(October 21, 2020) – NACWA submitted comments October 19 on the US Environmental Protection Agency’s (EPA's) proposed 2020 Financial Capability Assessment for Clean Water Act Obligations (2020 FCA Document).
NACWA’s comments noted that EPA’s proposal was an important step forward and that NACWA was encouraged by EPA’s acknowledgment of the criticisms of its existing financial capability methodology. NACWA urged EPA to move expeditiously to finalize the proposal but to also acknowledge that this is a complex issue and that additional refinements and supplementary information will likely be needed.
In its comments, NACWA outlined a series of suggested enhancements to EPA’s proposed methodology, based extensively on a review conducted by the experts who drafted the April 2019 report, Developing a New Framework for Household Affordability and Financial Capability Assessment in the Water Sector for NACWA, the American Water Works Association (AWWA) and the Water Environment Federation (WEF).
NACWA’s comments also stressed that while the proposal provides a much-needed, updated methodology, it does not address the broader affordability challenge. NACWA will be meeting with EPA in the coming weeks to discuss next steps on finalizing the 2020 FCA Document and continues its advocacy on Capitol Hill on affordability.
For questions or more information, please contact Chris Hornback, NACWA’s Deputy CEO.