Advocacy & Analysis

As the nation’s leading advocacy voice for municipal stormwater utilities across the country, NACWA is dedicated to protecting water quality; addressing large scale watershed impacts, such as flooding and erosion; and solving related modern-day challenges, such as water quality impairment from stormwater runoff and land-use impacts.

The Association and its individual members are committed to advancing robust, innovative programs and working collaboratively with regulators and stakeholders. The U.S. Environmental Protection Agency’s (EPA) MS4 General Permit Remand Rule, issued in early 2017, represents a change in the development and issuance of National Pollution Discharge Elimination System (NPDES) permits for small Municipal Separate Storm Sewer Systems (MS4s).

Since the COVID-19 pandemic emerged, NACWA has been working with our clean water agency members and our partner organizations across the water and municipal sector to urge Congress to act to provide federal relief to utilities and assistance to households unable to pay their water bills. NACWA’s ongoing advocacy encompasses direct funding for utilities for lost revenues and COVID-19-related expenses, assistance to households unable to pay their water bills, support for essential employers and workers, stabilizing and improving municipal financing tools, and engaging with the utility perspective in the conversation around water shutoffs.

With the pandemic persisting far beyond initial expectations, Congress has continued to negotiate the terms of another round of major COVID-19 relief, with many twists and turns over the summer and fall. As of late October 2020, differences between Congress and the White House appeared irreconcilable until after the election. NACWA remains engaged with Congressional staff in the meantime as is preparing for further action on the next round of “relief” or “recovery” in late 2020 or early 2021.

Climate change impacts are already affecting clean water agencies and are projected to grow in the years ahead. Increased intensity of storm events and flooding, the threat of sea level rise at treatment works—traditionally located on low-lying coastal land in a community—and increased attention to water scarcity and reuse are just some of the ways in which clean water agencies are seeing impacts from a rapidly changing climate. As the public and government at all levels becomes more concerned, legislative, regulatory and legal pressures to control greenhouse gas emissions and mitigate climate change impacts will grow. Given the critical services clean water agencies provide in their communities, our sector needs to be closely engaged in climate and resiliency conversations.

NACWA believes that climate change is primarily a water issue. The Association’s advocacy focuses on the interrelationships between water resources and climate change. NACWA is also committed to ensuring that greenhouse gas emissions from wastewater treatment are accurately estimated, and that any efforts that impact the wastewater sector are reasonable.

NACWA's Toilets Are Not Trashcans campaign is focused on protecting the pipes, pumps, plants, and personnel of wastewater utilities across the nation by reducing the materials that are inappropriately flushed or drained into the sewer system. 

Products such as wipes, paper towels and feminine hygiene products should not be flushed, but often are, causing problems for utilities that amount to billions of dollars in maintenance and repair costs—costs which ultimately pass on to the consumer.  Other consumer products contain ingredients, such as plastic microbeads and triclosan, which may harm water quality and the environment.  Fats, oils and greases (FOG) and unused pharmaceuticals should also be kept out of the sewer system.

Pursuing New Tools to Address Nutrient-Related Water Quality Challenges

Nutrient pollution remains a substantial challenge to the water resources of the United States. Deficiencies in the federal regulatory and policy framework, as well as the lack and inflexibility of financial resources, have constrained needed progress. These factors are driving a strong interest across nutrient management stakeholders in developing and implementing alternative nutrient management approaches.

At the same time, as outlined in more detail below, NACWA played a leading role in securing legislative language in the 2018 Farm Bill that will help public clean water utilities better engage upstream with agricultural partners to achieve meaningful water quality improvements through a holistic, watershed approach.

Over the last 45 years, communities have been responding to a growing list of Clean Water Act (CWA) regulatory mandates to improve the nation's water quality. Often taking on compounded wastewater and stormwater responsibilities, many communities are struggling to adequately allocate strained financial resources to these clean water needs.

Thanks to advocacy efforts by NACWA, the U.S. Conference of Mayors and others, EPA recognized the regulated community’s need for flexibility, and developed its Integrated Municipal Stormwater and Wastewater Planning Approach Framework (IP Framework) in 2012. NACWA and its members have been working with EPA and state water regulators ever since to ensure the Framework can be utilized by communities when appropriate.

There is no issue more central to NACWA’s advocacy than increasing the availability of infrastructure funding for public clean water utilities, which includes increased federal funding to support this critical infrastructure sector. 

Originally founded in 1970 as an organization focused on ensuring appropriate distribution of federal construction grant dollars under the Clean Water Act, the Association has maintained a strong commitment to advancing federal clean water funding.  At the same time, NACWA has also evolved over the years to recognize the importance of other water infrastructure funding mechanisms including municipal bonds, innovative financing approaches, and public-private partnerships.

Publicly owned clean water utilities are “passive receivers” of PFAS, since they do not produce or manufacture PFAS but de facto “receive” these chemicals through the raw influent that arrives at the treatment plant. This influent can come from domestic, industrial, and commercial sources and may contain PFAS constituents ranging from trace to higher concentrations, depending on the nature of the dischargers to the sewer system.

Although the influent is not generated by the utility, the utility is responsible for treating it under the Clean Water Act. Municipal clean water utilities were not traditionally designed or intended with PFAS treatment capabilities in mind. Today, there are no cost-effective techniques available to treat or remove PFAS for the sheer volume of wastewater managed daily by clean water utilities.

NACWA’s advocacy priorities on PFAS include urging source control, empowering the Clean Water Act pretreatment program, preventing public utilities and their customers from unintended liabilities and costs of PFAS management, and advancing research to support sound rulemaking that protects public health and the environment.