Mr. Vicory Comes to Washington
It was my privilege to represent WEF on July 25 as a witness at a U.S. House of Representatives hearing that examined the recently released EPA Clean Water Act (CWA) Integrated Planning & Permitting Framework.
Other witnesses included elected officials (the Mayors of Lima, Ohio and Salt Lake City), municipal utility directors (George Hawkins from DC Water and Carter Strickland from New York City), and state water administrators (my friend Walt Baker from Utah).
WEF was an active participant in the development of the Framework and we hosted a webcast for our members immediately after its release.
The framework comes at a time when states and local governments are facing significant resource challenges (not to mention looming additional budget cuts at EPA and in federal grants to states to support water infrastructure). Now more than ever, we must ensure wise investment of precious and finite resources. Nearly 40 years after the passage of the CWA in 1972, this framework provides the potential for a major paradigm shift in urban water management by directing available resources to those projects or initiatives that will produce the greatest public health and water quality return on investment. The CWA has been implemented and enforced as a top-down approach, but this framework should allow a locally driven, bottom-up method to manage and prioritize water programs and requirements. The framework includes adaptive management principles; water professionals have come to realize that an iterative, adaptive management approach makes the most fiscal and environmental sense. EPA and states should include such principles in all permits and enforcement orders moving forward, regardless of which communities volunteer to have an integrated plan.
WEF members, along with other key stakeholders, firmly believe that EPA must stop treating local governments like polluters and instead should embrace them as partners. We know from 40 years of experience that success with the CWA is best achieved when there is cooperation among regulators and stakeholders, including EPA headquarters and regions, states, local governments and utilities, regional agencies, the technical community, and engaged citizens. The framework is a symbol of this collaborative spirit.
As I emphasized during the hearing, policy is not implementation. WEF will not sit idly by and wait to see if this effort succeeds or fails. WEF will monitor implementation and work to ensure that the flexibility afforded by the framework is available to all communities regardless of size or location. We will continue to work with EPA to push for even more flexibility, particularly with regard to affordability; we will provide education and training to our members on integrated planning; and we always will be seeking the most innovative and cost-effective approaches to water infrastructure investment and program management because as we all know, Water’s Worth It