GWPC and NGWA Provide Joint Comments to EPA on Proposed 2020 Financial Capability Assessment for CWA Obligations

The Ground Water Protection Council and the National Ground Water Association are jointly providing comments and feedback on the USEPA on the Proposed 2020 Financial Capability Assessment for Clean Water Act (CWA) Obligations. We support funding for communities needing assistance in managing their water resources and for stormwater reuse that may be used as a source of recharge for aquifers as well as supporting the environment. Assessing the financial capability of communities is fundamental to providing financial assistance for adequate needed infrastructure. 

Key points essential to our perspectives are: 

  • Stormwater management is critical in meeting CWA goals 
  • Stormwater management can impact drinking water in positive and negative ways 
  • Funding for stormwater capture and treatment can be critical to achieving greater water security and resilience 
  • Inadequate funding for stormwater projects can jeopardize groundwater quality (lack of treatment prior to injection or infiltration) 
  • Affordability should include all aspects of a water system. In medium to smaller communities there may not be separate water, wastewater, and stormwater utilities. They are often one and the same. EPA should consider all aspects of an individual community’s water system. 

Consistent with these perspectives and with our respective organization’s prior comments concerning the potential impacts of stormwater practices on groundwater, we believe that EPA’s assessment of financial capacity of programs and communities must take into account the cost of groundwater protective design of stormwater infiltration measures and small communities’ limited technical and fiscal capabilities to implement those measures. More detailed comments are in the attached pdf document.

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