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5 critical factors to meeting deadlines for America’s Water Infrastructure Act of 2018

September 30, 2020

By Caroline Cunningham, Andrew Faley and Matthew Lieuallen

The ins and outs of strengthening your utility for drinking water resiliency

Water systems across the country are being faced with the Environmental Protection Agency’s (EPA) newly enacted federal law: America’s Water Infrastructure Act (AWIA) of 2018. AWIA Section 2013 now requires community drinking water systems serving more than 3,300 people to develop or update risk and resilience assessments (RRAs) and emergency response plans (ERPs) every five years.

Why? It’s simple. Planning before disasters strike will help communities maintain critical water supply by identifying potential impacts and actions to prevent loss of service. The law specifies components to be addressed and deadlines for completion. Failure to comply can result in steep fines and even greater disaster impacts.

With deadlines on the horizon, let’s look at what goes into each piece of the AWIA. 

Once RRAs have been submitted, ERP deadlines follow six months later. The clock is ticking for communities with less than 100,000 residents.

RRA’s to Z: An overview

The RRA requirement replaces a previous law enacted post-9/11. AWIA broadens the assessment focus from “terrorism and intentional attack” to “natural hazards and malevolent acts.” Critical assets are typically paired with threats and evaluated to understand probability, likelihood, consequences, and deterrents in a comprehensive assessment. So, what needs to be covered?

  • Risks to the system: From natural hazards to malevolent acts
  • Assets/systems: Resilience of components like pipes and constructed conveyances, physical barriers, source water, collection and intake, pretreatment, treatment, storage, and distribution facilities, including security of electronic, computer, and automated systems
  • Assessments: Monitoring practices, financial infrastructure, chemical use, storage and handling, as well as operations and maintenance of the system.

RRAs may also include evaluation of capital and operational needs. Oftentimes, the seven-step J100 risk assessment methodology is used to understand the utility’s risk portfolio and make decisions when allocating scarce resources towards reducing risk and improving resilience. Ultimately, RRAs should inform risks, vulnerability, and resilience recommendations.

The J100 Standard for Risk and Resilience Management of Water and Wastewater Systems is a go-to resource for many water utilities working through their RRAs.

An informed and agile response

An emergency is typically defined as a situation that arises suddenly that can have considerable negative consequences if fast and effective corrective measures are not taken.

Water utilities—regardless of their size and location—have a legal responsibility to provide clean, safe drinking water, even under emergency conditions. The ability of utility staff to respond rapidly in an emergency helps to prevent unnecessary complications and protect consumers’ health and safety. Rapid response may also save money by preventing damage to water systems. 

Utilities need to not just understand the requirements of AWIA, but the intent behind them.

The ERP details strategies, resources, plans, and procedures utilities use to prepare for, and respond to, an incident—natural or man-made—that threatens life, property, or the environment. Incidents can range from small water main breaks or localized flooding to large scale hurricanes, earthquakes, or system contamination. ERPs are traditionally two phases: Preparation and execution.

No later than six months after certifying its risk and resilience assessment, each system must prepare or revise an emergency response plan. The ERP includes:

  • Strategies and resources: Roles and responsibilities, Incident Command System and communication schemes, including physical security and cybersecurity of the system
  • Emergency plans and procedures: Core and incident specific tactics to be implemented, along with identification of equipment that can be utilized
  • Risk mitigation policy: Actions, procedures, and equipment which can prevent or significantly lessen the impact on public health and safety, as well as supply of drinking water, including the development of alternative source water options, relocation of water intakes, and construction of flood protection barriers
  • Detection strategies: Used to aid in the detection of malevolent acts or natural hazards that threaten the security or resilience of the system.

Planning ahead to protect critical water infrastructure from all types of threats is key to delivering clean, safe drinking water even under emergency situations. 

5 key factors

Having successfully completed both RRAs and ERPs for clients, here are five key factors to meaningful AWIA projects:

  • Upfront support is crucial. As with any new directive, there is a lot to consider. From information gathering and gap analysis to risk assessment and review of existing emergency response documentation, collaborative client workshops are vital in the process. Making time for adequate and accurate data collection around critical assets sets up efficiencies for current and future assessments
  • Risk-informed operations. The RRA lays the foundation for a strategic pathway to building resilience and a comprehensive emergency response program. During the RRA process, in addition to understanding risk, projects, policies, and procedures that can add resilience are identified and prioritized. The ERP update process is done through the guise of vulnerabilities identified during the RRA and AIWA requirements, helping the utility prepare for nearly any event
  • Leveraging partnerships. Both the RRA and ERP require coordination with external partners such as an emergency management committee or information technology. This is a low-stress environment to build relationships and long-term resilience. Aligning operations with jurisdictional emergency management organizations is not only necessary but beneficial for expedited response and recovery
  • Don’t forget finance! Logically, most utilities will ask: “What can we afford to do to enhance resiliency and minimize risk?” At Stantec, we integrate our funding and finance experts to help clients understand two things. One, how an organization’s financial health can impact resilience. But also, how to tailor funding strategies to reduce future risk, protect assets, and derive sustainable business benefit from this investment. Future grant dollars are anticipated for identified AWIA projects and we can help you develop a tailored strategy
  • Meeting the letter and spirit of AWIA. Regulatory-driven efforts can easily run the risk of becoming a ‘check the box’ exercise. Utilities need to not just understand the requirements of AWIA, but the intent behind them. It takes prioritizing resources to certify with confidence as well as get value from the process to support a sustainable approach to risk and resilience management. 

Planning for the protection of assets— the security of electronic, computer, and automated systems—like this treatment facility “nerve center” are key to a successful AWIA submission. 

On the surface, AWIA is just another requirement. However, on a deeper level it is much more. It is a call for the Water sector to use the process to make defensible, business case-based decisions about how to better manage risk and become a utility capable of providing vital water to its customers during and after disaster events. 

  • Caroline Cunningham

    Caroline has a strong passion for protecting communities. She believes that trending climate changes have served as the catalyst for big ideas and innovative solutions to reduce a potential disaster’s impact.

    Contact Caroline
  • Andrew Faley

    A geographic information systems manager, Andrew is an expert in creating unique asset management plans for every community he works with.

    Contact Andrew
  • Matthew Lieuallen

    As an operations and resilience leader, Matthew works to improve the readiness of communities against events such as earthquakes and floods. This work includes addressing ongoing conditions and supporting community involvement.

    Contact Matthew
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