We appreciate the provisions in these two bills that will support community efforts to restore and protect local water resources and to improve wastewater and drinking water systems. In particular we support increased funding for the Clean Water State Revolving Fund and for specific programs directed at solving problems including: critical needs of small and tribal systems as well as disadvantaged communities; lack of access to sanitation and drinking water service, and cleaning up PFAS chemical contamination. With other organizations, we have called for significant and needed increases in both the Clean Water and Drinking Water State Revolving Funds in the amount of $100 billion over 5 years split evenly between the two Funds. We urge the Committee to consider increases in these critical programs that are commensurate with the need to invest in clean and safe water.
The lack of extraneous provisions that put water quality and public health at risk and are not related to the overall objectives of the bills is welcome. For example, language in the current House bill would allow Clean Water Act discharge permits for publicly owned treatment works to be extended to ten years. We support exclusion of this language from this draft and urge you to keep this provision and any similar provisions that would ease pollution permit requirements out of all subsequent bills. We include some specific comments on each bill.
America’s Water Infrastructure Act of 2020
Title I - Water Infrastructure Development
We are concerned about any provisions that would put water quality and public health at risk by expediting environmental review. For example: 1) The Great Lakes Comprehensive Flood Protection Study should investigate how low lake levels that could put drinking water intakes, harbors, and other resources and infrastructure at risk (Section 1001) and 2) Authorizing and directing agencies to consider adoption of expanded categorical exemptions under the National
Environmental Policy Act is counter to protecting public health and the environment (Section 1102).
Title II - Clean Water
- The incremental increases in the Clean Water State Revolving Fund program are a good first step. We urge the Committee to consider larger increases to address the realities of clean water needs. With many allies, we have joined the call for $50 billion over five years for the Clean Water State Revolving Fund with at least 20 percent of funding distributed to disadvantaged communities as additional subsidization (grants) rather than loans and at least 20 percent of CWSRF funding set-aside for investing in green infrastructure projects.
- The creation of the Clean Infrastructure Resiliency and Sustainability program is a welcome addition to enable wastewater systems to address long-term improvement needs and to be prepared for flooding and other risks.
- We support provisions in this bill to provide support for small, rural, and tribal communities as well as for non-profit organizations and circuit rider programs to help with improvements in small and medium wastewater systems.
- We support reauthorization of grants for workforce development in the utility sector as well as inclusion of water utilities in the eligibilities for these grants in addition to schools.
- Getting sanitation/wastewater treatment to households is critical to protecting water quality and public health. We support the programs to fund decentralized treatment for low- and moderate-income households and connection to wastewater systems.
Drinking Water Infrastructure Act of 2020
- We support reauthorization of the Drinking Water Infrastructure Risk and Resilience program for small and disadvantaged systems, the increased funding for this program, and the creation of a similar program for midsize systems.
- We support the inclusion of $300 million in grants annually to assist with addressing emerging contaminants, including PFAS chemicals. We urge the Committee to do more to address PFAS contamination including accelerating the ability to use the pollution prevention tools of the Clean Water Act to keep PFAS chemicals out of our rivers, lakes, and streams.
- We appreciate the Committee’s continued support for addressing lead at the tap in schools and childcare settings. The Voluntary School and Childcare Lead Testing Grants Program should be extended beyond 2022 and its focus should be updated to support efforts that fix the problem. Testing is of limited utility given that we would expect to find lead in many large buildings with outdated fixtures. Resources for addressing the source of the problem, for example installing water stations with proper filters, would improve the efficiency of this program and provide concrete protection for children.
Thank you again for the opportunity to comment during this process.
Lynn Thorp, National Campaigns Director 1444 I Street NW; Suite 400
Washington DC 20005 lthorp@cleanwater.org 202-895-0420 x 109
