AWWA Sends Letter to House Energy & Commerce Committee Regarding IIJA

The American Water Works Association (AWWA) released a letter that provided comments on current U.S. drinking water infrastructure and implementation of the Infrastructure Investment and Jobs Act (IIJA). The letter was sent to House Energy and Commerce Committee.

“AWWA thanks the House Committee on Energy and Commerce for addressing the state of the nation’s water infrastructure and efforts to rehabilitate and upgrade that infrastructure,” said AWWA in its comments offered on Hearing, “Trusting the Tap: Upgrading America’s Drinking Water Infrastructure.”

AWWA Comments & Concerns

EPA issued a memorandum on implementation of IIJA funds flowing through the drinking water and wastewater SRF programs on Mar. 8, which AWWA praised aspects of, including:

Descriptions of activities eligible under lead service line removal;
A definition and listing of emerging contaminants;
Encouragement to state SRF agencies to be flexible in administering funds;
Encouragement to state SRF agencies to streamline SRF application processes; and
Advice to state SRF agencies to revise and update their definitions of disadvantaged communities.

However, according to AWWA’s letter, there are some questions and concerns about implementation going forward, which include:

The IIJA is sending a huge volume of money and tasks through EPA and state agencies, but the workload may impact their ability to deliver funds in a timely manner.
The distribution of funds for lead service line replacement to states will follow the allocation formula for traditional SRF allocations, based on the latest needs survey. The allocation of these funds will be based on overall infrastructure needs, not just lead service line removal needs.
- AWWA is unclear about the processes and timelines for reallocation of SRF funding if certain states do not or cannot use their allotments in a fiscal year.

The new Build America, Buy America (BABA) domestic content requirements still need Office of Management and Budget (OMB) guidance.
- BABA also requires a new learning curve for new standards.
- There are concerns about the ability of domestic manufacturers to produce products not currently available in the U.S.
- There is a waiver provision in BABA that is not transparent and expeditious.

Small or rural water systems that have never applied for an SRF loan before will need assistance in assessing their own capital needs, rates and financial planning and in navigating the SRF process.
Mid-sized systems do not have a clear path for applying for funds and transparency in the factors weighed in selecting applicants for loans.

AWWA adds that it does see progress in addressing the country’s water infrastructure needs.