Municipal Water Leader February 2022 by Water Strategies

Volume 9 Issue 2

February 2022

Andrea Doyle: Combining Flood Control and Habitat Restoration in Washington’s Chehalis Basin

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Municipal Water Leader is published 10 times a year with combined issues for July/August and November/December by an American company established in 2009.

Jeff Kightlinger Contributing Editor

STAFF:

Andrea Doyle: Combining Flood Control and Habitat Restoration in Washington’s Chehalis Basin

Contents

February 2022 Volume 9, Issue 2 5 I mproving Water Management, From the River Basin to the Individual Home By Kris Polly

18 O utgoing General Manager Glenn Page on the AwardWinning Cobb County– Marietta Water Authority

24 H ow Subeca’s Water 6 Andrea Doyle: Combining Management Platform Flood Control and Habitat Goes Beyond Advanced Restoration in Washington’s Metering Infrastructure Chehalis Basin 32 A n Update on the EPA’s 14 D enver Water Conserves New PFAS Testing Method and Plans for the Long Term 38 JOB LISTINGS

Copyright © 2021 Water Strategies LLC. Municipal Water Leader relies on the excellent contributions of a variety of natural resources professionals who provide content for the magazine. However, the views and opinions expressed by these contributors are solely those of the original contributor and do not necessarily represent or reflect the policies or positions of Municipal Water Leader magazine, its editors, or Water Strategies LLC. The acceptance and use of advertisements in Municipal Water Leader do not constitute a representation or warranty by Water Strategies LLC or Municipal Water Leader magazine regarding the products, services, claims, or companies advertised.

4 | MUNICIPAL WATER LEADER | February 2022

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Municipal Water Leader welcomes manuscript, photography, and art submissions; the right to edit or deny publishing submissions is reserved. Submissions are returned only upon request. For more information, please contact our office at (202) 698-0690 or municipal.water.leader@waterstrategies.com.

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COVER PHOTO:

Andrea Doyle, Director, Office of Chehalis Basin. Photo courtesy of the Office of Chehalis Basin.

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PHOTO COURTESY OF THE OFFICE OF CHEHALIS BASIN.

Do you have a story idea for an upcoming issue? Contact our editor-in-chief, Kris Polly, at kris.polly@waterstrategies.com.

Kris Polly, Editor-in-Chief Joshua Dill, Managing Editor Jeff Kightlinger, Contributing Editor Elaine Robbins, Copyeditor Tyler Young, Writer Stephanie Biddle, Graphic Designer Eliza Moreno, Web Designer Caroline Polly, Production Assistant and Social Media Coordinator Tom Wacker, Advertising Coordinator Cassandra Leonard, Staff Assistant Eve Giordano, Media Assistant William Polly, Media Assistant Milo Schmitt, Media Assistant Amanda Schulz, Media Assistant

Improving Water Management, From the River Basin to the Individual Home By Kris Polly

n our cover story this month, we speak with Andrea Doyle, the director of Washington State’s Office of Chehalis Basin. The office runs the Chehalis Basin Strategy, which has brought together a diverse group of stakeholders to undertake projects to tackle two of the basin’s biggest challenges: the periodic catastrophic flooding of settled areas and the loss of habitat for salmon and other aquatic species. We also speak with professionals from two agencies that were recently honored by the Association of Metropolitan Water Agencies (AMWA). Jim Lochhead, the CEO and manager of Denver Water, tells us about the conservation achievements, energy innovations, and long-term planning that have made his agency a two-time winner of AMWA’s Sustainable Water Utility Management Award. And Glenn Page, who recently stepped down as general manager of Georgia’s Cobb County–Marietta Water Authority, tells us about how his agency earned AMWA’s Gold Award for Exceptional Utility Performance. Tech company Subeca has developed a total water management platform for water utilities that goes beyond the capabilities of a conventional advanced metering infrastructure solution. Chief Strategy Officer Hank McCarrick tells us about Subeca’s system, and

how rather than just gathering data, it allows utilities and individual customers to control shutoff valves, home irrigation systems, and other devices. Finally, we update readers on new steps relating to testing environmental media for per- and polyfluoroalkyl substances (PFAS). In September 2021, the U.S. Environmental Protection Agency (EPA), in collaboration with the U.S. Department of Defense, published a draft of Method 1633, the first EPA-validated laboratory analytical method to test for PFAS. Across entire river basins, in major metropolitan areas, and in individual homes, water professionals are helping improve efficiency, prevent disaster, and strengthen ecosystems. I hope their stories this month are an inspiration to you in your work. M Kris Polly is the editor-in-chief of Municipal Water Leader magazine and the president and CEO of Water Strategies LLC, a government relations firm he began in February 2009 for the purpose of representing and guiding water, power, and agricultural entities in their dealings with Congress, the Bureau of Reclamation, and other federal government agencies. He can be contacted at kris.polly@waterstrategies.com.

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February 2022 | MUNICIPAL WATER LEADER

Andrea Doyle: Combining Flood Control and Habitat Restoration in Washington’s Chehalis Basin

A major food along I-5 in the Chehalis basin.

n the Chehalis Basin Strategy, launched in 2010, community leaders and a diverse group of stakeholders have come together to tackle two of the Washington State region’s biggest challenges: the periodic catastrophic flooding of settled areas and the loss of habitat for salmon and other aquatic species, both of which are exacerbated by climate change. In this interview, Andrea Doyle, the director of Washington State's Office of Chehalis Basin, which runs the strategy, tells us about the history of the strategy, the many activities that have been undertaken as part of it, and the results that it has achieved. Municipal Water Leader: Please tell us about your background and how you came to be in your current position.

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Municipal Water Leader: Please tell us about the Office of Chehalis Basin. Andrea Doyle: The Office of Chehalis Basin was created by our state legislature in 2016, after about a decade of work initiated by former Washington State Governor Christine Gregoire. After the basin experienced devastating floods in 2007 and 2009, she convened a work group of community leaders and stakeholders to develop a long-term plan to protect basin communities from future catastrophic flood damage while also restoring aquatic species. The legislature later elevated its work into a formal state office and placed it under the direction and oversight of an independent board, the Chehalis Basin Board.We now work out of the Washington State Department of Ecology. Municipal Water Leader: Please tell us about the Chehalis basin’s geographic and environmental characteristics. municipalwaterleader.com

PHOTOS COURTESY OF THE OFFICE OF CHEHALIS BASIN.

Andrea Doyle: I have been the director of the Office of Chehalis Basin for 3½ years. I sought out the position after spending most of my career in a variety of different environmental and legal positions in the public, private, and nonprofit sectors in Washington. Through those different experiences, I’ve led a range of legal, policy, regulatory, and advocacy efforts and have become convinced that collaborative approaches produce the most positive and durable solutions to complex environmental issues. This opportunity was a great

way for me to bring my passion and experience to bear on one of the biggest challenges facing the Chehalis River basin, namely the complicated intersection of the economic effect flooding has on communities and the floodplain habitat needs of salmon and other important aquatic species.

ADVERTISEMENT Andrea Doyle: The Chehalis basin is a truly unique and special place. It is located in southwestern Washington, about halfway between Seattle and Portland, and is the state’s second-largest river drainage system. The 2,700‑square-mile watershed boasts more than 3,400 miles of rivers and streams. The Chehalis River itself is more than 125 miles long and drains into the Pacific Ocean through a large estuarine bay called Grays Harbor, which is midway between two much-better-known geographical features: Puget Sound and the mouth of the Columbia River. Geographically, our basin covers 10 distinct ecological zones and includes densely forested old-growth areas, rolling mountain foothills, fertile farmlands, valley floors, and marshlands along the Pacific Ocean. The Chehalis River and its tributaries are home to some of the most culturally and ecologically important species in our region, including steelhead and seven types of salmon, including Chinook, coho, and chum salmon, just to name a few. It’s also the only remaining river basin in the state of Washington where no salmon species are listed as threatened or endangered under the federal Endangered Species Act. One fun fact about our basin is that it also home to Washington State’s most diverse assemblage of amphibians, such as frogs, toads, and salamanders. Municipal Water Leader: Would you tell us about the basin’s human population? Andrea Doyle: The current population of the basin is about 220,000 residents. The bulk of that population is centered along I-5, a major interstate highway that runs north-south from Canada to Mexico. The other population center is in the harbor area around the mouth of the Chehalis River. What we call the Chehalis basin today is made up of the ancestral lands of many different tribes. Two of those sovereign nations continue to reside in and use the basin today: The Confederated Tribes of the Chehalis Reservation reside in the heart of the basin, and the Quinault Indian Nation has treaty-protected rights to fish, hunt, and gather in part of the basin. People in the Chehalis watershed remain closely connected to the land and river system, with working forests and farmlands making up a large percentage of the basin’s land uses, and commercial and recreational fishing contributing significantly to the region’s economy.

PHOTO COURTESY OF ANCHOR QEA.

Municipal Water Leader: How was the Chehalis Basin Strategy launched? Andrea Doyle: As I mentioned, it was initiated as a community working group by former Washington State Governor Christine Gregoire. The early work aimed to increase our scientific understanding of the hydrology of the basin as well as the fishery science relating to it. A major effort was undertaken to do what we call a programmatic environmental impact statement, which is a broad-scale, planning-level review of different approaches and options that could address both the municipalwaterleader.com

Skookumchuck River restoration, designed by Anchor QEA.

fish and the flood objectives of the strategy. That resulted in a robust body of science that informed project selection and now informs the policy work that folks are engaged in. Municipal Water Leader: Was that initial analysis carried out by the Office of Chehalis Basin? Andrea Doyle: The programmatic review was performed under the direction of the Department of Ecology, the Department of Fish and Wildlife, and other state agencies. It was done with the assistance of many external consultants specializing in a variety of disciplines and resource areas. For example, consultants assisted with hydrology and hydrologic modeling and analysis, wetlands and vegetation analysis, fisheries modeling, geology and geotechnical engineering analysis, and land use and transportation analysis, to name a few. Municipal Water Leader: What is the main problem that the Chehalis Basin Strategy is designed to address? Andrea Doyle: The strategy was launched in 2010 to meet two of the basin’s biggest challenges by reversing the decline of salmon and other aquatic species and protecting communities from catastrophic flood damage. The floods of 2007 and 2009 were some of the most damaging floods we’ve experienced. Five of the basin’s largest floods on record occurred in the last 35 years. As climate change continues to increase the scale and the frequency of major floods around the world, the Chehalis basin is predicted to see more-frequent atmospheric river events, which will unleash 25–50 percent more precipitation than storms in the past. We’ve also seen that while aquatic species like salmon are not currently listed, several of them are on the brink. In the upper basin, salmon and steelhead populations are predicted to decline by another 70 percent from currently depleted levels if we don’t implement aggressive protection and restoration actions. It is the urgency that comes with knowing that both issues are going to get worse if we don’t take bold and aggressive action that has caused people to solidify around this collaborative process. February 2022 | MUNICIPAL WATER LEADER

ADVERTISEMENT Municipal Water Leader: What are the main goals of the strategy? Andrea Doyle: We have a unique opportunity to address our dual goals of fish and flood protection together through a thoughtful and integrated approach. We know there is not any single simple solution to meet either of these important objectives on its own, so our goal is to use multiple reinforcing actions at every scale to make the basin safer and more resilient for both humans and aquatic species. Municipal Water Leader: How do the goals of flood reduction and fish habitat protection affect each other? Andrea Doyle: The issues of flooding and fish habitat are intimately connected. The floodplains are where the increase in the frequency and the intensity of flooding will cause the greatest damage. The floodplains are also where the best habitat is—or at least where it should be—for fish and other aquatic species. These issues intersect in the floodplains, and they create some challenges because of competing interests regarding how certain lands should be used, managed, and developed— or not developed. But we view carrying out fish and flood projects at the same time less as a challenge and more as an opportunity to provide mutual benefits on both a regional and site-specific basis. We work on a voluntary basis with willing landowners. In doing that, we aim to center their interests and needs as we plan which projects to implement and where to implement them. The good news is that many of the projects that we’re able to pursue have benefits for both aquatic species habitat and flood damage reduction. We have a lot of projects that we like to think of as integrated fish and flood projects that provide direct benefits in both key areas. Some of the best examples are projects that focus on protecting critical public infrastructure, such as wastewater treatment facilities, or protecting farm equipment industrial areas, which can leak oil, gas, and other toxic pollutants into the water if there’s a flood, which obviously can harm the ecosystem. By protecting that critical infrastructure from flood damage, we also protect the ecosystem and habitat. On the flip side, when we do floodplain habitat improvement projects, such as projects to restore riparian function or to reconnect floodplain areas to their river channels, we can increase the capacity of the floodplain to absorb, store, and slow down water in the event of a flood. Municipal Water Leader: What are some of the main projects that are part of the strategy today? Andrea Doyle: The strategy includes a range of projects of different sizes and types. Collectively, since 2012, we’ve invested over $100 million in more than 100 completed or ongoing local projects to reduce flood effects and to help salmon and other at-risk aquatic species.

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We have large-scale projects on both the habitat side and the flood-damage-reduction side of the strategy. On the flood side, for example, cities around Grays Harbor are teaming up to design and permit the major improvement of a levee to protect the cities along the north shore of the harbor. That large-scale project is designed to protect over 2,000 properties and over 360 businesses from floods. The largest-scale proposal that is currently being discussed is for a potential emergency flood-protection facility that would retain up to 65,000 acre-feet of floodwater near the headwaters of the Chehalis River during a major or catastrophic flood event. That project is still undergoing environmental review, and no decision has been made yet about whether it will be implemented as part of the strategy. On a smaller scale, we have worked in partnership with our local flood authority, which is made up of local governments. They have identified projects to protect local government infrastructure, and we fund the study, the project design, and the implementation of the highestpriority projects. Those are things like drinking water protection; public road protection; detour routes; and flood warning systems, which local governments are continuing to improve to help notify their residents in the event of future floods. We’re also providing technical assistance and some financial assistance to individual residents, business owners, and local and tribal governments to fund flood-proofing and flood-protection projects on a parcel-by-parcel basis. On the habitat side, we have an ambitious 30‑year aquatic species restoration plan that involves investments in the protection and restoration of more than 550 miles of prioritized river habitat. Those projects are being implemented in several ways, but the largest ones are on 1- to 3‑mile reaches of riparian and adjacent lands whose landowners are willing to allow conservation and restoration measures. We have also ramped up our investments in different types of smaller-scale habitat restoration activities, such as fish passage barrier corrections or removals, that can be deployed throughout the basin. Municipal Water Leader: Are there any existing floodcontrol reservoirs on the river now? Andrea Doyle: There are none on the mainstem of the Chehalis River itself. There are two reservoirs associated with dams in its tributaries, although neither is designed and operated for flood protection. There is a lot of interest right now in looking at one of those facilities, the Skookumchuck Dam, which provides incidental flood-protection benefits. The Chehalis Basin Board is currently looking at ways in which the operation of that dam could be modified to improve its flood-protection capabilities. They are also looking at ways in which potential modifications to the dam could benefit fish or upstream habitat through better fish passage facilities, what dam removal might mean for the fisheries in that tributary, and the implications of dam removal for downstream flooding. municipalwaterleader.com

ADVERTISEMENT Municipal Water Leader: How is the strategy being carried out in a way that respects tribes’ rights and perspectives? Andrea Doyle: Tribal involvement and engagement have been absolutely critical. This strategy wouldn’t have been as successful as it has been to date without the tribes’ involvement, and we know that it won’t be successful in the long run without their support. The two sovereign tribal nations in the basin, the Confederated Tribes of the Chehalis Reservation and the Quinault Indian Nation, have been involved in the strategy since its inception. Both of those tribes have representatives that serve on the Chehalis Basin Board, a nine-member oversight board that operates on a consensus-based-decisionmaking model. The two tribes were coauthors of the aquatic species restoration plan and serve on its steering committee. The plan is a major component of our strategy and has received widespread support and praise from basin residents, scientists, and local leadership. Both tribes also serve on the steering group of a newly formed Local Actions Non-Dam (LAND) alternative evaluation team. They are intimately involved in all parts of the strategy, from serving on the oversight board to steering both habitat-protection and flood-damage-reduction work. Municipal Water Leader: How is the strategy being funded? Andrea Doyle: The vast majority of the funding for the Chehalis Basin Strategy comes from the Washington State Legislature. We’ve been incredibly fortunate, and we are exceptionally grateful to our state legislative champions, including Representative Steve Tharinger and Senator John Braun, who have been tireless in their exceptionally successful advocacy on behalf of the Chehalis Basin Strategy. We also partner with other organizations on many of our projects, and in many of those cases, project partners bring additional sources of funding to the table. At the federal level, we work closely with Congresswoman Jamie Herrera Beutler and Congressman Derek Kilmer, who have been very attentive to the needs of the strategy. We’re looking to expand our funding sources in the future, and we’ve been laying some good groundwork with our congressional delegation to do that.

PHOTO COURTESY OF THE OFFICE OF CHEHALIS BASIN.

Municipal Water Leader: What kind of results do you expect to see from the strategy in the next 5, 10, or even 50 years? Andrea Doyle: Over the life of this strategy, to put it simply, we expect to see safer communities for people, stronger local economies, and healthier ecosystems. We are already seeing tangible results from projects we have implemented, such as the removal of 56 fish passage barriers, which has opened or improved access to more than 178 miles of stream habitat for migrating salmon and steelhead; the protection of dozens of homes, buildings, farms, and wells from floods; the protection of a wastewater treatment plant from riverbank erosion, which could have breached the plant and potentially municipalwaterleader.com

released millions of gallons of raw sewage into the river; and the protection of a local airport using storm pumps. We look at future time horizons in a few different ways. We’ve got the immediate projects that we’re working on—in summer 2021 alone, crews worked to restore over 12,000 feet of river shoreline and to treat almost 300 acres for invasive plants, benefiting salmon and the other aquatic species. We’ve also recently completed the protection of over 360 acres of floodplain habitat through various property acquisitions and conservation easements. We’re installing the final elements of a new flood-protection project in the city of Centralia to keep a local creek that is currently diverted underground through the heart of the city from flooding the downtown area during periodic 5- to 10‑year flood events. If we can keep this collaboration moving ahead, we expect to achieve up to 550 miles of restoration and to better protect the residents of thousands of existing homes and other structures that are currently at risk of flooding or that we expect to be at greater risk of flooding in the future. We also expect that we can help local governments redirect new development away from high-flood-risk areas by using the best available climate change projections. While we hope to be aggressively implementing projects over the next 30 years, we look at a 50‑year timeline when considering the effects of our actions—or inaction. If we’re not able to take aggressive action now, what will that mean by the latter part of the century? We want to avoid the extirpation of species that are at the highest risk. We want to prevent the more than $3–$4 billion in economic harm that will occur if we don’t take aggressive action to reduce flood damage risk. Those are the kinds of results that we’re expecting to see through this work. Municipal Water Leader: Is there anything you would like to add? Andrea Doyle: Although the Chehalis basin is unique, the challenges we’re facing are not. A lot of other communities around the state and country are facing similar challenges— problems that are complicated not only from the scientific and technical perspectives, but from the social and political perspectives as well. We think we’re showing that a collaborative approach is better than trying to work on these issues in silos or with an adversarial approach. We are looking to foster long-term relationships and durable solutions for future generations. We all share the common goal of a safer and more resilient future for the basin. M Andrea Doyle is the director of the Office of the Chehalis Basin. She can be contacted at andrea.doyle@ecy.wa.gov or (360) 407‑7674.

February 2022 | MUNICIPAL WATER LEADER

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Denver Water Conserves and Plans for the Long Term

Denver Water’s water recycling plant.

mpressive conservation achievements—along with innovations in energy use and long-term planning for future disruptions—have made Denver Water a two-time winner of the Sustainable Water Utility Management Award from the Association of Metropolitan Water Agencies (AMWA). In this interview, Denver Water CEO and Manager Jim Lochhead talks with us about how the agency seeks sustainability while providing water to the Denver metro region. Municipal Water Leader: Please tell us about your background and how you came to be in your current position.

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Jim Lochhead: Denver Water was created in 1918 under the Denver City charter. We’re a part of the City and County of Denver, but we’re a separate enterprise. I report to a five-member board appointed by the mayor. We were established to be apolitical and to be able to take a long-term perspective. We serve about 1.5 million customers, about half of whom are located in the city and county of Denver. The other half are in various municipalities in the suburbs of Denver. Our water supply comes solely from surface water— from snowpack and rain. We get about half our water supply from the Colorado River basin and the other half from the South Platte River basin. Our reach is extensive—we sit at the backbone of the Rocky Mountains and get water from both sides of the Continental Divide. Our watersheds cover about 4,000 square miles, an area about the size of the state of Delaware. We’re the third-largest public landowner in the state of Colorado. Our reservoirs are used both for water service and recreation. They’re a big part of the economy. For example, Dillon Reservoir is located in Dillon and Silverthorne, right next to a bunch of ski areas. It’s a big economic driver of the local economy. We like to think of ourselves as more than municipalwaterleader.com

PHOTOS COURTESY OF DENVER WATER,

Jim Lochhead: I am the CEO of Denver Water. I’ve been with Denver Water since 2010. Before that, I was a lawyer doing water rights work for a variety of organizations, including states, municipalities, agricultural interests, and real estate development interests, and one of my clients was Denver Water. I also served for 4 years as the executive director of the Colorado Department of Natural Resources, so I’ve been in both government and the private sector throughout my career. I wanted to be at Denver Water because I love its sense of mission and purpose. We have 1,100 employees dedicated to providing a secure water supply for the Denver metropolitan area. It’s both a huge challenge and incredibly rewarding.

Municipal Water Leader: How has Denver Water evolved?

ADVERTISEMENT simply a water utility. Our properties span the state as we engage in local communities. We’re part of the fabric of the community, and indeed, Denver and other western municipalities and cities wouldn’t exist but for Denver Water. Municipal Water Leader: Denver Water’s service area has expanded dramatically since its creation. Do you expect that expansion to continue? Jim Lochhead: Our service area is constrained under an agreement that we reached with western Colorado. Denver Water moves water from western Colorado into eastern Colorado, and as with Northern and Southern California, that importation of water creates tension between regions. In 2013, we entered into what was in essence a peace treaty with western Colorado, which resolved several issues and established a partnership. As part of that, Denver Water agreed not to expand our service area. We’re really growing up instead of out, which is a good thing from a sustainability perspective, both for the city and for the utility.

Solar panels on the roof of Denver Water’s new administration building, shown here during construction, will help the utility meet net-zero goals for electricity generation.

Municipal Water Leader: You serve 25 percent of the state’s population, but you consume less than 2 percent of the state’s water. How is that possible? Jim Lochhead: It’s about conservation and efficiency. Denver Water has been engaged in encouraging conservation by our customers since at least 1938, when we experienced a major drought. Through those efforts, we have reduced our water use by more than 22 percent over the past 20 years. In fact, we are using about the same amount of water as we did in the 1970s, even though we have about 600,000 more people in our service area. Our customers are cognizant of how much water they use. We have a tiered rate structure, and we send educational materials to our customers. We work with customers on an individual basis to encourage efficiency, and it has really taken hold.

Denver Water CEO Jim Lochhead (center), pictured here with AMWA President Angela Licata and AMWA Vice President John Entsminger, receives the 2021 AMWA Sustainable Water Utility Management Award.

Municipal Water Leader: Is Denver Water involved in wastewater treatment? Jim Lochhead: We are just a drinking water utility. We do have a recycling treatment plant at which we take water from the Metro wastewater plant and retreat it; it is then used for irrigation and other industrial purposes throughout the system. We’re also partnering with storm water agencies and other agencies on green infrastructure projects. We are really moving toward the One Water concept that’s being embraced throughout the world, which envisions making full use of the urban water cycle, including treatment and storm water management, installing green infrastructure, and matching water quality to purpose. Municipal Water Leader: Denver Water is a two-time winner of AMWA’s Sustainable Water Utility Management Award. What are the factors that go into receiving that award? municipalwaterleader.com

Denver Water won an award from the Urban Land Institute for its brand-new, LEED Platinum–designated, net-zero-energy headquarters and operations complex.

February 2022 | MUNICIPAL WATER LEADER

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ADVERTISEMENT Jim Lochhead: This is the second time that Denver Water has received this honor. It’s a recognition by peer utilities of our efforts. It’s difficult to win it once, so to win it twice means that we have continued going above and beyond what we were doing when we first won it. Sustainability is a big part of what we do. As a water utility in the West, we are protective of our source water supply. For example, in a program called Forest to Faucets, we’re working with the U.S. Forest Service to perform forest thinning in national forests and key watersheds to reduce fuel and mitigate the effects of catastrophic wildfires, which will be exacerbated by climate change. In addition to the AMWA sustainability award, we recently won an award from the Urban Land Institute for our brand-new, LEED Platinum–designated, net-zero-energy headquarters and operations complex. The 35‑acre campus houses our administration building, fleet operations, warehouse, meter shop, and various other operations. We completely redeveloped the site to reflect the future of water in the West. It incorporates rainwater capture and an in-building wastewater treatment system: We’re capturing wastewater in the building and using it for toilet flushing and irrigation. We’re using our own water supply for heat exchange instead of groundwater. The building reflects our sustainability ethic. We do a lot of work on climate change and energy efficiency. We generate a lot of hydropower, and we aim to be an overall net-zero water utility, meaning that we generate at least as much clean energy through hydropower as we use in all our operations. We also are in the process of constructing a new water treatment plant. We challenged the engineers to design a self-sustaining plant that could be operated off the electric grid. They thought we were crazy, but they went to work and developed a plant that is so efficient and generates so much energy that we are connected to the grid only because we’re selling power back to it. Municipal Water Leader: Please tell us more about AMWA. Jim Lochhead: I serve on the board of AMWA. It is an organization that is designed for C‑suite utility executives. We have lots of programs that deal with operations and business excellence in water utility management. The organization also advocates in Washington, DC, on federal legislation and regulatory matters that affect drinking water. Municipal Water Leader: What does the award mean to Denver Water?

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Jim Lochhead: Two years ago, we received approval from the U.S. Environmental Protection Agency (EPA) for a variance under the lead and copper rule. Through discussions with the EPA and the Colorado Department of Public Health and Environment, we received approval to remove 65,000– 85,000 lead service lines within our service area at no direct cost to our customers. We’re absorbing those costs. We can deal with lead service lines from a treatment standpoint, but the root cause of the problem is the lines themselves. The ultimate solution is just to get those lines out. We’re are working to remove every lead service line from our system over a 15‑year program timeline. We are now 2 years into that program, and we’ve removed over 10,000 lines so far. We’ve also worked with environmental permitting agencies on the enlargement of the Gross Reservoir. The environmental approval process for that project—including steps dealing with the National Environmental Policy Act, the Clean Water Act, the Forest Service, the Federal Energy Regulatory Commission, and other federal agencies—has taken 20 years. Our focus through this entire process has been not just meeting regulatory requirements but undertaking environmental enhancements over and above those mitigation requirements. We do this by partnering with the local community and with nongovernmental organizations. We look forward to starting the construction of that project early next year. Municipal Water Leader: What is Denver Water’s vision for the future? Jim Lochhead: Well, the future is uncertain. We’ve learned that through climate change and the pandemic. We’re going to be seeing more severe weather events, longer droughts, more severe flooding, and a generally warmer climate. We will find out how that affects both our water supply and the demands on our system over the next 100 years, but we need to be able to meet those challenges. As a result, we have a 50‑year planning process in which we look at what we call scenario planning. We look at what the world might look like 50 years from now. It’s going to be full of disruptive change, and we need to be ready to meet any of the challenges that might be coming our way. Our readiness, resilience, and long-term view underpin our vision. M

Jim Lochhead is the CEO and manager of Denver Water. For more on Denver Water, visit www.denverwater.org.

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PHOTO COURTESY OF DENVER WATER,

Jim Lochhead: It’s important to be recognized by your peers. Our employees are extremely dedicated, and they are proud of the work they do every day to deliver water. Throughout the pandemic, we’ve had employees reporting to facilities every day; interfacing with the public; and working in the streets, replacing mains and repairing and building the system. That’s part of sustainability as well—the sustainability and resiliency of your people and their ability to meet challenges, both those we can anticipate and those we can’t.

Municipal Water Leader: How do you work with the state, federal, and local governments to further their objectives?

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CCMWA's Wyckoff water treatment plant.

Outgoing General Manager Glenn Page on the Award-Winning Cobb County–Marietta Water Authority

he Cobb County–Marietta Water Authority (CCMWA) provides wholesale water to cities, counties, and water authorities across a five-county region in northwestern metropolitan Atlanta, Georgia. It recently won the Gold Award for Exceptional Utility Performance from the Association of Metropolitan Water Agencies (AMWA). In this interview, outgoing General Manager Glenn Page talks with Municipal Water Leader about how CCMWA delivers efficient water supply, maintains infrastructure, and meets water quality challenges. Municipal Water Leader: Please tell us about your background and how you came to be in your current position. Glenn Page: I have a bachelor’s degree in civil engineering from Clemson University and a master’s in environmental engineering from Georgia Tech. After designing pipelines for CCMWA as a consulting engineer, I joined the staff 34 years ago as a project engineer. I was named assistant general manager in late 2001, when we had to address changes in utility management to respond to the events of 9/11. I was appointed general manager in late 2007, following the retirement of my predecessor. Municipal Water Leader: Please tell us about CCMWA.

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Municipal Water Leader: Does CCMWA partner with other regional water and wastewater entities in the area? Glenn Page: CCMWA is located within the footprint of the Metropolitan North Georgia Water Planning District. The district encompasses 15 counties and 95 cities that are required by state law to coordinate water supply, water municipalwaterleader.com

PHOTOS COURTESY OF CCMWA.

Glenn Page: We are a water wholesaler and provide treated drinking water to approximately 900,000 people through 10 wholesale customers across a five-county region, including cities, counties, other water authorities, and a defense contractor. We supply all the water to Cobb County, which is a primarily urban metropolitan area just northwest of Atlanta. Our mission is to provide sustainable and reliable

drinking water that supports public health, public safety, and the economic vitality of our region. The word sustainable is key for us. We don’t just define that from an environmental perspective. We plan decades into the future. That planning includes financial planning and fiscal policies that are designed to help us remain financially viable well into the future. This allows us to continue to execute our mission year after year. Since we are an authority, our board is able to take a business approach rather than a political approach. This allows us to do long-term planning; we’re not just planning from election cycle to election cycle. We have 116 employees. For a water authority that has over 170 million gallons per day in production capacity, we are a lean organization. We have held a triple triple‑A bond rating since 2002. We have a low debt ratio and strong financials, and we’re currently in a rehabilitation, or rebuilding, phase in our infrastructure cycle. Part of our financial strategy is to pay for our depreciation up front so that we have cash available for replacement projects. We would plan to borrow for a project to meet a growth need or to meet a new regulatory requirement, but currently, we’re paying for our entire capital improvement plan with cash. Our capital improvement plan requires expenditures of about $50–$70 million per year.

ADVERTISEMENT conservation, wastewater treatment, and storm water management together for the good of the region. I currently serve as the chair of the district. Like many areas of the country, we are moving toward a One Water approach. Specific to our system within the district, CCMWA’s largest wholesale customer, the Cobb County Water System (CCWS), now buys about 75 percent of the water we produce. CCWS collects wastewater from its customers and from some of our other wholesale customers and treats it to a high level before discharging it back into the environment. Two of CCWS’s water reclamation facilities discharge back to Allatoona Lake, which is the water source for our Wyckoff water treatment plant. We have recently received a record of decision from the U.S. Army Corps of Engineers acknowledging the allocation of water returned to Allatoona Lake by CCWS to CCMWA for supply—essentially, it is a reuse stream. As a result of this decision, we will not have to purchase any additional storage for increased supply from Allatoona Lake for at least 30 years. This decision by the Army Corps has endorsed the coordinated planning between water provider and wastewater discharger, employing One Water principles and requiring no additional costs to our customers for additional infrastructure or the purchase of storage space.

CCMWA’s Calvin F. Simmons microbiological laboratory analyzes around 500 regulatory water samples each month from distribution systems of the agency’s wholesale customers.

the publication, these organizations laid out 10 attributes of successful utilities and 5 keys to management success. A successful applicant for the Gold Award must demonstrate that the 10 attributes and 5 keys to management success are present and practiced in its organization. Municipal Water Leader: What does the award mean for your organization? Glenn Page: We’re constantly getting awards, but this one is special because it recognizes the contributions of everyone in the organization. You can be successful in a lot of different arenas, but this award recognizes excellence in every area of the authority and shows that our focus on leadership, alignment, and workforce development is paying off. Municipal Water Leader: Please tell us about your conservation efforts and leak prevention systems. Glenn Page: Our technical services group has deployed devices in our transmission system that help us monitor flows and pressures. Just this week, our largest customer, CCWS, had a break after taking a pipe out of service. We started monitoring our sensors in the system in that specific geographical area, and we were able to confirm the location of the break and let CCWS know immediately so that it could effect a repair. Before, it would have required somebody seeing the leak, calling it in, and having a crew dispatched to confirm the situation; thanks to the new technology, we were able to pinpoint the location for immediate repair. Related to infrastructure and leaks, Georgia has a statewide water audit program that was mandated by the Water Stewardship Act of 2010, which is probably the most aggressive water stewardship law in the country. Every water system in Georgia is required, on an annual basis, to report its water losses, what it is doing to correct them, and how much improvement is occurring. Each system must prove that continuous improvements are being made, year after year. Because of the unique way our systems are interconnected, CCMWA submits the annual audit with our largest customer, CCWS. Our water loss rate is well below the industry norm.

Municipal Water Leader: Please tell us about the award CCMWA recently received from AMWA.

Municipal Water Leader: What efforts have you made to reduce water consumption?

Glenn Page: We received the Gold Award for Exceptional Utility Performance, which is actually not the result of a competition, but a measure against a standard. Several years ago, the U.S. Environmental Protection Agency (EPA), AMWA, the American Water Works Association, the Water Environment Federation, the National Association of Clean Water Agencies, and other water industry associations defined a standard through a publication titled Effective Utility Management: A Primer for Water and Wastewater Utilities. In

Glenn Page: Efforts to upgrade infrastructure to reduce the loss of water have been part of our long-range capital planning since I came to work here in the mid-1980s. We now have an aged pipe replacement program in which we use a planning tool to assess pipe replacement needs and place the highest-priority projects into our capital improvement plan. We have also used technology to evaluate the condition of our pipelines in situ to predict anticipated life before failure. Just this week, we removed seven pieces of pipe found to be

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ADVERTISEMENT excessively corroded and to require immediate replacement. Through the use of these technologies, we are able to make some of these replacements on our schedule, rather than under the duress of a pipe break. Over the past three decades, CCMWA and its customers have made great strides in water conservation. We hired the first water conservation expert in the state of Georgia in 1988, following a major drought, to teach landscape professionals and homeowners about xeriscaping and other outdoor water saving measures. We implemented a summer surcharge rate in 1992 to attempt to shave the peak in summer demands. In 2001, after the water planning district was formed, it established multiple water conservation measures that all its member utilities were mandated to adopt. These measures included mandatory tiered water-rate structures, toilet replacement rebate programs, and changes in plumbing codes. As a result of these efforts, individual water use in the CCMWA service area has dropped from approximately 140 gallons per capita per day in the early 2000s to around 90 gallons per capita per day now. We are producing the same amount of water today as we were in 1995, even though we have 50 percent more people. Water conservation has become a requirement for economic viability; we can grow only as much as we conserve. We used to think that we would just produce more water to meet a growing population, but we have hit the limit on water availability. That’s what droughts and the water wars have taught us.

The 180-foot-high Hickory Log Creek Dam is jointly owned by CCMWA and the City of Canton, Georgia.

algae blooms. We are concerned about harmful algae blooms in both sources. As a result, we are expanding our source water monitoring plans and adding additional treatment steps to ensure drinking water safety. We are trying to stay ahead of the curve on the revised lead and copper rule that is under review by the Biden administration. We have already done a good bit of work in this area and expect to change our strategy to optimize corrosion control in the near future. Finally, we are watching closely for new regulations expected on perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS). These compounds, made for human convenience, will require much effort to contain and remove from our environment. While they are not a huge concern in our region, there is no urban area immune from the effects of their presence, including on water supplies. On the workforce front, our utility experienced a 2‑month period in mid-2021 when we experienced the retirement of five employees with 40 or more years of experience each, adding up to a total tenure of 215 years. Four of these five employees were senior managers. They have been joined by several others since, and I retired as general manager at the end of 2021. Utilities and other industries around the country that are experiencing this surge in retirements require a successful strategy to survive it. At CCMWA, we have focused on individual employee development through educational and training opportunities focusing on technical matters, leadership, and other topics. This year, our human resources department won the award for best total rewards strategy from the Society for Human Resource Management–Atlanta and the Atlanta Business Chronicle, which pitted CCMWA against other businesses headquartered in Atlanta, such as Home Depot, Chick-fil-A, Coca-Cola, UPS, and Truist Bank. As we focus on individual development, we pay for full tuition reimbursement for those who want to get a college degree in our business areas. We also pay for all certification training and conference attendance and provide pay increases and other incentives when significant achievements are made. And we provide all of that on top of competitive salaries for jobs in the public arena. This type of targeted strategy will be an ongoing requirement for any water utility desiring to retain a high-performing and sustainable workforce in the coming years. M

Municipal Water Leader: What are the top concerns in your organization right now?

20 | MUNICIPAL WATER LEADER | February 2022

Glenn Page retired as general manager of the Cobb County-Marietta Water Authority on December 31, 2021. He can be contacted at glenn@gmpage.net. For more about CCMWA, visit www.ccmwa.org. municipalwaterleader.com

PHOTOS COURTESY OF CCMWA.

Glenn Page: Our biggest concerns right now are related to water quality and the workforce. We have deteriorating source water quality, and we must accept that all water is reuse water. One of our water intakes is about a mile downriver of a wastewater plant discharge, and the other is in an Army Corps reservoir subject to nutrient overload and

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How Subeca’s Water Management Platform Goes Beyond Advanced Metering Infrastructure

The physical elements of the Subeca solution.

echnology company Subeca offers a total water management platform for water utilities that goes beyond the capabilities of a conventional advanced metering infrastructure (AMI) solution. It uses meters, sensors, and valves to provide utilities and customers with intelligence about water operations and potential problems like leaks and to enable them to react remotely. Further, its customer-facing portal, Engage, not only provides information about water consumption to end users but can also be set up to enable them to control shutoff valves, monitor irrigation systems and consumption, and operate other elements of their home systems. In this interview, Chief Strategy Officer Hank McCarrick provides insight into Subeca’s solution and how it is helping utilities around the country.

from a water utility encouraging me to conserve water and to go lift the lid on my meter box and take a peek at the numbers. When I opened my meter box, I saw a bunch of spiders and thought it was a pretty poor process. I saw a need for a platform that allowed customers to understand what was going on with their water. As a process engineer, I could see that this industry was ripe for innovation. I applied a methodology similar to the one I used at the first company. I knew that this was a system approach, not a widget approach. We required sensor technologies to provide consumers the information they needed, telemetry to get the signals from the ground to wherever they needed to go, and a customer-facing presentation to make sense of it all.

Municipal Water Leader: Please tell us about your background and how you came to be in your current position.

Municipal Water Leader: How did the company develop?

24 | MUNICIPAL WATER LEADER | February 2022

Hank McCarrick: At the beginning, I didn’t think we had a prayer, going against all the big meter companies that had been entrenched for more than half a century. But it was clear to us that the end customers didn’t have the tools that they needed to do the job of managing water, so we decided to be customer focused. We provided our first platforms to companies such as Pepsi Cola; the California Department of Transportation; the University of California, Irvine, Medical Center; hotels; and homeowners’ associations, all of which are heavy water users. The initial product line was a traditional SCADA platform that was hardwired—it had to be plugged in the wall. We knew that it wasn’t an municipalwaterleader.com

PHOTO COURTESY OF SUBECA.

Hank McCarrick: My original background was in semiconductor engineering. I was on the process side of developing integrated circuits for companies like Motorola, McDonnell Douglas, and Hughes Aircraft. From there, I took my first venture into being an entrepreneur: I developed a platform that monitored the process gases used to manufacture integrated circuits. That company was pretty successful, and it was subsequently acquired. Today, Subeca is doing with water what I did with semiconductor gases many years ago. My introduction to the water utility market occurred when I was a customer. It was a simple thing: I got a notice

ADVERTISEMENT appropriate AMI solution for water utilities. If we were going to satisfy their requirements, the product had to be battery operated and the batteries had to keep running for several decades. We started trying to figure out what kind of telemetry and web services should be used. We looked into the technologies that seemed to have the most promise. Fortunately, we made a couple of good guesses in the beginning, one of them being choosing LoRaWAN as the radio frequency telemetry platform for our products. Municipal Water Leader: Do you still market your solutions to industrial installations and homeowners’ associations, or is your main market today municipal water districts and similar larger-scale entities? Hank McCarrick: Today, municipal water districts and utilities are our only market. We have stepped away from the industrial market. The utility market is a big fish, and it takes all our attention. Municipal Water Leader: Please describe your solution and the various hardware and software elements that go into it. Hank McCarrick: Subeca offers a platform for water utilities and their customers to manage water more efficiently, not just an AMI solution. Our hardware products use a common water intelligence core module called BLINC, which incorporates both Bluetooth5 and LoRaWAN. This dual network approach satisfies the need for high-speed data delivery at the endpoint location while also delivering longrange data transmission for remote device management. The Subeca BLINC core products include a smart water meter replacement register called Pin, a smart sensor hub called Link, and a water shutoff valve called Act. On the software side, device management is delivered through Subeca Engage cloud-based web services. Subeca Engage provides a water management portal for water utilities and water agency customers. Subeca Engage is designed around Amazon Web Services (AWS), including AWS Internet of Things (IoT) Core for LoRaWAN. Engage provides customers with personal portals to which they can add devices such as valves to prevent leak loss or damage, flow meters to measure outdoor use, or moisture sensors to gain a complete water management experience. Similarly, water agencies can add IoT devices to the water system that can be integrated into the Engage platform through the agency-controlled LoRaWAN network. Municipal Water Leader: What is generally understood to be an AMI system, and how does Subeca’s system differ from that? Hank McCarrick: As the meaning of the acronym implies, AMI focuses on the delivery of meter readings only. The Subeca platform goes beyond meter reading by providing a true smart-agency IoT experience. System pressure, tank municipalwaterleader.com

level, fleet tracking, and water quality sensors are just a few of the devices that can be added to the Subeca Engage platform. If the water purveyor happens to be a municipality, it can add other sensors, such as street lighting and parking, as well as waste management devices. On the consumer side, the Subeca platform provides an opportunity to create or enhance a smart home environment that maximizes control and integrates water use with water management devices. Municipal Water Leader: What is LoRaWAN, and what advantages does Subeca’s use of a LoRaWAN-based network provide? Hank McCarrick: LoRaWAN is an open long-range network, based on the LoRa modulation technique, that originated in Europe. The name derives from the phrase long-range widearea network. LoRaWAN can transmit data over long distances with very low output power. This makes the network ideal for devices that must be battery powered and must achieve long battery life. There are over 500 companies producing IoT devices for LoRa. This allows water agencies that have moved to a LoRaWAN network to pick from an ever-growing catalog of add-on solutions and operational intelligence. Municipal Water Leader: What sort of data can Subeca provide to utilities and customers? Hank McCarrick: Any LoRaWAN-connected sensor is a candidate for providing data to water utilities through the Subeca Engage platform. Examples include pressure sensors at customer endpoints, hydrants, or any other location in the distribution system; soil moisture sensors; tank level sensors; and water quality sensors. Legacy AMI is typically limited to end-point water demand quantification and ignores the water production side of the equation. On the customer side, rebated products such as moisture sensors, shut-off valves, and irrigation flow sensors can be added by the customer. These devices can then be accessed through personalized Engage consumer dashboards. This allows end-point consumers to achieve water use efficiency at their properties as never before. Municipal Water Leader: Please tell us about your Subeca Engage portal. Is it intended for individual residential customers to be able to monitor the water use their own homes? Hank McCarrick: Absolutely. There are already several customer-facing dashboards out there, including WaterSmart and Dropcountr. Visitation to those sites by end customers is typically under 20 percent. Customers may take a brief look at their water use history, but they probably won’t go there unless they’ve got a high bill. That can be changed only if you make the dashboard far more engaging, which is why we named our platform Engage. We saw the need to make it an application rather than just February 2022 | MUNICIPAL WATER LEADER

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ADVERTISEMENT a web page that customers passively look at. That meant integrating devices that were useful to the end customers. For example, our platform allows customers to easily add a moisture sensor or the controls for a shutoff valve to their house to the same dashboard that the water utility provides them. We have a sort of cookbook of devices that we can put onto our platform, which water utilities can make available to their customers through the optional dashboard rebate store. That way, customers can look at their dashboards, see what devices are available, and click on the ones they want. The devices show up on their doorsteps and are installed as part of the water management experience. Customers are much more likely to visit a customer-facing dashboard if it can be used to control an irrigation system than if it simply displays information about historical use. That’s the direction we’re taking. We eventually want to make these devices communicate with each other autonomously. Municipal Water Leader: What would be some of the use cases for shutoff valves? Hank McCarrick: There are a number of use cases. We offer those remote shutoff valves to utilities as well as to customers. The utilities might want to use them for service interruption, for example if there is a broken pipe at the customer site between the house and the meter box. Some agencies will actually shut off or throttle service in the case of nonpayment or tenant turnover. What is distinctive about what we do is that we allow the water utility to share that valve with the customer. That way, the customer is alerted if they have a leak in the house, have left the faucet on, or have a stuck irrigation valve and can resolve the leak or shut the water off, either locally or remotely. Municipal Water Leader: Does using Subeca’s technology involve a complete replacement of all metering infrastructure and software, or can Subeca also adapt or upgrade existing systems? Hank McCarrick: Perhaps the biggest strength of the Subeca Platform is the ability to retrofit existing meters with the Subeca Pin without disrupting customers’ water service. The meter retrofit time is a fraction of what is required to shut down a customer service, remove the meter, and replace it with a new meter. New meters can be phased in as required by their age.

Hank McCarrick: The Smart City concept is intended to deliver city or utility workforce efficiency, environmental stewardship, sustainability of utilities, and an enhanced quality of life for residents. The applications and devices that fill the Smart City bucket help with asset tracking, lighting control,

26 | MUNICIPAL WATER LEADER | February 2022

Municipal Water Leader: Would you tell us about some of the results your customers have seen from using your products? Hank McCarrick: We have already assisted customers in discovering large leaks in irrigation systems, water left on in hoses, and vacated apartments where a faucet is left running. With leaks, even a small pinhole can slowly develop into a larger and larger leak. It is useful to see those early on—they will show up on our system as the loss of a fraction of a gallon per minute. If those leaks are not detected, they will grow. Users can lose a lot of water quickly. We sometimes see the equivalent of several swimming pools of water being consumed in a week from an irrigation leak. Municipal Water Leader: Please tell us about your vision for the future. Hank McCarrick: The future is bright for water utilities, as innovation is on the rise on many fronts. Subeca’s focus is to enable the creation of smart water homes and smart water utilities through innovative products, networks, and web services. Subeca is working closely with Amazon to deliver on our vision. In our vison of the future, water utilities and their customers will become seamless partners in driving water supply resiliency. There is more and more focus on the consumer, because sustainability efforts are not going to succeed without sleeves-up partnership participation by those end users. They have to be part of the formula. Our focus is on finding the best tools to make end customers participants in the whole process. We call that converting customers into partners in water conservation. A punitive paradigm isn’t going to work. Customers need to feel like they have the power to help. We want to see agencies make them partners, rather than just customers out there waiting for the bad news on the next bill. M Hank McCarrick is the chief strategy officer at Subeca. He can be contacted at info@subeca.com or (800) 366‑2271. For more about Subeca, visit www.subeca.com.

municipalwaterleader.com

PHOTO COURTESY OF LANCE GERBER STUDIO.

Municipal Water Leader: What is meant by the Smart City concept, and how does Subeca’s system further it? How might a utility using a Subeca system integrate into a broader Smart City?

traffic management, and tracking available parking. The biggest challenges for smart cities are the aggregation of data from disparate sources and the interpretation of these data for the use of the need-to-know parties. A big step in the right direction is the implementation of open wireless networks on which numerous devices can send data to target applications. LoRaWAN and cellular networks will soon carry data for over 80 percent of deployed IoT devices. When a water utility deploys a LoRaWAN network, it can allow the city access to the network. This gives the city a big push in the smart direction.

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An Update on the EPA’s New PFAS Testing Method

n September 2021, the U.S. Environmental Protection Agency (EPA), in collaboration with the U.S. Department of Defense (DoD), published a draft of Method 1633, the first EPA-validated laboratory analytical method to test for per- and polyfluoroalkyl substances (PFAS) in eight different environmental media. PFAS are a group of so-called forever chemicals used in firefighting foam, nonstick pans, food packaging, and other products whose effects on human health and the environment are under increasing scrutiny. Method 1633 can be used for National Pollutant Discharge Elimination System (NPDES) permits and other applications. In this interview, Robert Wood, the director of the Engineering and Analysis Division of the Office of Science and Technology in the EPA’s Office of Water, helps clarify how Method 1633 was developed, its uses, and the next steps for PFAS testing. Municipal Water Leader: Please introduce the EPA’s role in validating laboratory analytical methods for water contaminants. Robert Wood: Clean Water Act (CWA) methods are validated and approved for nationwide use through rulemaking, primarily in support of National Pollution and Discharge Elimination System (NPDES) permits that regulate and monitor point source discharges to Waters of the United States. Dischargers are required by the Code of Federal Regulations (CFR) to use these approved methods when their permit requires analyses of pollutants for which there are approved methods that can measure to the level the permit requires. When there is not an approved method for a contaminant, as is currently the case for PFAS, it is up to the permitting authority to specify the analytical method that will be used to measure that pollutant parameter. CWA methods are also often used in surface water, biosolids, and other CWA applications. Other EPA method programs exist to support the Safe Drinking Water Act, the Clean Air Act, and the Resource Conservation and Recovery Act. Some EPA regions and the Office of Research and Development may use other methods for specific projects or sites. Those other EPA method programs have different requirements for validating methods but contain many of the same steps. Municipal Water Leader: Please tell us about the importance of testing for PFAS. What sort of requirements for PFAS testing currently exist? Robert Wood: Without PFAS testing methods, it is impossible to determine the presence and extent of environmental contamination of PFAS or to gauge their potential effects on human health and the environment. EPA analytical methods provide consistency to stakeholders, including industry, allowing for comparability of laboratory data from multiple sources.

32 | MUNICIPAL WATER LEADER | February 2022

Currently, there are no PFAS methods from any source that have been approved by the EPA for nationwide CWA applications, so NPDES permitting authorities must determine what methods are most appropriate. Different states have taken different approaches to filling that methods gap. The EPA’s Office of Water recommends Method 1633 for CWA applications, since it has undergone singlelaboratory validation in a wide variety of environmental matrices and will likely be proposed for approval through a public comment and rulemaking process in the future. Municipal Water Leader: How was Method 1633 developed? Robert Wood: Method 1633 is still a draft method, so it is more appropriate to ask, “How is Method 1633 being developed?” The entire method development process contains the following steps: 1. The identification of a promising technique or procedure based on internal (EPA) or external development efforts (e.g., literature review, lab standard operating procedures, or voluntary consensus standard body procedures). 2. Formal study planning documentation. 3. Single-laboratory validation, targeting a variety of different water and wastewater matrices. 4. The refinement of any issues identified in the singlelaboratory validation study. 5. The drafting of an actual method in EPA format. 6. Multilaboratory validation testing of a variety of wastewater matrices at several laboratories. 7. The development of quality control acceptance criteria that reflect the real-world performance of the method in the multilaboratory validation study. 8. The publication of a final method. 9. The inclusion of the method and all the supporting documentation in a rulemaking docket, typically for proposal at 40 CFR part 136. 10. Following the proposal, the EPA reviews and responds to all public comments received and makes any needed revisions to the method based on the comments. 11. The method gains approval through a final rule that promulgates the method for nationwide use in CWA NPDES compliance monitoring. Method 1633 is currently undergoing the sixth step above. The EPA is collaborating with the DoD to carry out the multilaboratory validation of the method. No method is formally adopted for nationwide use in NPDES until step 11 of the rulemaking process is complete, but methods that have not yet been promulgated may still be useful to the EPA and other organizations. And importantly, permitting authorities can specify draft methods in permits if no approved method exists for that contaminant. municipalwaterleader.com

PHOTO COURTESY OF THE EPA.

ADVERTISEMENT Municipal Water Leader: How frequently does the EPA cooperate with the DoD and other federal agencies in developing testing methods and other scientific advances? Robert Wood: This is the first laboratory method collaboration between the DoD and the EPA’s CWA methods program. The CWA methods program has approved multiple methods from the U.S. Geological Survey and hundreds of methods from voluntary consensus standard bodies, such as ASTM International and Standard Methods. Additionally, many private vendors and other organizations have had their methods approved through the EPA’s alternate testing program (ATP). There must already be an approved method in order for the ATP route to be taken. Since there currently is no approved method for PFAS analytes, this is not an option for PFAS. Because of the multiple federal and state players involved in PFAS investigation and remediation activities, DoD’s Strategic Environmental Research and Development Program sought a unified approach and approached the EPA’s Office of Water in 2019 to start a collaborative effort to develop, validate, and give formal EPA approval to a PFAS method that would be useful for the DoD and various EPA programs. The DoD and the EPA are working collaboratively to complete the full, multilaboratory validation of EPA Method 1633 for 40 specific PFAS analytes. The DoD is funding and managing the method validation study. The method is being validated in eight matrix types: wastewater, surface water, groundwater, leachate, soil, sediment, biosolids, and tissue. The EPA’s goal is to produce sufficient data to validate a CWA method and a solid waste (SW-846) method. Municipal Water Leader: Would you please describe Method 1633, particularly how it differs from other methods of PFAS testing? Robert Wood: Virtually all PFAS procedures for specific compounds employ high-pressure liquid chromatography (HPLC) to separate the target analytes and tandem mass spectrometry (MS/MS) to detect and quantify them. Method 1633 uses HPLC and MS/MS and is most similar to EPA Drinking Water Method 533. The primary difference is that the procedure is designed to accommodate the challenges of analyzing samples that contain high levels of organic, mineral, and solid materials, unlike drinking water. When the method is finalized, it will contain required quality control criteria that will be statistically generated from data obtained from numerous laboratories that have tested a wide variety of wastewaters. This will provide consistency to the laboratory analysis community, something regularly requested by many states and other laboratory organizations. Purchasers of laboratory services for CWA applications currently use a variety of other methods. Method 1633 is unique in having been tested in a wide variety of matrices (wastewater, surface water, groundwater, soil, biosolids, sediment, landfill leachate, and fish tissue). municipalwaterleader.com

Municipal Water Leader: How does the validation of this method change the status quo? Robert Wood: The status quo has changed because now there is a single-lab-validated method for PFAS compounds in wastewater that the EPA is recommending for use in the NPDES program. The method is, of course, useful in the other matrices listed above as well, including biosolids, fish tissue, and soil. As stated on the EPA’s website, “The method will support NPDES implementation by providing a consistent PFAS method that has been tested in a wide variety of wastewaters and contains all the required quality control procedures for a CWA. While the method is not nationally required for CWA compliance monitoring until the EPA has promulgated it through rulemaking, it is recommended now for use in individual permits.” The DoD may also use this method at some of its sites. Municipal Water Leader: What are the next steps for research into PFAS detection and monitoring? Robert Wood: Aside from the completion of the method validation for Draft Method 1633 and its proposal and promulgation through rulemaking, the CWA methods program anticipates two other PFAS method efforts in 2022. First, the EPA’s Office of Water is pursuing a validation on adsorbable organic fluorine by combustion ion chromatography. Organic fluorine is very rare in nature, so this will be a good screening method for synthetic organic fluorine compounds, such as PFAS, fluorine-based pesticides, and some pharmaceuticals. The Office of Water thinks that this tool is needed for PFAS monitoring because it is logistically impossible to make a method that can identify the thousands of PFAS chemicals that have been manufactured and their degradation products. Second, the CWA Method Program is also in discussions with VCSBs about validating other PFAS methods. Other EPA offices are pursuing a wide variety of methods. The CWA Methods Program requires that analytical methods have well-documented performance data from multiple laboratories, testing a wide variety of wastewater types, before methods are considered for approval through rulemaking. Given all the method validation and approval steps, this is a multiyear process. M Robert Wood is the director of the Engineering and Analysis Division of the Office of Science and Technology in the U.S. Environmental Protection Agency’s Office of Water. For more on the EPA, visit epa.gov. For more on PFAS methods, see the EPA’s frequent questions about PFAS methods for NPDES permits webpage at www.epa.gov/cwa-methods/frequentquestions-about-pfas-methods-npdes-permits. February 2022 | MUNICIPAL WATER LEADER

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Upcoming Events February 1 North Dakota Rural Water Systems Association, Annual Meeting and Expo, Fargo, ND February 8 North Dakota Rural Water Systems Association, Rural Water Rally, Washington, DC February 9 Nebraska Water Resources Association, Water Roundtable, Lincoln, NE February 17–18 Ditch and Reservoir Company Alliance, Annual Conference, Colorado Springs, CO February 23–25 Multi-State Salinity Coalition, Annual Salinity Summit, Las Vegas, NV February 24–25 Family Farm Alliance, Annual Conference, Reno, NV March 6–9 Association of Metropolitan Water Agencies, Water Policy Conference, Washington, DC March 9 Nebraska Water Resources Association, Water Roundtable, Lincoln, NE March 9–11 Texas Water Conservation Association, Annual Convention, Fort Worth, TX March 11 Oregon Water Resources Congress, District Managers Workshop, Newport, OR March 21–23 Utah Water Users Association, Utah Water Users Workshop, St. George, UT April 7–8 The P3 Water Summit, San Diego, CA April 13 Nebraska Water Resources Association, Water Roundtable, Lincoln, NE April 24–30 National Association of Clean Water Agencies, Water Week, Washington, DC May 2–4 National Water Resources Association, Federal Water Issues Conference, Washington, DC May 3–6 Association of California Water Agencies, Spring Conference and Exhibition, Sacramento, CA

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Municipal Water Leader February 2022

Articles inside

An Update on the EPA’s New PFAS Testing Method

How Subeca’s Water Management Platform Goes Beyond Advanced Metering Infrastructure

Outgoing General Manager Glenn Page on the Award-Winning Cobb County–Marietta Water Authority

Municipal Water Leader February 2022

Andrea Doyle: Combining Flood Control and Habitat Restoration in Washington’s Chehalis Basin

Improving Water Management, From the River Basin to the Individual Home