ACWA’s mission is to provide high value, science-based practical services to its membership through education, regulatory advocacy, and partnerships for the development of proactive solutions resulting in water resources management that is equitable and environmentally, financially, and organizationally sustainable. ACWA offers technical information, policy analyses, and local government wastewater and stormwater management perspectives on legislative issues in support of that mission.
TOP ISSUES FOR 2021:
Continue to engage with DEQ leadership to work cooperatively with governmental partners to tackle the state’s water quality challenges. This year will be especially challenging in light of the State’s economic and budget conditions. ACWA will advocate for making continued progress on improving performance and maintaining staffing in the permitting program within the 60/40 general fund/fee split, as previously agreed. We will clearly articulate our support for clean water initiatives while showing the real revenue challenges facing our members. We will work to ensure that new requirements provide real water quality benefits and that additional costs are justified.
Disposable wipes flushed down the toilet clog sewer lines and cause sanitary sewer overflows and collection system maintenance problems for ACWA members. Many of these wipes are even labelled as “flushable” or are simply not labeled at all. Clogged pipes, clogged pumps and sanitary sewer overflows cause unnecessary expenses for ratepayers and can create public and worker safety hazards. ACWA has worked with legislators on a Legislative Concept – LC 1178, based on recent Washington legislation (which passed) and California legislation (which did not pass). We will work with and through our League of Oregon Cities and Special Districts Association of Oregon partners to advocate for passage of this bill in the 2021 legislative session.
COVID-19 Relief and Consideration of Wastewater Workers as “Essential”
Wastewater and Stormwater agencies have been seriously impacted by the current economic downturn. Unlike many private businesses, these vital public service providers must continue to operate wastewater and stormwater services without interruption. ACWA members are providing public health services, the value of which is even more obvious during a pandemic. But, they are suffering serious losses of revenue that impact their ability to keep rates affordable for communities that are suffering during this time.ACWA has and will continue to advocate for assistance for our members so that they can continue to provide affordable service, meet clean water requirements and offer payment assistance to low-income residents. ACWA also will continue to advocate for wastewater utility workers to receive COVID-19 vaccinations in the earliest possible phases of the State’s vaccination plan.
Many communities in Oregon were struggling even before the current pandemic and will continue to struggle into the future. ACWA will advocate for assistance programs that are tailored to help those who are most in need so that they can continue to receive these essential services.
Local Control Over Disconnection Policies
ACWA members do not want to disconnect water service to homes during this time, or any other. To this end our members are working hard to reach out to customers to offer discount programs and payment plans, especially in communities of color and low-income communities. However, as a last resort, we need to maintain the option of notifying customers of potential disconnection to be able to compel people to engage with us. Otherwise, we will be forced to pass along the cost to everyone else, impacting our rates and affordability for our entire community.ACWA will resist blanket prohibitions that limit utilities’ ability to address delinquent accounts and long-term failure to pay.
Local governments need to have the ability to maintain fair and equitable charges between new and existing users. Any attempt to limit the methodology to a one-size-fits-all approach, and that creates excessive administrative burdens, will be opposed. Our communities have different challenges, different geography, and different infrastructure systems, and adding to the administrative burdens and restricting SDC eligible capital expenses simply shifts the burden of cost recovery to the ratepayers and increases overall utility costs.
Many communities continue to grapple with the aftermath of rampant wildfires in 2020. Three issues have already been identified:
- In areas with extensive fire damage, our members have lost a significant portion of their ratepayers. This is a huge challenge for those communities that need to repair or replace that infrastructure with a smaller number of ratepayers.
- Some fire-impacted communities had pre-existing problematic septic conditions. Options for switching to a regional system should be explored rather than re-building the same pre-existing problem.
- In some areas, natural infrastructure investments were lost to fires. It is unclear how communities can access funding to rebuild those areas, as they are not accounted for in the same way as more traditional water infrastructure.
- Protection of surface waters from contaminated runoff from fire damaged areas is requiring significant efforts across many local, state and federal agencies.
ACWA will advocate where appropriate for our members’ needs, as well as efforts to protect water quality and restore natural infrastructure.
ACWA will resist any attempt to dictate what materials our engineering professionals must consider in design of infrastructure. Technical decisions related to pipes and other materials should be made by licensed engineers and local communities and should be based on the unique nature of individual water systems. All water pipe materials have significantly different characteristics and are not equally appropriate for all applications. Critical factors such as seismic resilience, wildfire resilience, soil compatibility and resistance to corrosion, and maintenance and life cycle costs must be considered. Imposing new materials mandates not only interferes with sound engineering judgment, but also with the ability of communities to manage their systems as efficiently as possible. Communities should remain free to adopt system-wide best management practices and uniform specifications in the development and maintenance of their water systems to maximize efficiency and control costs.
Biosolids Land Application
ACWA has and will continue to work with partners to inform key legislators about the robustness of the biosolids regulatory program in Oregon, including the safeguards that are in place and the positive aspects of beneficial use, which includes agricultural land application, resource recovery, and greenhouse gas reduction. ACWA will guard against legislative action that limits flexibility for DEQ to innovate the program or creates unnecessary or duplicative regulations for biosolids management practices.
Many ACWA members have a strong interest in increasing energy efficiency and reducing climate/carbon impacts of operations. And while energy is a significant expense for wastewater utilities, investments in energy efficiency and renewable resources require significant capital expense in many cases, which makes these investments challenging. ACWA members are interested in legislative actions that will restore and increase financial incentives for energy efficiency and renewable energy projects in the wastewater sector. Our members need appropriate timelines and assistance that will help us promote both increasing efficiency and moving toward a renewable energy future.
ACWA will continue to advocate for appropriate levels of effort for wastewater treatment plants and other sources that have de minimis emissions levels. We will oppose actions that would be expensive and onerous for Oregon’s publicly owned treatment works (POTWs) that are not cost-effective or provide material public health benefits. ACWA will support streamlined processes to seek waivers from costly risk assessments for low-risk facilities and advocate for an exemption for POTWs because they are highly-regulated pollution reduction facilities that have de minimis air emissions.
Special Public Works Fund
ACWA will support increased funding for Business Oregon, which provides funds for publicly-owned facilities that support economic and community development in Oregon. There is a backlog of eligible projects in Oregon; the fund received $20 million in 2017 after requesting $50 million.
Technical Assistance Program
ACWA recognizes a need for technical assistance funding for many of members with smaller populations. A program should be designed to provide assistance to wastewater and stormwater utilities for negotiating and complying with permit requirements, operational issues, and facilities planning. Most importantly, there must be a clear separation between compliance/enforcement and technical assistance.
PFAS: As with all pollutants created by industry, Per- and Polyfluoroalkyl substances (PFAS) regulation needs to concentrate on reducing the source of these chemicals. Removal at wastewater treatment plants is not the answer for these industrial chemicals; those that profit from their manufacture and sale should be responsible for keeping them out of the environment. The conversation will likely focus this session on implementing alternative materials for fire-fighting foam and issues of disposal of PFAS products.