Oregon is home to “Tree for All,” one of the largest and most successful landscape conservation programs in the country Since 2005, Tree for All has restored more than 120 river miles across more than 25,000 acres in the rural and urban landscapes of this watershed. It employs a community-based systems approach to build-


ing watershed resiliency. Engaging partners


from the public, private, and nonprofit sectors, the program weaves together diverse strategies and funding mechanisms to enhance watershed resiliency across the entire 750 square-mile watershed—home to corporate headquarters, productive farmland, vast forests, and massive urban and suburban development. ( RETHINKING REGULATORY



Creating a program capable of acting on a watershed scale has been an interesting journey. In our case, a regulatory driver became a catalyst for the development Adapted from Figure 1

of a landscape conservation program.

Like many utilities across the nation, Clean Water Services (CWS) was faced with regulatory requirements that gave it a choice: invest $150 million in facility upgrades or find a creative way to work with Mother Nature to meet the regulations. CWS and the communities in Washington County, Oregon recognized that there was a unique opportunity to think outside the box with an innovative riparian restoration program that could create watershed-wide benefits. This riparian restoration program became the foundation for what is today a very successful landscape conservation program.

farms working in collaboration, millions of dollars contributed through the federal Farm Bill and by local governments, the engagement of hundreds of community volunteers, establishment of a new national wildlife refuge, and more than two million native plants going into the ground in a single year. These are a few of the many results that demonstrate how the Clean Water Act can serve as a catalyst for landscape conservation. Twelve years into this journey, CWS is meeting its regulatory obligations and at the same time catalyzing the kinds of actions needed for a healthy and resilient watershed. By working with more than thirty partners, the Tree for All program has generated the millions of dollars needed to fund a landscape conservation program. Notably, CWS was able to access existing funding sources, many of which can be found in every community. SCALING UP: RETHINKING PROJECT DELIVERY AND FINANCING

Pilot projects have a role. They are an essential part of moving to scale, and they create an

21 Winter 2018

to see “landscape-scale” results, such as 100

Tree for All is a community partnership of cities, nonprofits, farmers, volunteers and others who have joined hands (and shovels) to plant native trees and shrubs along the Tualatin River and its tributaries. Streams lined with native vegetation provide cleaner, cooler water, better flood management, and fish and wildlife habitat. It’s good for Mother Nature and good for the community.


As the Tree for All program matured, we began

opportunity to think about new partnerships and the planning and administrative costs needed to deliver at scale. For the Tree for All program, two important things happened in the course of conducting pilot projects: multiple partners and resources were engaged, and innovative planning and project delivery methods were created. Instead of hearing a speech about CWS regulatory obligations, partners were invited to conversations about the actions and outcomes that CWS proposed to lay out on the landscape. This meant talking about things like aquatic and terrestrial diversity, healthy floodplains, urban and agriculture economies, sense of place, recreation, and human health. Landscape thinking is taking root in the region by meeting each partner where they stand or framing the conversation in a way that clearly



articulates how these actions would help them achieve their goals. For farmers, it was about voluntary incentive programs that made their farms more successful. For park interests and groups, it was about supporting recreational opportunities. For environmental interests and groups, it was about creating the aquatic and terrestrial wildlife habitat needed for a healthy watershed. These are a few of the many interesting partner conversations were needed to bring actions to scale. Thinking at the “landscape scale� provides a broader view of outcomes, and, at the same time, demands

Making room for a resilient Mother Nature meant that we deliver projects through her eyes. that we rethink how to plan and deliver projects. Making room for a resilient Mother Nature meant that we deliver projects through her eyes. This approach requires innovative contracting methods,

new approaches to easements,

real-time monitoring, integrated adaptive

changing weather patterns and rapid urbaniza-

management, restoration asset management

tion. The Tree for All program’s partners have

systems, and the list goes on. Ultimately, this

made transformative progress regarding water-

required—and will continue to require—proj-

shed health and resiliency. However, there are

ect delivery methods that deliver multiple

always new opportunities to innovate, collabo-

outcomes, including clean water, healthy soil,

rate, and achieve results. The Tree for All story

community engagement, and the ecological

demonstrates that a regulatory obligation can

diversity essential for a resilient and healthy

serve as a catalyst for landscape conservation.


It also prompts us to consider the role that landscape conservation plays in the emerging


Utilities of the Future paradigm.

As the utility industry continues our One

vation, scale, and watershed resiliency. They appear to be important topics as we think about

Bruce Roll is the Director of Watershed Management for Clean Water Services and the nonprofit Clean Water Institute in Hillsboro, OR, a founding member of the Intertwine Alliance, and a key developer of the Tree For All Landscape Conservation Program. 23 Winter 2018

paths with concepts like landscape conser-


Water journey, we find ourselves crossing

Tackling Nutrient Pollution at the Watershed Scale By Chris Hornback



The National Association of Clean Water

levels and is working to build on this momen-

Agencies (NACWA) convened a Nutrient

tum to “scale up� the collaborative approach.

Summit in March 2017, gathering stakeholders from the clean water, agriculture, state regulator, and environmental NGO communities to explore new approaches to addressing the nutrient challenge.

The federal Farm Bill provides an important source of potential funding for these collaborative efforts, and NACWA is actively engaging in the ongoing efforts to reauthorize the Farm Bill. The Association is working to better

The Summit sought to build on the growing

ensure that clean water utilities are incentiv-

number of examples where the full range of

ized to work with agricultural interests and to

nutrient sources and key stakeholders have

reduce the burden

successfully collaborated at a watershed scale

associated with

to advance nutrient man-

current Farm

agement. NACWA

Bill programs

has noted a

that support

greater willing-

these types

ness by its mem-

of watershed

bers and members

partnerships. At

of the agricultural

the same time,

sector to find common

NACWA is work-

ground at the national, regional, and local

ing with the U.S.

Environmental Protection Agency (EPA) to explore more flexible ways to implement nutrient control requirements and potential new pathways for addressing nutrient impacts outside of the normal Clean Water Act (CWA) programs. In July 2017, NACWA’s Board of Directors adopted a position statement to guide the Association’s engagement on the nutrient issue with EPA, Congress, and the agriculture community, and to focus the Association’s advocacy efforts regarding the Farm Bill. The statement outlines six specific “outcome areas” that form NACWA’s advocacy objectives:


Increased and more meaningful engagement by all nutrient sources, with balanced accountability for nutrient management actions

Greater utilization of existing CWA flexibilities

More widespread adoption and an increased scale of coverage for collaborative watershed nutrient management approaches




Acceptance and adoption of a mid-to-long-term adaptive management (or similar) model as an alternative to the current water-quality-based standards (WQBS) point-source-focused approach

Increasing the amount and flexibility of funding to better support “at scale” nutrient management efforts, directing funds to the most productive investments, and addressing the shortfall of support for offfield agricultural investments

Enhanced monitoring that provides a basis for broader nutrient source accountability and supports adaptive management as an alternative nutrient management approach

NACWA believes these advocacy objectives and efforts will (1) promote greater overall collaboration with, and engagement by, the key non-point nutrient sources—specifically the agricultural sector—and (2) address critical aspects of the CWA regulatory and policy framework to ensure smarter and more effective outcomes for its member utilities and the communities they serve.

Chris Hornback is the Chief Technical Officer at NACWA.

25 Winter 2018




MS4 Permit Requirements: the



By Philip D. Guerin and Joshua D. Schimmel

Fighting For Practicality In Stormwater Regulation The permit requires MS4s to comply with water quality standards in addition to reducing the discharge of pollutants to the maximum extent practicable (MEP) as required by the Clean Water Act (CWA), and it imposes strict compliance schedules for doing so. The permit also attempts to regulate flow in the form of specific retention requirements. The 60-page permit, with 232 pages of appendices, directs municipalities to undertake an array of tasks, including the following: n R  educing phosphorous levels in stormwater as identified in total maximum daily loads (TMDLs) and calculating, tracking, and reporting reductions in accordance with the dictates in a 140-page appendix to the permit. Some communities would have to achieve phosphorus reductions of over 50% using both structural and nonstructural approaches.

27 Winter 2018

In April 2016, Region 1 of the U.S. Environmental Protection Agency (EPA) issued a general National Pollutant Discharge Elimination System (NPDES) permit for small municipal separate storm sewer systems (MS4s) in Massachusetts. The MS4 permit, which supersedes the original 2003 general permit, was intended to regulate stormwater in more than 250 municipalities in Massachusetts and was originally scheduled to take effect on July 1, 2017.




ushing back on unreasonable regulation is as important as ensuring compliance with responsible regulations. The permit we are examining here is, unfortunately, an example of the former.

n Implementing a prescriptive Illicit Discharge Detection and Elimination (IDDE) program to locate and remove all non-stormwater discharges from the stormwater system and to track and report these efforts. All outfalls would have to be ranked and their respective catchment areas thoroughly investigated within 10 years. n Implementing measures to regulate pre- and post-construction stormwater runoff at new and redeveloped sites of one acre or larger. The permit allows the federal EPA to dictate growth and economic development in Massachusetts cities and towns.

terms of frequency, magnitude, and duration of flows as well as in the amount and types of pollutants it carries. Thus, Congress explicitly set forth a standard to regulate stormwater discharges differently. The MS4 permit disregards Congress’s intent by forcing communities to meet water quality standards in addition to satisfying the MEP standard, at the same time dictating unreasonable and impractical additional actions. In actuality, the permit sets communities up to fail, subjecting them to enforcement actions by EPA and thirdparty advocacy groups. A UNIFIED FRONT, A NEEDED REPRIEVE



EPA’s own analysis projects the new requirements would cost each city or town between $400,000 and $1.35 million. In total, the permit would impose immense regulatory burdens on Massachusetts communities, which could cripple local budgets and impose huge rate hikes and fees on residents and businesses. EPA’s own analysis projects that the new requirements would cost each city or town between $400,000 and $1.35 million. INCONSISTENT STANDARDS, MOVING TARGETS The permit as written is inconsistent with the CWA’s clearly articulated standard, which requires MS4s to reduce stormwater pollution to the MEP. In 1987, Congress created this practicability standard for MS4s because of the unique nature of stormwater runoff and the challenges associated with it. EPA recognized that traditional end-of-pipe controls used at industrial and municipal wastewater facilities were not well-suited to stormwater, which varies widely in

Due to the importance of this issue in the state,

the Massachusetts Coalition for Water Resources Stewardship (MCWRS) — an organization of municipalities and public waste- and stormwater utilities promoting watershed-based policies to effectively manage and conserve water resources — joined with the Town of Franklin, Massachusetts, and filed an appeal in the U.S. Court of Appeals for the First Circuit. The City of Lowell, Massachusetts, as well as the National Association of Homebuilders and its Massachusetts affiliate, also challenged the permit in the First Circuit. Simultaneously, the Center for Regulatory Reasonableness filed an appeal in the U.S. Court of Appeals for the D.C. Circuit. The Conservation Law Foundation and the Charles River Watershed Association appealed the permit as well, since they did not feel that it would do enough to protect waterways. The appeals were consolidated in the D.C. Circuit. To date, the appeal has seen success in producing a one-year postponement of the permit’s effective date to July 2018. This postponement came about through the efforts of the MCWRS and has provided impacted

n T  he numerous legal challenges. n T  he exploration of alternative dispute resolutions. n T  he delay’s alignment of the Massachusetts permit with a functionally identical MS4 permit issued for New Hampshire, which already has a July 1, 2018 compliance date. The Massachusetts Rivers Alliance, an organization of river and watershed advocacy groups, has challenged EPA’s postponement of the permit, hoping to have it overturned so that the permit can take effect immediately. Just recently, the Massachusetts Attorney General (AG) filed an amicus brief in support of the Rivers Alliance legal challenge. While undoing the permit postponement would be harmful to over 250 municipalities, the AG claims it is necessary to push back on the Trump Administration’s efforts to roll back environmental protections. STAKES ARE HIGH NATIONWIDE While the permits apply only in Massachusetts and New Hampshire, the outcome of this case is likely to set a crucially important national precedent that defines the scope of EPA’s regulatory authority relative to local governments and their MS4s— because the requirements in question were established by EPA itself and will squarely address the extent and limits of federal CWA authority. MCWRS has been working closely with NACWA, which has a long history

We believe that each community has unique characteristics and challenges that should shape its individual approach to achieving improvements in managing stormwater. We believe that this approach aligns with Congressional intent. As written, the permit eliminates the opportunity to develop an adaptive management approach that addresses communities’ specific challenges and environmental priorities in meeting the MEP standard. While the permit was postponed, the appeal moves forward. The court has appointed a mediator in hopes that the parties, including EPA, the environmental community, and municipalities, reach a resolution. MCWRS is at the table, participating in these negotiations, but the appropriate legal standard is clear and nonnegotiable. MCWRS’s role is to give Massachusetts municipalities an opportunity to obtain a fair, reasonable, and legally sound permit that provides regulatory certainty can endure political shifts. It’s a battle worth fighting, and we intend to see it through.

Philip D. Guerin currently serves as Director of Water and Sewer Operations for the City of Worcester, MA. He is also the current President of the Massachusetts Coalition for Water Resources Stewardship. Joshua D. Schimmel is the Executive Director of the Springfield Water and Sewer Commission, and serves as Board Member for the Massachusetts Coalition for Water Resources Stewardship.

29 Winter 2018

EPA gave several reasons for the postponement:

of defending the MEP standard in litigation as the appropriate standard for MS4 compliance. NACWA views this appeal as the most important MS4 litigation to date, with the potential to set a precedent affecting MS4s across the country.


communities a reprieve from this onerous permit for at least one year.

The Year of Stormwater By Erica Spitzig and Emily Remmel



If we had to put a name to it, 2017 was the Year of Stormwater, or the year in which the complexity and uncertainty surrounding stormwater permitting became palpable. It was the year in which EPA and the states began implementing the Remand Rule for the issuance of National Pollutant Discharge Elimination System (NPDES) permits for small municipal separate storm sewer systems (MS4s) and the year in which permits issued by EPA Region 1 requiring small MS4s in New Hampshire and Massachusetts to comply with water quality standards (WQS) were set to take effect. For anyone operating a small MS4 in the United States, these were major developments.

But how did we get here? And what makes these developments so significant? Throwback to 2003. Beyoncé’s hit “Crazy in Love” was the definitive song of the summer, and the Ninth Circuit partially remanded the Phase II stormwater rule to EPA in the landmark case Environmental Defense Fund Center v. EPA. This decision required EPA to rethink the process for developing and issuing NPDES permits for small MS4s and to ensure that the new process provided more transparency and opportunity for public engagement. This is where things began to get tricky. Fast-forward to December 2016: Beyoncé was still topping the charts with her Lemonade

The flexibility inherent in this MEP standard is important. Controlling what pollutants are discharged in stormwater—never mind the quantity or concentration—is a significant challenge for many communities. EPA’s shift toward water-quality-based requirements not only exceeds the agency’s authority under the statute but also will place a significant burden on utilities seeking to meet these more stringent standards. As the states with authority to issue NPDES permits implement the Remand Rule, there are rumblings that these states will follow EPA’s lead on water quality-based requirements. Draft permits are currently out for comment in Oregon and Maine, and the ultimate permit terms may signal this trend at the state level.

1. R  ead your permits with care—even the boring boilerplate at the back! The most pernicious language may not be in the sections you think you care about. Read every single word of your existing permit and draft renewal permits, and do not be afraid to kick up some dust about unreasonable or unlawful provisions. 2. W  atch out for water quality-based requirements! They may be hidden in catchall language incorporating WQS by reference. This catchall language can be a source of citizen suits that would hit your utility with unexpected requirements (and penalties!) after the fact. 3. Read NACWA’s Stormwater Permitting Guide! To help ease the difficulty of navigating permitting complexities, NACWA is releasing a Stormwater Permitting Guide. This comprehensive guide demystifies the challenges of permit renewals, implementation, and inspections or enforcement proceedings, and will be available on the “Publications Section” of the NACWA website (”

Erica Spitzig is Deputy General Counsel for NACWA. Emily Remmel is the Director of Regulatory Affairs at NACWA.

31 Winter 2018

Meanwhile, trouble was brewing in EPA Region 1, with the issuance of NPDES permits in New Hampshire and Massachusetts marking EPA’s apparent shift toward more restrictive water quality-based requirements, as opposed to the more flexible Maximum Extent Practicable (MEP) standard (see preceding article).

What can you do to avoid getting caught up in the complexities of the Remand Rule and getting stuck with onerous requirements that your community cannot meet or afford?


album, and EPA finally issued a Remand Rule in response to the decision in the Environmental Defense Fund Center case. The rule significantly changed how EPA and the states issue permits for small MS4s. The impact of this change is only beginning to come to light, but it will likely create a greater permitting and litigation burden for both the states and MS4s.

NACWA Thanks its 2018

All-Conference Sponsors for Their Many Contributions to the Clean Water Community



interested in becoming an all-conference sponsor? Contact Paula Dannenfeldt at





The Time Is Now For Congress And EPA To Address The Twin Challenges Of Aging Infrastructure And Affordability

By Rudolph S. Chow and Adam Krantz


he Clean

namely the ratepayers.

Water Act and Safe Drinking

The water infrastructure

Water Act

and affordability chal-

are hallmark

lenge can be exemplified

pieces of

by many urban and rural


utilities across the country—

legislation that for

and by utilities of all sizes—but

decades have shaped

clearly through the lens of the City of Baltimore, situated approximately 45 miles from

Over these decades, regulatory requirements

Capitol Hill.

have expanded; systems of pipes and water treatment apparatuses have continued age; population growth or decline has created different pressures on the customer bases of certain cities; and the gap between wealthy and poor has become more stark, which also leads to severe affordability pressures. During the same period, federal investment in our water infrastructure has plummeted, leading to a national funding gap of somewhere between $650 billion to $1

BALTIMORE’S WATER INFRASTRUCTURE STORY Baltimore’s water and sewer systems were largely constructed 80+ years ago and, frankly, had their maintenance deferred in past years, which has allowed rates to remain artificially low. As a result, customers took low-cost water services for granted and were ill-prepared for rate increases once the aging infrastructure could no

trillion over the next 20 years.

longer be ignored.

It is against this backdrop that clean water advo-

The story is a common one:

cates — which should include everyone who uses

n Thousands of large and small water main

tap water or flushes a toilet— seek to encourage Congress and the U.S. Environmental Protection Agency (EPA) to (1) engage in a thorough review of how it treats municipal affordability assessments, and (2) provide municipalities with maximum flexibility when it comes to achieving regulatory compliance and the prioritization of projects based on the maximum net environmental benefit to those who are footing the bill,

breaks have inconvenienced or endangered customers and their property, and have resulted in enormous water losses. n Sanitary sewer overflows caused by infiltration and inflow from the collection systems, hydraulic capacity issues, and structured overflows have resulted in sewage in streets, sewage in streams, or basement backups.

35 Winter 2018

treatment services have evolved in our country.


how drinking water and wastewater

we can explore these challenges

n Sinkholes caused by failures in stormwater mains and wastewater mains have led to tens of millions of dollars in response and repair costs and a negative economic impact on businesses and residents in the area. In an effort to ensure that financial resources are effectively targeted to optimize the efficiency and reliability of each utility, Baltimore City’s Department of Public Works (DPW) founded the Office of Asset Management (OAM) to plan for, and proactively address, significant challenges for underground and above-ground assets. This office has successfully identified critical repairs needed and prevented potential significant failures. BALTIMORE’S DEMOGRAPHICS Across the country, water and sewer rates con36

double the rate of inflation, and where water/


tinue to increase at a national pace of nearly

averaging over $800 per household annually, and

sewer rates were once modest, they are now well over $1,000 per household in some communities. These bills are now being noticed, painfully in many cases, and this is especially true in cities with severe affordability challenges. Baltimore’s population is older and poorer than many communities (Source: 2010 Census data): n 26% of the population is at or below the federal poverty line. n A  nother 24% is below the City’s median household income of $39,386. n M  ore Baltimore residents have low annual incomes, and fewer Baltimore residents have high annual incomes, than national residents. LOW-INCOME ASSISTANCE Many municipalities are implementing assistance programs for

low-income customers, and Baltimore is among them. Baltimore’s current assistance program includes the following: n Senior Citizen Low-Income Assistance Program – customers 65 years and older with annual income at or below $30,600 receive a 43% discount on their volumetric water consumption and sewer charges (fiscal year 2016 [FY16] witnessed a total benefit of $585,298 provided to 2,777 eligible customers). n Hardship Exemption Program – income-based and other assistance program eligibility (such as the federal LIHEAP program for home heating) exempts customers from paying their storm water remediation fee and Chesapeake Bay Restoration Fee, a state program (in FY16, more than 3,000 customers were eligible for this exemption program, which averages a savings of $10 per month). n Low-Income Water Assistance Program – provides eligible customers (income-based) with a $216 credit toward delinquent bills when facing potential turnoffs or tax sale (in FY16, a total benefit of $356,246 was provided to 1,992 customers).

Payment Plans are also offered to help customers get control of their delinquent accounts: n Traditional twelve-month payment plan (50% down payment, balance paid over twelve months). Seniors enrolled in the Senior Citizen Low-Income Assistance Program do not have to pay a down payment.

six months). n T  he Low-Income Assistance Program may be used to help with these delinquencies. It is critical to note, however, that the financial assistance for these programs is taken from the utility’s revenue. As such, ratepayer assistance programs must be balanced with maintaining affordability for the remainder of the ratepayers and with the need for infrastructure investment, both proactive and reactive.


Baltimore’s financial challenges are directly linked to regulatory compliance under the Clean Water Act (CWA) and Safe Drinking Water Act (SDWA). Under the CWA, a consent decree to improve our sanitary sewer collection system will cost $2.5–3 billion (2002–2030). Under the Safe Drinking Water Act, covering all finished-water reservoirs would cost Baltimore nearly $400 million, with the most expensive projects, namely Druid Lake and Lake Ashburton, just beginning to move forward—each more expensive than the first three combined. Baltimore is also under a municipal sanitary storm sewer (MS4) permit. And while the city currently collects a fee to cover the costs of work to meet the terms of the permit, the cost for helping to restore streams associated with this effort are likely to increase as well. This overall financial landscape is made even more complicated by the ongoing political pressure to limit rate hikes, an uncertain commitment from the federal government in terms of partnering on the needed investments, and the uncertainty of potential additional unfunded mandates at the state or national level.

37 Winter 2018

money down, balance paid over


n N  ew six-month payment plan (no

Under the Safe Drinking Water Act, covering all finished-water reservoirs would cost Baltimore nearly $400 million...

infrastructure package, and that promise has not yet been fulfilled. NACWA will continue to hold the Administration to this promise. Similarly, all efforts must be made to continue funding the recently created Water Infrastructure Finance and Innovation Act (WIFIA) program, which is also a low-interest loan program. Baltimore is fortunate enough to have been invited to apply for this program. NACWA is continuing to work with key municipal organizations to ensure that the tax exemption


for municipal bonds remains intact. The exemp-


passed tax reform package, although the legisla-

There are several vital programs that the fed-

engage in advance refunding of these bonds—an


eral government must continue to fund. First and foremost is the State Revolving Loan Fund (SRF), which has been a critical tool for low-in-



terest loans at the local level. Through focused advocacy, NACWA and its fellow water sector organizations have successfully secured consistent funding for the SRF in recent federal budgets. However, the Trump Administration promised a tripling of this fund through their

tion was successfully protected in the recently tion took away the authority for municipalities to activity that saves the municipal water sector $1–2 billion by buying back the outstanding bonds when interest rates decline. NACWA will be working to have this capacity reinstated in future congressional tax reform legislation. Finally, and perhaps most importantly, the federal and state governments must begin to see the municipal utilities as co-equals in protecting our cherished water resources. The

the greatest environmental bang for the increasingly limited ratepayer buck. Allowing municipalities to engage in integrated planning and regulatory prioritization, and to holistically assess their community’s affordability restraints, is vital. This demands a move away from the states’ and federal government’s perception of themselves as “enforcement-first” entities, and to have them instead consider themselves “partners” in compliance assistance and assurance. In October 2017, a congressionally

cation strategy with its regional and state regulators to ensure better consistency among the regions. n EPA innovation should be strengthened through integrated planning (IP), stormwater management practices that utilize business models like community-based public-private partnerships (CBP3s), and creative financing mechanisms such as leveraging of WIFIA to expand SRF lending activities as a key to providing effective cost reductions.

requested report titled, Developing

Congress and the EPA should move

a New Framework for Community

forward immediately to implement

Affordability of Clean Water

the NAPA study’s recommen-

Services, was published

dations. In Congress, where

by the National Academy

the Senate has unanimously

of Public Administration

passed bipartisan integrated

(NAPA), and made several key

planning legislation, it is time


for the House to do the same and for President Trump to sign

n Median household income

the package into law. This would

(MHI) is an inadequate metric

be a terrific step toward the goal

for identifying affordability issues and the EPA should instead use concise, valid, easily-retrievable, straightforward, and comparative criteria for improving the metrics with a common starting point for all

of a meaningful and long-lasting localstate-federal partnership, and toward addressing an affordability challenge that will only grow if ignored.

permittees. n The residential indicator should include all water costs, including drinking water costs, and should focus on low-income users that are most vulnerable to rate increases, rather than median household income. n The financial capability indicator should be revised to focus on operational efficiency, debt burden, and managerial effectiveness; expanded to include the socioeconomic components affecting the utility’s market condition; and be used in all clean and drinking water regulatory decision-making.

Rudolph S. Chow is the Director of the Baltimore City Department of Public Works (DPW) and serves as a NACWA Board Member. Adam Krantz is the CEO of NACWA.

39 Winter 2018

ance, and how to do so in a manner that achieves

n The EPA should improve its two-way communi-


municipalities know how best to achieve compli-


$498.32 million

















$112.24 million





$495.83 million

$101.4 million

$303.23 million


$60.88 million


$119.20 million






$190.37 million

*All data used in the creation of this visual is taken from an analysis conducted for NACWA and AMWA by SJ Advisors, LLC. *Insufficient data available for the states of Wyoming and Vermont. *The full report, including state-by-state information sheets are available on NACWA’s website (

Through advocacy and perseverance, NACWA, along with its partners and stakeholders, have preserved the tax-exemption for municipal bonds in the 2017 tax reform package. Had it not, utilities and ratepayers would have been on the hook for huge dollar amounts. Often buried beneath legislative detail and politics, these advocacy victories often go unnoticed. So, to provide proper context to this victory, we present the answer to a simple bottom line question:



$875.01 million

$133.12 million

$262.34 million

$456.81 million













$31.66 million $76.43 million $148.82 million $2.60 million $19.75 million $165.29 million


$112.35 million

$267.91 million

$33.35 million









$291.30 million

$225.50 million



41 Winter 2018








PUERTO RICO $184.42 million


$16.45 BILLION



of water service disruption

Water is crucial to the health and survival of every citizen, every day. Naturally, water infrastructure should be funded at the federal and state levels with an emphasis and priority it is presently not receiving. Meanwhile, water pipes, drains, sewers, levees, etc. are aging, outdated and inadequate in many communities.

Priority Gap: Over the years, the Federal Government’s contribution to total water infrastructure capital spending has decreased significantly.


Winter 2018


Closing this priority gap in water infrastructure investment would result in $220 billion in annual economic activity and result in 1.3 million jobs annually.

Statistics derived from the report, The Economic Benefits of Investing in Water Infrastructure, published by the Value of Water Campaign (, a campaign of the U.S. Water Alliance.





How Employee Inspiration & Involvement Can Unleash An Organization’s Mass Communications Potential

By Pamela H. Perez, with Anthony Viardo, Contributor

Advocates In marketing jargon, this person is known as a “brand evangelist,” which loosely means a person who believes so strongly in a product or company, or is so enthusiastic about it, that he or she freely and actively tries to convince others to like it, too (think Apple customers). These particular types of

As clean water utilities, our organizations may not sell commercially branded products, but I contend that this model is both appropriate and valuable: publicly owned utilities are ultimately dependent on paying customers, whose attitudes, perceptions, and satisfaction are paramount to the agencies’ success

45 Winter 2018

consumers are a marketer’s dream because they spread a company’s message on their own initiative and are, on the whole, perceived as much more trustworthy than ads, salesmen, or paid company pitchmen.



was recently inspired by one of our wastewater collection managers, who was working on a sewer issue when he realized the need for a tool that didn’t actually exist. So, he took it upon himself to develop the tool, probably in his free time, and when the tool proved useful, he developed more of them. He didn’t stop there: The animated employee began showcasing his work and achievements on his personal Twitter page—enough to get noticed. He was eventually featured in a national industry publication and, from there, amassed a large social media following. This had the ancillary effect of driving more followers to the LA Sanitation Twitter account and website. From the organization’s perspective, this employee is an absolute gift that continues to give on multiple levels.

in many ways. In the water sector—where the product is a life-giving element, and service is a mission—I deem it appropriate to think of these individuals as “Organic Advocates”: advocates because they are advancing a cause, and organic because they are acting naturally on their own initiative and inspiration. The advantages of having organic advocates within a clean water agency cannot be overstated, since effectively communicating the value of service is essential to building relationships with service communities. For this reason, organic advocates such as our enterprising manager should not just be a marketer’s dream but rather the dream of every clean water leader, professional, and stakeholder. SAY IT OUT LOUD: I NEED ORGANIC ADVOCATES



LA Sanitation has over 3,200 employees. We are one of five bureaus within the Department of Public Works, which adds another 2,300 employees into the mix. The City of Los Angeles employs roughly 50,000 workers. Now, imagine if just ten

percent of these employees shared our company’s positive service messages with others in their circles—whether via social media, email, or word-of-mouth, the collective impact could be immense. In bottom-line terms, organic advocates can outdo communications staff many times over, which is a big boost for utilities with modest or even no communications budgets. While the anecdotal example of our wastewater collection manager speaks to increased morale and work quality, the need for organic advocates is generational as well. Across the country, we’re all potentially facing a workforce crisis that the media has dubbed “The Silver Tsunami.” As early as 2015, City of Los Angeles Controller Ron Galperin reported in the Los Angeles Times that “by 2018, 46% of civilian employees will be eligible for retirement.” Most new, entrylevel employees tend to be millennials, so positive comments about an organization’s work environment and mission— even on Facebook or Twitter—make an organization much more attractive. As a water leader or professional, it’s easy to forget that internal communications are just as important as external communications, and this is where “growing,” or inspiring, the organic advocate begins. Without a doubt, engaged, in-theknow employees are healthy for any organization, and effective internal communication is vital for team-building, workforce development, and—most important from an advocacy standpoint—mission implementation. IT’S ALL ABOUT THE CAUSE Personally, I think the best part of my job is the cause. LA Sanitation is the

As for our sector, in which we toil and sweat daily to provide our communities with the water they need to live, I believe that an inordinately large percentage of our colleagues instinctively under-

stand this concept, whether they voice it every day or not, and are incorporating its principles into their daily and professional lives.

In short, our clean water staff are, deep down, the “salt of the earth,” and it would significantly benefit our mission to help them all to be talking billboards as well. Working in water, we’re champions of the environment, and that’s cause for a great deal of pride. I believe most employees, deep down, are bursting to share with friends and family what they do at work, knowing that they are helping society, the environment, and future generations. It would be nothing short of a duty, then, for clean water leaders to help every

47 Winter 2018

environmental arm of the city of Los Angeles. Our work is changing the city’s future, and I’m extremely proud to be a part of that. I also know I’m not the only one: while there will always be staff members who are just here for a paycheck, recent employee surveys in our organization suggest that the majority selected LA Sanitation as an employer because its mission to protect public health and the environment aligns with their own desires to make the world a better place. Day after day, we provide vital services to our community, and we often go above and beyond the call of duty to do it right. This fact, communicated, resonates with most of our staff, and I’m

There is some social science behind this belief. In 2015, Forbes referenced a report entitled, “SixMonth Research Update to the 2014 Millennial Impact Report,” sponsored by The Case Foundation, that stated that “[m]illennials feel connected through a shared passion for their company’s cause work, ideally through initiatives that help their surrounding community.”


In the water sector—where the product is a life-giving element, and service is a mission—I deem it appropriate to think of these individuals as ‘Organic Advocates.’

willing to bet that this type of energy exists in every clean water utility.

Our clean water staff are, deep down, the ‘salt of the earth,’ and it would significantly benefit our mission to help them all to be talking billboards as well. one of their colleagues tell their stories, be it at dinner parties, on train rides home, or on social media. ACTIVITIES THAT GROW ADVOCATES



While many of us find ourselves spread thin due to a lack of staff and time or too many distribution channels and projects, I personally have learned that one of my most worthwhile professional priorities is to creatively engage this passionate audience, which is often hidden in plain sight. Understanding and committing to the objective of inspiring them is half the battle, with small daily practices to ensure progressive success. But making the extra effort to involve staff in organized campaigns or activities—specifically ones connected to the heart of the organization’s mission—goes a very long way in growing advocates organically. Our flagship event is “Earth Day LA” (2018 will be the third). More than 3,000 residents come out to spend a Saturday afternoon with us, learning about sustainability. It’s also LA Sanitation’s annual “Day of Service,” where staff can volunteer their time to serve free food and beverages, man educational booths, direct vehicles, or even portray mascots. We encourage staff to bring their loved ones, promoting a sense of family and pride. The booths allow the public to learn about

LA Sanitation’s programs and projects, but just as importantly, they also give staff an opportunity to take pride in the programs. The energy of the crowd impacts employees as much as it does the public, and when video footage of the event is saved and added to our orientation video, it energizes future employees as well. Recently, LA Sanitation launched “recycLA,” an exciting new public-private partnership that changes the way solid waste is collected from businesses and multifamily homes across the city. As part of the launch, we held a thorough training session for staff to help them use the right phrases when explaining the program. We created and distributed fact sheets to help everyone understand recycLA’s benefits. Ultimately, employee involvement in company campaigns doesn’t have to be elaborate, just deliberate and done well, so that employees know that their organizations care that they care. BUILDING INTERNAL COMMUNICATION INFRASTRUCTURE As clean water leaders, the gestures we make on a daily basis tend to subtly communicate our priorities. Our email distribution lists are one such gesture. Through lists created for each work site, we have the ability to connect with every city employee. And while group emails generally get a bad rap these days, every communications study shows that they are still the most effective and widely used medium for reaching audiences en masse, whether associates or strangers. The Department of Public Works recently launched a digital employee newsletter in which stories, project updates, and vital information are shared with all 5,500 staff across the city. We make deliberate efforts to encourage interoffice and department networking. It’s not uncommon for us to repost each other’s social media content or mention each other in our blogs. Building internal communication infrastructure

MOVING THE NEEDLE Ultimately, inspiring organic advocates is just an outgrowth of a simple

Pamela Perez is the Marketing Manager for LA Sanitation in the City of Los Angeles, and formerly served as Chair of NACWA’s Communications & Public Affairs Committee. Anthony Viardo is the Director of Communications & Marketing for NACWA.

49 Winter 2018

is an ongoing journey of improvement, as the rapidly changing communication landscape constantly demands new and creative strategies to stay current and effective. The good news? Right now, many utilities within NACWA’s nationwide network are brimming with fantastic examples of communications activities and initiatives—initiatives that other clean water agencies can implement immediately at very little cost. Clean water professionals looking for a place to start should take advantage of this and connect with the nationwide network, beginning with NACWA’s Engage Forum® ( Where else can you ask for solutions directly and receive innovative ideas (for free) from utilities coast to coast that are doing amazing things in communications right now?

Building a group of organic evangelists is an endeavor that holds benefits for us all—too many to enumerate here. If we, as a water sector, are to elevate clean water issues to their rightful place in the national consciousness, every single one of our utilities must strive to build communications platforms that move the needle in our local communities. If each utility made even incremental progress in that mission, the impact would be immense, and all of us together can help shape the public landscape to begin solving the truly massive challenges that our sector both faces now and will face in the future.


Making the extra effort to involve staff in organized campaigns or activities—specifically ones connected to the heart of the organization’s mission—goes a very long way in growing advocates organically.

truth: our clean water colleagues and employees deserve to be appreciated and respected, so much so that they can’t help but pay it forward, and yes, talk about it from the mountaintops—or at their dinner tables.





The field of Clean Water Law is expanding rapidly. The issues are growing in complexity and the stakes have never been higher. NACWA’s Legal Advocacy Program is the only program of its kind in the country focused specifically on national legal advocacy on behalf of the public clean water sector. It is a key component of NACWA’s mission to safeguard the interests of NACWA Member Agencies.

LITIGATION NACWA tracks litigation and legal developments across the country that have the potential to impact the clean water sector. We work to establish positive precedents that will benefit utilities nationwide and regularly intervene or serve as amicus curiae on issues of importance to our members. The Association engages in litigation to ensure appropriate, reasonable, cost-effective and consistent regulations, and to protect clean water utilities from unreasonable enforcement actions and third-party litigation.

RESOURCES & TOOLS NACWA provides high-value legal tools for our members and the municipal clean water utility community at large including the Consent Decree Handbook, Consent Decree E-Library, Stormwater White Paper, and the upcoming Stormwater MS4 Permit Guide and Key Clean Water Cases Compendium.

COMMUNICATIONS & PROGRAMMING NACWA keeps member utilities up to speed on critical legal issues affecting the sector through the National Clean Water Law and Enforcement Seminar, quarterly webinars and regular articles, newsletters and alerts.

COLLABORATION & NETWORKING NACWA is peerless in offering member engagement opportunities, such as, Legal Affairs Committee meetings and networking at National Clean Water Law and Enforcement Seminar.

MEMBERSHIP NACWA engages top clean water firms and attorneys to help deliver these exceptional legal benefits to our public agency members. Become part of NACWA’s defining nationwide network of legal experts by becoming a legal affiliate! For more information on membership, contact Kelly Brocato at For more information on the NACWA’s Legal Advocacy Program, contact Amanda Waters at


K E E E W SAV R 8 E 1 T A 0 2 W E T DA






D , ON

51 Winter 2018




1 2 15

Breaking the



Mold Finding A New Dental Amalgam Regulatory Strategy

By Timothy Potter

things. Simple, cheap, and scientifically elegant, these composite metals, held together and made pliable by mercury, lace right into tooth enamel and render annoying cavities pain free. When a filling is done right, the recipient will

never even notice it’s there. Is it effective? The procedure has been around for 150 years and is common around the world (who doesn’t get a filling at some time?). For the clean water sector, however, its success is its problem. According to the American Dental Association

For the many POTWs that did not regulate dental amalgam discharges, major program resources would be required to implement any new rule. (ADA), 175 million tooth-filling operations are performed every year in the United States. That’s a lot of dental amalgam. Although composite resins are gradually replacing dental amalgam in tooth fillings, amalgam is still widely used and subsequently removed as the fillings age and expire. The stuff has to go somewhere. The mercury and other metals in dental amalgam inevitably find their way down the drains and are therefore a clean water concern, one that the EPA now regulates through the National Pretreatment Program. Understandably, then, a collective OMG was felt by the national pretreatment community when the EPA announced in 2010 that it was unilaterally withdrawing from the 2008 Memorandum of Understanding—which it had agreed to along with NACWA and the ADA—to control mercury discharges from dental practices, and that it was proceeding with rulemaking to regulate dental amalgam discharges under the federal pretreatment program. With more than 125,000 dental practices across the country affected by this

53 Winter 2018

amalgam, are ingenious little



ooth fillings, made from dental

new regulation, the prospect for the publicly

elements of a pretreatment program (i.e., ordi-

owned treatment work (POTW) community was

nance, enforcement response plan, staff).

daunting. Any regulation based on the traditional national pretreatment regulatory strategy, specifically for an “industry” the size of

A rallying theme was adopted by local agencies and NACWA in dealing with the EPA as they proceeded with rulemaking for dental practices: “Break the mold” of traditional

the dental trade, would have

regulatory strategies. EPA staff

major resource implications

acknowledged that they had

for nearly all the POTWs

heard this message from

in the country. A small

local agencies and NACWA

percentage of POTWs

during their years of

with existing manda-

working to publish the

tory amalgam separator

proposed federal dental

programs would have a

amalgam rule.

head start, but would still

The proposed dental amal-

have to expend signifi-

gam rule was first published

cant resources to comply

in December 2014, and it did

with the specific regulatory



standards. For the many POTWs that did not regulate dental amalgam discharges, major program resources would be required to implement any new rule, especially for agencies with thousands of dental practices in their service areas. A large percentage of POTWs serving small communities are not required to have a pretreatment program, so if these wastewater agencies had even one dental practice subject to the new rule, they would need to start from scratch to establish the basic

represent a different regulatory strategy than traditional categorical standards. However, the initial proposed rule did not break the mold and would still have required local agencies to dedicate significant program resources for compliance. Primary areas of concern involved the requirement to establish and maintain an inventory of dental practices subject to the rule, conduct enforcement response for dental practices that did not comply with the federal standards, and manage a process that converted noncompliant dental practices into a Significant Industrial User

A rallying theme was adopted by local agencies and NACWA in dealing with EPA rulemaking for dental practices: ‘Break the mold.’

(SIU) status that invoked all of the traditional oversight standards in the federal pretreatment regulations. Consternation emerged again — with corresponding OMG — across the nationwide pretreatment program community with the publication of the proposed rule. Active engagement in the rulemaking process was initiated through comment letters and dialogue with the EPA.

As with the worst-case scenario summarized above, the proposed rule would impact all POTWs with dental practices in their service areas, including those with existing pretreatment programs and those without. A general consensus developed that the proposed rule would require significant resources to be expended, even for POTWs with existing amalgam separator programs, with little impact on POTW-effluent mercury concentrations. Members of NACWA’s Pretreatment & Pollution Prevention Committee engaged EPA staff to

Consternation emerged again — with corresponding OMG — across the nationwide pretreatment program community with the publication of the proposed rule.

express gratitude for attempting to establish a different regulatory strategy for dental dis-

the impact on local agencies’ resources. A key theme of these discussions was that the “industry” of dental practices generally takes pride in complying with the standards relevant to its professions. Historically, once a standard was set, a high percentage of voluntary compliance usually occurred among agencies with mandatory amalgam separator programs. This observation was reinforced by repeated communication with dental associations. The potential for a high degree of voluntary compliance by dental dischargers enabled EPA staff

to consider a significantly different regulatory strategy while adopting an effective rule to control mercury discharges to wastewater systems. Another key theme that emerged was that mercury loading from one dental practice did not usually amount to significant problems for a wastewater agency, but the aggregate of mercury from all dental practices did. Effective dental amalgam control programs didn’t need to expend significant program resources (for example, to chase down compliance from individual dischargers) to realize significant reductions in the amount of influent mercury to the wastewater treatment plants. The prepublication version

55 Winter 2018

sary to truly break the mold and better manage


chargers, but also that more would be neces-

to implement the rule. All dental offices subject to the new rule need to install and maintain an

The level of effort to control dental amalgam discharges is a local decision backed up by the new federal standards.

amalgam separator and follow several “best management practices (BMPs)” by specified dates—July 14, 2020, for existing dental offices, and for new dental offices, ninety days from starting discharges. A dental office that does not comply with the new standards is subject to enforcement by any local, state, or federal agency with the authority to enforce Clean Water Act provisions. But that’s where the rule departs from traditional pretreatment standards.

of the final rule that EPA released in December 2016 contained modified elements that actually did break the mold of their traditional regulatory strategies. This rule, published as a final 56

rule on June 14, 2017, establishes national pretreatment standards for dental offices without


creating a significant burden on local agencies

Unlike most other national pretreatment standards, local agencies do not have to maintain inventories of dental offices, verify the compliance status of dental offices, or take enforcement actions if a dental office is identified as not meeting the new federal standards. The only obligations for local agencies under the new

rule are to receive and store the one-time cer-

reinforce the benefits of

tification forms that dental offices are required

establishing effective

to complete, and to submit to their “control

national pretreat-

authority,” typically the local wastewater

ment standards

agency. Local agencies can create or implement

without having

more stringent programs than what is required

to burden local

under the new federal rule, but they don’t have

agencies’ limited

to. Existing mandatory amalgam separator pro-

resources. We

grams can continue without conflicting with the

can all contribute

federal standards. The level of effort to control

to its success with consistent messagcustomers. And as we continue to work together on the dental amalgam issue, everyone involved—the dental trade, the clean water sector, and even government regulators—regardless of differing interests, can reach a common professional goal: pain-free smiles all around.

Timothy Potter is the Environmental Compliance dental amalgam discharges is a local decision that is backed up by the new federal standards. Pretreatment programs and local POTWS without pretreatment programs can and should support the new national regulatory strategy adopted by the EPA for dental dischargers. We need to maintain a consistent message that dental offices are obligated to comply with the federal standards and serve as a resource for accurate information about the new standards. A central information hub—likely a webpage— that identifies the federal standards with submittal deadlines can and should be developed at low cost and with nominal resources. Successful implementation of this new regulatory strategy over the next few years will

Superintendent for Central Contra Costa Sanitary District located in Martinez, CA, where he manages environmental compliance regulatory programs, including a mandatory dental amalgam separator program. When not regulating dental offices, Tim loves to travel and has rediscovered scuba diving during several recent international excursions.

Winter 2018



Pretreatment programs, and local POTWS without them, should support the new regulatory strategy adopted by the EPA for dental dischargers.

ing to our dental office

ADVOCACY it works by Cynthia Finley



When someone asks me what line of work I’m in, I tend to give the simplest answer: advocacy. The inevitable follow up question—either “So what’s that?” or “How does that work?”—is never far behind. I believe advocacy’s nuances and ramifications are complex, but they deserve an explanation. As with most complex ideas, illustrations say it best. The Dental Amalgam Rule provides an excellent example of how advocacy works and how it can achieve results for the utilities NACWA represents. The rule evolved from a proposal that was universally opposed by Association members into a final rule that the members could support. It also illustrates the synergistic nature of the pretreatment program. The National Pretreatment

Program has been a huge success since the General Pretreatment Regulations were promulgated in 1983, significantly reducing the amount of toxic chemicals discharged to sewer systems. But it is a government program that is generally hidden from public view, receiving little recognition for its successes in protecting the nation’s infrastructure and waterways. First, background: The program is set up so that the U.S. Environmental Protection Agency (EPA), the states, and publicly owned treatment works (POTWs) are all co-regulators of industries that discharge pollutants into sewer systems. While the EPA establishes the regulations for how pretreatment programs operate and sets the requirements for certain industries, called Categorical Industrial Users (CIUs), utilities are responsible for

Utilities were not opposed to requiring every dentist to have a dental amalgam separator; the question was how to enforce this requirement without overburdening utilities. As the rule development process unfolded over a period of several years, the value of NACWA members working together on advocacy became even more apparent. Over 120 utilities submitted information for NACWA’s comprehensive comments to the EPA on the proposed rule. Association members then answered specific questions and provided examples in response to the EPA’s follow-up questions on NACWA’s comprehensive comments. The EPA took the co-regulator aspect of the pretreatment program seriously, giving due consideration to every type of impact that utilities might see as a result of

While no new rules as far-reaching as the Dental Amalgam Rule appear to be on the horizon for pretreatment programs, the EPA continues to evaluate and update its regulations for industrial discharges through its Effluent Guidelines Program. The Agency is currently studying the “Metal Finishing” and the “Electronics and Electrical Components” categories — two industries that have changed dramatically since the original regulations were written in 1983, before many current pretreatment professionals were even born. The NACWA Pretreatment & Pollution Prevention Committee has been providing the EPA with the clean water utility perspective of these two categories, as the Agency’s review of these categories presents an opportunity to streamline the industries’ regulation while maintaining the current protections for wastewater treatment processes and the environment. Advocacy can be painstaking and slow, even messy, but as the evolution and implementation of the Dental Amalgam rule shows, advocacy works. It allows the voices of clean water utilities across the nation to be heard effectively, leading to solutions for difficult problems that cannot be addressed by traditional approaches.

Cynthia Finley is the Director of Regulatory Affairs at NACWA.

59 Winter 2018

When the EPA first began developing the Dental Amalgam Rule, it was apparent to pretreatment professionals that it would be impossible to regulate dentists in the same way that other CIUs are regulated without creating an excessive burden on utilities. The EPA even noted in its rule proposal, “The number of dental offices that would be subject to this proposed rule is approximately ten times the current number of Categorical Industrial Users.” The sheer number of dentists would simply overwhelm pretreatment programs.

regulating the dental industry — impacts that the EPA may have otherwise overlooked or ignored.


regulating the industries within their service areas. Utilities are also able to set local limits on pollutant discharges as needed to protect their treatment processes, their workers, and the local environment. The states and EPA regions also regulate industries that discharge to a POTW that doesn’t have a pretreatment program.



A Day in the Life of a Clean Water Worker By Oliver Hamilton

NACWA Staff Followed James Atkinson, Of Alexandria Renew Enterprises, On An Ordinary Day, And Discovered Someone Far From Ordinary

SHIFTS AND TECHIES A straight shooter, the 47-year-old Shift Leader spoke swiftly and steadily, as a man with nearly

30 years of experience does, carefully deconstructing the coded language of wastewater acronyms and technical jargon. His enthusiasm was infectious and inviting: he talked fervently through the technical details but always took a moment to step back, look me in the eyes, and explain what he was doing and why he was doing it. I’ve always had an admiration for techies like James, people who work with computers — unintimidated, like they were old friends — easily gleaning useful conclusions from mountains of codes and figures. But James wasn’t always a techie. Back in the day, he began, as many clean water workers do, in general maintenance. James recounted with a wry smile his early days at



arrived at the sprawling Alexandria Renew Enterprises (AlexRenew) facility while it was still dark. James Atkinson was already there, sitting before a dizzying array of computer monitors in the facility’s control room. He was soft-spoken but approachable and heroically accommodating given the conditions. At an hour when most people were trying to start their engines, James was already in fifth gear, processing what looked like an impossible amount of digital information on a wall of LED screens. Checking. Monitoring. Making sure the facility was humming and the staff was safe.

Winter 2018


Like many utilities, AlexRenew was experiencing shifts in the workplace family as large numbers of staff reached, or neared, retirement. AlexRenew, where he started right out of high school, working with his hands, cutting grass, cleaning out pipes, combing the old sewage screening system with a large rake to remove rags and other “unflushables”—that was back before the process was automated. Hard day’s work. Job well done.



A fond laugh accompanied the story now: how he grew and evolved as a worker, right along with the facility where he worked. Like many of the plant changes that took place over the years, James’s role at AlexRenew expanded gradually, deliberately, and painstakingly until he reached a watershed moment. With patience, persistence, and, he added, the belief and support of AlexRenew, he eventually took and completed a six-month self-training program to become a licensed Wastewater Operator. And after a few years in that role, he was promoted to Shift Leader, a position in which he now oversaw compliance (as a techie) and managed a team of four operators. James admitted that, as a younger Shift Leader, he was nervous about managing his coworkers, but the trust and familiar atmosphere nurtured him beyond those barriers. And on that day, during the brief management meeting, the attention and gravitas everyone in the room afforded him spoke volumes about his hardearned leadership. It was a long journey indeed from broom handles to bundled software.

BASKETBALL AND APPRENTICES At one point during our walk around the floor, I listened while James stopped to speak with Jessica, a second-year apprentice, about an issue that came up earlier that morning involving sludge and thickening. I really didn’t care to listen more deeply to the details, but the encounter struck me. There again was the avuncular quality that seemed to infuse all of James’s interactions. I’d find out later that it was the same parental instinct that immersed him in his daughter’s budding basketball career—James burned the phone lines to help his daughter get recruited by a university—and that informed his own career for decades. In addition to his tasks around the facility, James plays an active role in AlexRenew’s Apprentice Training program. He typically oversees one or two apprentices per rotation and ensures they complete all the necessary paperwork before assigning them to a mentor. It became obvious to me that this was not just a job task for James but a labor of the heart: apprentices are rotated through different positions around the facility, where they are thrust into active roles, bolstering their confidence and building trust along the way.

As mentors do, James waxed thoughtfully about the transformation of the wastewater industry, in worker’s details of course, belying his hardearned experience and expertise. For example, as the city of Alexandria grew, AlexRenew was one of the first utilities to utilize ultraviolet technology on a larger scale, in order to comply with permit terms. But one of the changes that James appreciated most concerned how the utility’s role in the community had evolved over the years. When he first arrived at AlexRenew, the general focus was “to avoid headlines” and “treat the community’s water without drawing attention.” Today, the facility actively works as a partner with the community on several community-focused projects, such as introducing a fertilizer blend, using renewable energy, and even constructing a community sports field on-site. Hence, it was only natural that James’s favorite part of the job became family and community. According to him, AlexRenew’s welcoming familial environment not only bred trust among his coworkers but also promoted a culture in which employees challenged themselves and sought personal growth. In addition to the opportunities it gave employees to learn skills from experienced operators, James spoke highly of the opportunities that the utility offered to improve the staff’s technical knowledge, encouraging a knowledgeable workforce by requiring a Class I license for all operators and even offering employee tuition assistance for members of staff pursuing degrees outside the wastewater field.

PARTING THOUGHTS The sun was high when our session ended, but James still had a few hours left in his day. He talked about plans, sludge, and, ever the company man, AlexRenew’s commitment to be a “Utility of the Future.” As he walked me across the facility toward the exit, James reflected on the changes in the plant and how it, and he, had come such a long way. True to form, he avoided talking about himself whenever I tried to glean his take on why and how he’d reached this point in his career. A few casual laughs, and we parted ways. He made sure I knew my way out and that I wouldn’t get lost driving home. And as I was leaving, he gave me a parting thought, “Hey Oliver, always strive to be an innovator, not just a caretaker, OK?”

Oliver Hamilton is the Government Affairs Manager at NACWA.

63 Winter 2018


The downside to family, he lamented, was retirement—an issue that especially seemed to fuel his passion. Like many utilities, AlexRenew was experiencing shifts in the workplace family as large numbers of staff reached, or neared, retirement. As he explained it, not only was there pain associated with the departure of coworkers and friends, but the consequences of losing seasoned operators and staff were also wide-ranging and went beyond the costs associated with training new staff. More specifically, James noted the regrettable loss of mentors as the staff lost critical institutional knowledge along with seasoned employees who could guide younger operators.


Perhaps it’s a sense of gratitude for his career or a harkening back to his own experience as a raw employee just out of high school or maybe a bit of both, but James assumes a natural mentoring posture, and those around him are the better for it.

Fortune Favors the Bold CLEAN WATER ADVOCATE Winter 2018


Large-scale water infrastructure funding & solutions make up clean water’s biggest undiscovered territory for 2018. Will you be part of the expedition to discover it?

EXPLORE NEW FRONTIERS at NACWA’s 2018 Summer Conference

NACWA Utility Leadership Conference & 48th Annual Meeting Boston, MA | July 23 – 26, 2018

We Clean It. For Everyone’s Sake.

For nearly five decades, the National Association of Clean Water Agencies (NACWA) has been the nation’s recognized leader in legislative, regulatory and legal advocacy on the full spectrum of clean water issues. NACWA represents public wastewater and stormwater agencies of all sizes nationwide, and is a top technical resource in water quality, water management and sustainable ecosystem protection. NACWA’s unique and growing network strengthens the advocacy voice for all member utilities, and ensures they have the tools necessary to provide affordable and sustainable clean water for all communities. Our vision is to represent every utility as a NACWA member, helping to build a strong and sustainable clean water future.

STANDS FOR ADVOCACY Regulations, court decisions, legislation, and more: For utility leaders and professionals, clean water policy is difficult to follow, much less influence. Yet the effects are felt powerfully — sometimes painfully — by everyone whenever new developments emerge. Most will only be able to react and accept the federal, state and local forces that impact ratepayers and the bottom line. What about you? It’s time to take control. We don’t have to sit by passively as policy decisions impact our utilities. Across the country, major issues are developing and shifting. We are moving the needle on them. And so can you. For five decades, the National Association of Clean Water Agencies (NACWA) has been the nation’s recognized leader in clean water issue advocacy. It’s time to join the nationwide network and have an active role in the forces that directly shape your decisions.

We keep you connected and proactive. It’s time to find and collaborate with your peers.

Give us a look. Membership means Advocacy. For information about membership, contact Kelly Brocato at


Clean Water Advocate | Winter 2018  
Clean Water Advocate | Winter 2018